Privacy Policy

 1. Introduction and important information We are committed to protecting and respecting your personal data and  privacy .This privacy policy relates to how we use and collect personal data  from you when you book with us as a guest or visitor to our self-catering  accommodation (the Property), use our services or access our website. It  also relates to our use of any personal information you provide to us by  telephone (including SMS), in written correspondence (including letter and  email), through our social media channels and in person.Please note that: • our website is not intended for children under the age of 18 but we may  collect personal data belonging to children who are guests of the  Property; and • 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 policy of every website you visit.

 Whenever you provide personal data, we are legally obliged to use your  information in line with all applicable laws concerning the protection of such  information; including but not limited to the Data Protection Act 2018 and the  General Data Protection Regulation, as it applies to the UK (UK GDPR),  described in this policy as the “Data Protection Laws”. This privacy policy also forms part of our terms of business and is not  intended to override them. This policy may be amended or updated from time  to time and any revisions will be posted to this page. 2. Who we are and how to contact us • For the purpose of the Data Protection Laws, the data controller is Beach  Breeze Holidays. If you want to request more information about our  privacy policy or information regarding data protection you should contact  us using the details provided below: Beach Breeze Holidays, Twin Oaks, Youngwoods Way, Alverstone  Garden Village, Sandown, Isle of Wight PO36 0HF, United Kingdom Email: beachbreezeholidays@outlook.com Telephone: 07491 640580 and ask to speak to the Privacy Officer. • 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. 3. The data we collect about you • We collect and process personal data. Typically, the personal data we  collect and process will include identity, contract, transactional, profile,  financial and marketing and communications data such as: - Identity Data includes first name, last name, title or other identifier  (such as job title), marital status, date of birth, gender and images. - Contact Data includes billing address, email addresses and telephone  numbers. - Transaction Data includes details about services you have purchased  from us or your visits to our premises. - Financial Data includes bank account and payment card details. - Profile Data includes purchases or orders made by you, feedback and  survey responses. - Marketing and Communications Data includes your preferences in  receiving marketing from us and our third parties and your  communication preferences. Please note that we may collect and/or process other personal data from time  to time. If we ask you to provide any other personal information not described  above, the personal information that you are asked to provide, and the  reasons why you are asked to provide it, will be made clear to you at the point  that you are asked to provide your personal information. • We do not collect, use or share aggregated data, such as statistical or  demographic data for any purpose.  • We do not routinely collect any Special Categories of Personal Data  about you (this includes details about your race or ethnicity, religious or  philosophical beliefs, sexual orientation, political opinions, trade union  membership, information about your health, and genetic and biometric  data). However, we will collect any health information we need to  provide special assistance services requested under the booking or  where we need to record and report an incident or accident occurring at  the Property. Nor do we collect any information about criminal  convictions and offences. • We only collect data from you directly or via third parties (see the  section Third Parties below). • It is important that the Personal Data we hold about you is accurate and  current. We cannot be held responsible for any inaccurate or  incomplete data on our system arising out of your default in this regard.  Please keep us informed if your Personal Data changes during your  relationship with us. 4. How is your personal data collected? • We use different methods to collect data from and about you including  through: - Direct interactions. You may give us your Identity, Contact, Profile and  Financial Data by filling in forms or by corresponding with us by post,  phone, messaging service, email or otherwise. This includes personal  data you provide when you: - book our Property; - create an account on our website; - subscribe to our additional service(s); - request marketing to be sent to you; - enter a promotion or survey; or - give us feedback or contact us. - Visiting the Property. We may collect your usage Data through our  inspection of the Property. - Third parties or publicly available sources. 5. 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 (for example, to provide you with our services). In this case, we may  have to cancel all or part of a service you have with us but we will notify you if  this is the case at the time. 6. How your data will be used • We use information held about you to: - carry out our obligations arising from any contracts entered into  between you and us and provide our services, including any third party  services we make available to you; - carry out feedback and research on our services; and - notify you about changes to our services. • We never sell your data to third parties or allow third parties to contact  you without your permission. • We share your data with third parties where there is a legal obligation for  us to do so or we have identified a valid lawful basis as set out in the  table below (please also see clause 7 below). We may process your  personal data without your knowledge or consent where this is required  or permitted by law. • We have set out below, 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 below.  