Welcome to our privacy notice.
We respect your privacy and are committed to protecting your personal information, which we call “personal data”. This privacy notice will tell you how we look after your personal data and about your privacy rights. It supplements any other notices and is not intended to override them. We have tried to be brief and clear. We are happy to provide any additional information or explanation.
WHO WE ARE
Surf Bay Holidays – (Data Controller referred to as ‘we/us/our’)Data Protection Manager – Ray Ford – IT Manager, Surf Bay Leisure, Winkleigh, Devon EX19 8DW 01837 680100 email [email protected] You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO) (www.ico.org.uk). We would appreciate the chance to deal with your concerns first.
This version was last updated on 24th May 2018 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed of any changes.
HOW WE COLLECT YOUR PERSONAL DATA
You may give us data orally or by filling in forms or by corresponding with us by post, phone, email or otherwise, for example when you:
- enter into a contract with us or contact us about doing so;
- contact us about any contract we have with you;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- give us some feedback.
HOW WE USE YOUR DATA
We will only use your personal data when the law allows us to. We have set out below how and why we plan to use your personal data.
|Purpose/Activity||Lawful basis for processing including basis of legitimate interest|
|To register you with our business||Performance of a contract with you|
|To perform any contract with you including:
(a) Managing payments, fees and charges
(b) Collecting and recovering money owed to us
(c) Addressing any breach
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Necessary for our legitimate interests (to ensure compliance with contract terms)
|To manage our relationship with you which will include:
(b) Notifying you about changes to our business which are relevant to you
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how people use our business)
|To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|Where you have purchased a product or service from us||Necessary for our legitimate interests (to contact you in respect of any field service actions, warranty matters, product recalls or any similar relevant notifications)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Necessary for our legitimate interests (to develop and grow our business)|
|Asking you to partake in a review, prize draw, competition or complete a survey||Necessary for our legitimate interests (to study how people use our business, to develop and grow our business)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Necessary for our legitimate interests (to study how people use our business, to develop and grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, relationships and experiences||Necessary for our legitimate interests (to define types of people for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
PROMOTIONAL OFFERS FROM US
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.
We may then use your personal data to send you marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we use your personal data for any other marketing purpose or share it with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting our DPM.COOKIES
CHANGE OF PURPOSE
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.However, if we need to use your personal data for a new purpose and the law allows us to do so, we will notify you and explain the legal basis for our actions.
VISITORS TO OUR WEBSITE
If we want to collect personally identifiable information through our website, we will be up front about this.When someone visits our website, we may use a third-party service to collect standard internet log information and details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. This information is only processed in a way which does not identify anyone.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
IF YOU FAIL TO PROVIDE PERSONAL DATA
If you do not provide personal data to us and this would prevent us from performing the contract we have or are trying to enter into with you, or place us in breach of the law, we may have to cancel our contract. We will notify you if this is the case.
DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 to help us run our business or carry out our obligations to you.
We may share your information with selected third parties including:
- Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
- Our professional advisers including lawyers, bankers, auditors and insurers.
- HM Revenue & Customs, regulators and other authorities
- Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others.
- Analytics and search engine providers that assist us in the improvement and optimisation of our site.
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Surf Bay Holidays or substantially all of either of their assets are acquired by a third party, in which case personal data held by them about its customers will be one of the transferred assets.
We do not transfer your data outside the European Economic Area.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL WE USE YOUR PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.You can ask us about the retention periods for different aspects of your personal data by contacting our DPM. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
We do not knowingly collect data relating to children.
No fee usually required You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
When visiting our web pages, we would like to use tracking technologies which record information about you automatically. This can include using a cookie which would be stored on your browser.Without such technology it is possible that certain functionality of this site might be affected. This information does not identify you personally. We automatically collect and store only the following information about your visit:-
- The internet domain and IP address from where you access our website;
- The type of browser software and operating system used to access our website;
- The date and time you access our website;
- the pages you enter, visit and exit our website from;
- If you linked to our website from another website, the address of that website.
We use this information to help us identify click stream patterns, to improve our website and to learn about the number of visitors to our website and the types of technology our visitors use. We only use this information to ensure that our web pages stay compatible with a selection of browsers and systems and thereby ensure that the pages appeal to a wide audience. We do not track or record information about individuals and their visits.
If you have any questions about this privacy statement, the practices of this site, or your interactions with Surf Bay Holidays please contact us.