What is the purpose of this privacy policy?

This privacy policy is to tell you what personal data we collect from you and why and what we will do with this data. It also tells you about some of the key rights which you have under data protection laws. From 25 May 2018 onwards, you and your personal data will be protected by the EU General Data Protection Regulation (which is otherwise known as EU GDPR) and a new UK Data Protection Act 2018. In this privacy policy, we refer to this legislation as data protection laws.

 

We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are otherwise permitted to do in accordance with data protection laws.

 

What is our role in relation to your personal data?

 

For the purposes of data protection laws, we, KeyNstay and affiliates, are data controllers in respect of the personal data you provide us with.

 

What is my personal data and what do you mean by process?

 

When we refer to personal data, we mean any information which relates to an identified or identifiable individual.

 

Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties, and erasing it.

 

What personal data will we collect from you and why?

We collect personal data from and about you whenever you use our services, or if you are in touch with us in any way, whether this is directly or indirectly. You may, for example, make your booking or booking inquiry through a travel agent or you may provide personal information to a third party involved in your travel plans such as a local service supplier. We also collect data from publicly available sources which we use to profile clients internally for marketing purposes.

Examples of personal data that we might collect include (but are not limited to):

 

• names of all persons traveling
• contact details (such as telephone number, postal and e-mail addresses) of the person making the booking
• information in respect of any medical condition, disability, or reduced mobility which may affect any person traveling – this comes within special categories of personal data (see below)
• Your group composition; the ages of people in your group, their dates of birth, gender, nationality, and passport information
• Next of kin information
• dietary information
• notes about our interactions with you
• copies of documents such as passport or driver’s license
• Your feedback on our service, including from third parties.

CCTV footage is used to keep our properties secure.

 

For an inquiry, the personal data we will need to process is likely to include the name and contact details of the person making the inquiry.

 

For a booking or booking inquiry, we will process your personal data (other than any data which comes within special categories of personal data – see below) on the basis that this is necessary for the performance of your contract with us or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency situation).

 

If you wish to receive brochures or other promotional material from us, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address.

 

What are special categories of personal data?

Personal data which concerns your health or which reveals your racial or ethnic origin or your sexual orientation are special categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the booking and provision of travel arrangements.

 

Generally speaking, the processing of special categories of personal data requires your explicit consent.

 

Accordingly, information concerning any disability, medical condition, restricted mobility, or another health-related issue that may affect your travel arrangements (and related requirements) as well as dietary restrictions which disclose your religious beliefs or a health issue are special categories of personal data. We will ask for your consent to our processing of this information at the time you make your booking or your booking inquiry.

 

Who may we provide your personal data to?

Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen arrangements (for example property owners, caretakers, experience providers, cooks, car hire companies, restaurants, support staff) together with any other third party (for example banks and/or credit card companies and/or merchant account providers and/or booking software providers) who need this information so that we can arrange for your holiday to be provided.

 

The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.

 

Certain information may also be passed on to security or credit checking companies.

We may also make personal data available to other companies who provide services on our behalfs, such as mailing brochures and marketing material.

 

We only provide third parties with the personal data they require in order to deliver their services.

 

Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.

 

Where will we process your personal data?

Your personal data may be processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland, and Liechtenstein.

 

We may also process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.

 

How do we protect your personal data?

We take appropriate technical and organizational measures to protect against unauthorized or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorized or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.

 

Can we use your personal data to send you information about our properties or other services in the future?

We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so or, in relation to e-mail marketing, where we comply with EU GDPR. EU GDPR permits us to send you e-mail marketing where you have previously provided us with your e-mail address in the course of entering into a contract with us and we wish to e-mail you marketing material about our similar services or products. You will of course be given the opportunity to opt-out of receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send you any e-mail marketing.

 

You may provide your consent by opting to receive marketing material either online or by email or by telephone. You may also choose in what ways you are happy to receive communications from us. You may, for example, be happy to receive information and offers by post and e-mail but not by telephone.

 

Can you withdraw your consent to our processing of your personal data?

Yes, you can withdraw your consent to receiving marketing material or other communications from us, either generally or in any particular way, at any time by emailing us at [email protected]. Alternatively, you can telephone us.

 

How can you find out what information we are holding about you?

You are entitled to ask us (by e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within 1 month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.

 

What should you do if the personal data we are holding is inaccurate, out of date, or incomplete?

If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within 3 months if the rectification request is complex.

 

 

How long can we retain and process your personal data?

We will not process your personal data in a form that enables you to be personally identified for any longer than is necessary in order to fulfill the purpose for which it was originally collected or for any other legitimate business purpose.

 

Where your personal data has been provided for the purpose of the holiday arrangements or other services you have contracted, we are entitled to retain this data for a period of 6 years after those arrangements have been completed.

 

In certain limited circumstances, we may be able to retain it for a longer period.

 

If you have consented to receive marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.

 

Can you ask us to delete your personal data?

Yes, you can ask us to erase your personal data in certain circumstances, for example where you have withdrawn your consent to further marketing material where the data in question has only been processed for this purpose. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.

 

Can this privacy policy be changed?

Yes, from time to time we may need to make changes to this privacy policy. These may be required as a result of changes in data protection laws or in the guidance issued by regulators such as the European Commission.

 

Does your website use cookies?

Yes, as is the common practice, our website uses cookies. A ‘cookie’ is a small data file which our website server stores on your computer in order to collect information about your visit and to remember you when you visit again at a later date. The main purpose of a cookie is to identify users and to personalize their visits by customizing web pages for their use. We may also use third parties who will collect data that is not personally identifiable to analyze site visits and carry out other similar activities. In the course of doing so, they may place their own cookies on your computer so that they can collect information about your visit. You may if you wish disable or delete such cookies through your internet browser. However, doing so may mean you will be unable to access our website or parts of it, your experience of our website may be adversely affected, and/or you may not receive information that is relevant to your personal interests.

 

If you’ve used our website we may use advertising on other websites and on social media sites and apps, to remind you about the services we provide based on your browsing.

 

What should I do if I have a complaint about the processing of my personal data?

If you have any complaints about the way in which your personal data has been dealt with, please let us know by e-mail at [email protected].
We will investigate and respond to you as soon as we reasonably can.

 

If you remain dissatisfied, you may complain to the EUROPEAN DATA PROTECTION SUPERVISOR.
For further details, see https://edps.europa.eu/.

 

See also our Terms of Use.