The following shows the Reason/Purpose/Activity (Purpose),   The type of Data used (Data),  The lawful basis for processing, & basis of legitimate interest (Basis): Purpose: To register you as a guest or visitor of the Property   (including any vehicles). Data: Identity, Contact Basis: Performance of a contract with you to ensure unauthorised   visitors do not attend or occupy the Property. Purpose: To provide our self-catering accommodation and connected  service(s) to you and to process related transactions,  including: Manage payments, fees and charges;   Collect and recover money owed to us. Data: Identity, Contact, Transaction, Financial,   Marketing and Communications Basis: Performance of a contract with you;  To recover debts due to us. Purpose: To provide you with requested special assistance. Data: Identity, Contact, Health (Special Category Data limited to   what is necessary for the provision of special assistance) Basis: Explicit consent Purpose: To manage our relationship with you which will include:  Notifying you about changes to our terms or privacy policy;  Asking you to leave a review or take a survey. Data: Identity, Contact, Profile, Marketing and Communications Basis: Performance of a contract with you;  Necessary to comply with a legal obligation;  Necessary for our legitimate interests (to keep our records updated  and to assess how customers use our products/services) Purpose: To record incidents and accidents occurring at the Property. Data: Identity, Contact, Health (Special Category Data) Basis: Necessary to comply with a legal obligation (health and safety);  To ensure the Property is fit for use by guests and to resolve  complaints;  We may also use this information to exercise and defend our legal  rights and may be required by law to process this information. Purpose: To enable you to enter a competition or complete a survey. Data: Identity, Contact, Profile, Marketing and Communications Basis: Performance of a contract with you Purpose: To administer and protect our business and our website  (including troubleshooting, data analysis, testing, system  maintenance, support, reporting and hosting of data). Data: Identity, Contact Basis: Necessary to comply with a legal obligation Purpose: To measure or understand the effectiveness of the advertising  we serve to you Data: Identity, Contact, Profile, Marketing and Communications Basis: To study how customers use our products/services, to develop  them, to grow our business and to inform our marketing strategy 7. Lawful basis for processing • We only process your data (which may include providing it to a third  party) where we have identified a valid lawful basis to do so. These are  as follows: - Contractual obligation – means processing that is necessary to  comply with our obligations arising out of a contract, for example,  where you have bought services from us we will use the personal data  you provide to fulfil our contractual obligations. - Consent – We will seek to obtain your consent to process: • your data outside our contractual obligations (see above) unless we  have identified a Legitimate Interest (see above); and • any special category data. - Legal obligation – We may process your data where we it is  necessary for us to do so to comply with the law. 8. THIRD PARTIES and sharing information • We will keep your information within the organisation except where  disclosure is required or permitted by law or when we use third party  service providers (data processors) to supply and support our services to  you. We have contracts in place with our data processors. This means  that they cannot do anything with your personal data unless we have  instructed them to do so. They will not share your personal data with any  organisation apart from us. They will hold it securely and retain it for the  period we instruct. • The following list sets out the categories & locations of potential  recipients of personal data: - SERVICE PROVIDERS WITHIN THE UK… • IT Support Services • Secure document disposal service • Banks • Online payment providers • Accountants • Insurers • Solicitors • Feedback aggregators and collectors • Couriers • Marketing agencies - SERVICE PROVIDERS WITHIN THE UK/USA/EU etc… • Email provider • Website provider • Software provider • Holiday booking agents • Travel companies • We may disclose your Personal Data to any competent law enforcement  body, regulator, government agency, court or other third party where we  believe disclosure is necessary: (i) as a matter of applicable law or  regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to  protect your vital interests or those of any other person. • We may also be required to share your Personal Data as part of any  sale, transfer or merger of our business or assets (or parts thereof). Such  disclosure will be subject to the buyer’s processing of your Personal Data  on terms equal to the protections afforded to you by this policy. • In addition, third parties may provide us with personal data and they  should only do so where the law allows them to. This may vary our  position as Data Controller under clause 1. 9. Information security • We use appropriate technical and organisational measures to protect the  personal information that we collect and process about you. The  measures we use are designed to provide a level of security appropriate  to the risk of processing your personal information. 10. Marketing • We may use your Identity, Contact 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 you  have not opted out of receiving that marketing. • We strive to provide you with choices regarding certain personal data  uses, namely around marketing and advertising. In particular: - We will always obtain your express opt-in consent before we share  your personal data with any third party for marketing purposes; and - You can ask us or third parties to stop sending you marketing  messages at any time by following the opt-out links on any marketing  message sent to your or by contacting us at any time. 11. International transfers • Your data is stored by us and our processors in the UK. However, some  of our external third parties are based outside the UK. Whenever we  transfer your personal data out of the UK, we ensure a similar degree of  protection is afforded to it by ensuring at least one of the following  safeguards is implemented. We will either: - transfer your personal data to countries that have been deemed to  provide an adequate level of protection for personal data by the  European Commission; or - ensure that standard contractual clauses (SCCs) or, International Data  Transfers Agreements (IDTAs) as required by law from time to time are  in place and we have received assurances that an adequate level of  protection of the personal data is achieved (based on a case by case  assessment of the circumstances of the transfer), including adequate  technical and operational measures in place to protect the personal  data. • Please contact us if you want further information on the specific  mechanism used by us when transferring your personal data out of the  EEA. 12.Data security • 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. 13.Data retention • We will only retain your personal data for as long as reasonably  necessary to fulfil the purposes we collected it for, including for the  purposes of satisfying any legal, regulatory, tax, accounting or reporting  requirements. We may retain your personal data for a longer period in  the event of a complaint or if we reasonably believe there is a prospect of  litigation in respect to our relationship with you. • 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, regulatory, tax, accounting or other requirements. • By law we have to keep basic information about our clients (including  Contact, Identity, Financial and Transaction Data) for 6 years after they  cease being clients. • In some circumstances you can ask us to delete your data (see below for  further information). • 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.  Please see clause 2. 14.Your rights • Under the data protection laws your rights are: - To be informed – We must make this privacy policy (sometimes  referred to as a privacy notice) available to you and be transparent  over how we process your data. - Access – You are entitled to know what details we hold about you and  why. We strive to be as open as we can be in terms of giving people  access to their personal data. You can find out if we hold any of your  personal data by making a formal request under the data protection  laws. Such requests should be made using the contact details provided  in this policy. If we do not hold information about you we will confirm  this in writing at the earliest opportunity. If we do hold your personal  data we will respond in writing. Our response will: • confirm that your data is being processed; • verify the lawfulness and the purpose of the processing; • confirm the categories of personal data being processed; • confirm the type of recipient to whom the personal data have been  or will be disclosed; and • let you have a copy of the data in format we deem suitable or as  reasonably required by you. - Rectification – We are obliged to correct or update your details. We  will correct or update your data without delay provided you make the  request in writing to the contact details provided in this policy, clearly  specifying which data are incorrect or out of date. - Erasure – This is also known as the right to be forgotten. Under Data  Protection Laws you have the right to require us to erase your personal  data under specific circumstances. A request for your personal data to  be deleted will be decided on a case by case basis and should be  submitted in writing to the contact details provided in this policy. - Restrict processing – You have the right to ‘block’ or suppress the  processing by us of your personal data. - Portability – You have the right to obtain the personal data that you  have provided to us in a commonly used machine-readable format and  reuse it with a different provider. - Object – You have the right to object to us processing your data in  certain circumstances. You have an absolute right to stop your data  being used for direct marketing, but in other circumstances we may still  be allowed (or required) to process your personal data if we can show  you that we have a compelling reason for doing so. - Rights in relation to automated decision making and profiling –  We do not use automatic decision making or profiling. - Withdraw consent. Where you have given us consent to process your  personal data, you can withdraw that consent at any time either by  contacting us using the details set out in this policy, or by following the  opt-out links in electronic messages where relevant. We do not  penalise individuals who wish to withdraw consent and we act on  withdrawals of consent as soon as we can. • Please note that: - in certain circumstances Data Protection Laws may relieve us of  some of our obligations to you under the rights summarised above;  and - you may need to provide identification in order to prove who you are  if you wish to invoke any of your rights as provided by the data  protection laws and as summarised above. • If you agree, we will try to deal with your request informally, for example  by providing you with the specific information you need over the  telephone. 15.CHANGES TO THE PRIVACY POLICY We keep our privacy policy under regular review. This version was last  updated on 14/05/2024