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Welcome to the Villa Plus Privacy Notice. Villa Plus Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you. We keep our website policies under regular review and will update the webpages as required. Please also refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
Purpose of this privacy notice
This privacy notice aims to give you information on how Villa Plus collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc. This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Villa Plus Ltd is the controller and responsible for your personal data (collectively referred to as "Villa Plus", "we", "us" or "our" in this privacy notice). We have appointed a data controller who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exerciseyour legal rights, please contact the data controller using the details set out below.
Our full details are:
Full name of legal entity:Villa Plus Limited
Name or title of Data Compliance Officer: Anuradha De
CCTV Enquiries: firstname.lastname@example.org
DPR Enquiries: GDPRenquiries@villplus.com
Postal & Registered Address: Drover House, 16 Adelaide Street, St. Albans, AL3 5BH
Telephone number:01727 836686
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
The policy was reviewed on the 23rd May 2018 and was last updated on 1st October 2018. The data protection law in the UK changed on 25 May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
This 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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(A) Identity Data
(B) Contact Data
(C) Financial Data
(D) Transaction Data
(E) Technical Data
(F) Profile Data
(G) Usage Data
(H) Marketing and Communications Data
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice. Special Categories of Personal Data We collect the following special categories of personal data about you.
Details about your:
We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so. You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking. If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellations in clause 1 of our Booking Terms and Conditions /booking-conditions will become payable. If you fail to provide personal data Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into, with you. In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book. In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions /booking-conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.
We use different methods to collect data from and about you including through:
(A) Direct interactions You may give us your Identity information, Contact information and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
(C) Third parties We may receive personal data about you from various third parties as set out below:
(D) Contact, Financial and Transaction Data from providers of technical, payment and delivery services, such as Creditcall as intermediary payment gateway for card payments on Worldpay transactions based inside the EU and Barclays based inside the EU. (E) Identity and Contact Data from data brokers or aggregators such as CACI, based inside the EU. (F) Identity and Contact Data from publicly availably sources, such as Companies House and the Electoral Register based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by using this link /sign-up
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on, to process your personal data where more than one ground has been set out in the table below.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms: a sign-up link: /sign-up Subscription preferences or Subscription requests can be managed by you, from the above link.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
Marketing Loyalty programme
Villa Plus may on occasion send you a gift or item, as an existing customer loyalty gesture. There is no inducement or requirement to make a further booking. Should you not wish to participate in this programme, please email our Marketing team at: email@example.com
We will get your express opt-in consent before we share your personal data with any company outside Villa Plus for marketing purposes.
You can ask us to stop sending you marketing messages at any time by entering your email address and clicking the Unsubscribe button from the /sign-up page. Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us, as a result of a purchase of travel services or other such transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
(A) Internal Third Parties as set out in the Glossary below, section 10
(B) External Third Parties as set out in the Glossary below, section 10
(C) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your booking data within the Company and if shared outside the EEA, is only within the context of an intra-group transfer (such as our IT development team) Booking data held in databases outside the EEA for the purpose of ensuring that all required information has been provided to confirm your booking, will be automatically deleted after a 1 week period, post processing and transfer to our central booking system. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA. For all other transfers of data that are unrelated to the provision of travel services to you, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
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 you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting, insurance, dispute resolution or other related requirements in order to conduct our business, such as the detection and preventions of fraud or other illegal activities. 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. In addition to the above, by law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. If you have a question about a specific retention period for certain types of personal data we process about you, please contact us GDPR DSAR LINK In some circumstances you can ask us to delete your data: see Request erasure below for further information. 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us at: GDPRenquiries@villaplus.com
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.
What we may need from you
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.
Time limit to respond
We will 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.
Guidance: Villa Plus operates CCTV cameras which are fitted to the exterior of the building and records external images of its premises 24/7. These have been installed for the safety and security of its employees and visitors whilst on company premises.
YOUR LEGAL RIGHTS
You have the right to: