Last updated: 5th August 2020
- Introduction
At Exmoor Character Cottages the privacy and security of our customers, clients and visitors are of paramount importance. Exmoor Character Cottages is committed to protecting the data you share with us. This privacy policy explains how Exmoor Character Cottages processes information that can be used to directly or indirectly identify an individual (“Personal Data”) collected through use of its website and booking platform.
For the purposes of this policy, Exmoor Character Cottages defines the term “User” as an entity with which Exmoor Character Cottages has an established relationship, and the term “Visitor” as an individual that visits our front-end website (for example www.exmoorcharactercottages.co.uk).
Any information stored by Exmoor Character Cottages is treated as confidential. All information is stored securely and is accessed by authorised personnel only. Exmoor Character Cottages implements and maintains appropriate technical, security and organisational measures to protect Personal Data against unauthorised or unlawful processing and use, and against accidental loss, destruction, damage, theft or disclosure.
- Collection and use
2.1 General
The following sections cover the specifics of each of the two groups from which data is collected: website Visitors and Users.
2.2 Website Visitors
By visiting this website, you consent to the collection and use of your Personal Data as described herein. If you do not agree with the terms set out herein, please do not visit this website.
As required by applicable law (in the EEA, GDPR), we will seek your explicit consent to process Personal Data collected on this website or volunteered by you. Kindly note that any consent will be entirely voluntary. However, if you do not grant the requested consent to the processing of your Personal Data, the use of this website may not be possible.
Exmoor Character Cottages may collect, record and analyse information of Visitors to its website. We may record your IP address and use cookies. Exmoor Character Cottages may add information collected by way of pageview activity. Furthermore, Exmoor Character Cottages may collect and process any Personal Data that you volunteer to us in our website’s forms, such as when you make an enquiry, booking or sign up for information and newsletters.
If you provide Exmoor Character Cottages with your social media details, Exmoor Character Cottages may retrieve publicly available information about you from social media, however this information is not routinely captured for usage by ourselves.
Personal Data which may be captured from social media (but not used by ourselves) could comprise your IP address, first and last name, your postal and email address, your telephone number, your job title, your areas of interest, your route to visiting Exmoor Character Cottages. Exmoor Character Cottages are unable to control the information collected by social media and users should refer to the T&C of the social media channel for further information.
Exmoor Character Cottages gathers data about visits to the website, including numbers of Visitors and visits, Geo-location data, length of time spent on the site, pages clicked on or patterns of visits. This information is not shared with any third party other than to provide insight and analysis relating to the effectiveness and return on investment of marketing campaigns.
2.2.1 Purpose of processing personal data
Exmoor Character Cottages uses the collected data to communicate with Visitors, to customise content for Visitors, to show ads on other websites to Visitors, and to improve its website by analysing how Visitors navigate its website.
2.2.2 Sharing personal data
Exmoor Character Cottages may also share such information with similarly compliant service vendors or contractors in order to provide a requested service or transaction or in order to analyse the Visitor behaviour on its website.
Exmoor Character Cottages uses the services of SuperControl to manage bookings and availability calendars on behalf of website Visitors. We also use SuperControl to manage bookings made via other channels (such as by ‘phone, email or for repeat bookings) and for these processes, SuperControl are classified as a third-party / Joint Data Controller.
Exmoor Character Cottages uses <SagePay> to authorise payments for bookings made by Visitors on its website. For these payment processes, SagePay are classified as a third-party Data Processor.
Both SuperControl and SagePay only process data which is pertinent to task and will not collect or distribute data to any other third party outside of their own legitimate interest policies.
Exmoor Character Cottages utilises the services of Master Cancel (InsureStays Insurance Agency LLC) to provide peace of mind warranties for guest bookings from 5th August 2020. In the event of a claim against this policy, Master Cancel may interrogate booking information captured within SuperControl to approve or decline the case. Master Cancel does not interrogate SuperControl at any other time, therefore Master Cancel are classified as a third-party Data Processor.
2.2.3 Cookies
Cookies are small pieces of information sent by a website to a Visitor’s hard disk. Cookies cannot be used to run programs or deliver viruses to your computer. By continuing to visit the website, you agree to the placement of cookies on your device. If you choose not to accept our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be.
2.2.4 Links to other sites
Although very unlikely, please be aware that while visiting our site, Visitors could follow links to other sites that are beyond our sphere of influence. Exmoor Character Cottages is not responsible for the content or privacy policy of these other sites.
2.3 Users
2.3.1. General
In order to provide services to its Users, Exmoor Character Cottages collects certain types of data from them. Data entered or transferred into Exmoor Character Cottages by Users such as texts, questions, contacts, media files, etc., remains the property of the User and may not be shared with a third party by Exmoor Character Cottages without express consent from the User.
2.3.2 Collection of User data
We collect no user registration content from Visitors and will only ask for personal information during an enquiry or when Visitors undertake a booking or payment.
2.3.3 Geographical location
Exmoor Character Cottages operates in a number of data regions. An Exmoor Character Cottages “Data Region” is a set of data centres located within a defined geographical area where User and Respondent data is stored. For Exmoor Character Cottages, all Users are processed within the European Data Region (EEA).
Our third-party Processors and Joint Data Controllers process data outside of our own Data Region. In this case, data protections are in place to ensure that data is protected to the same standard as within the EEA.
2.3.4 Processing in the European Economic Area (EEA)
For Users with technology assets located in Exmoor Character Cottages’ European Data Region, all processing of Personal Data is performed in accordance with the Directive and local legislation of Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and Exmoor Character Cottages processing will take place in accordance with the GDPR.
2.3.5 Controller
Exmoor Character Cottages processes Personal Data both as a Processor and as a Controller, as defined in the Directive and the GDPR:
The Exmoor Character Cottages entity which you as a User entered an agreement with when using Exmoor Character Cottages’ platform, will be the Controller for User data, as outlined above in “Collection of User data” section.
Exmoor Character Cottages adheres to the GDPR from May 25th, 2018. Consequently, Exmoor Character Cottages processes data provided by its Users in the European Economic Area (EEA) or in similarly classified jurisdictions.
All hosting is performed in accordance with the highest security regulations and secure encryption.
All transfers of data internally within the EEA is carried out in accordance with this data processing agreement.
2.3.6 Special Category Data
We will only process and retain data which is essential to undertake reservations, bookings, payments and to comply with relevant legislation. Special Category Data (SCD) may apply (but are not limited) to: Passports, ID documents, credit card details held for security deposits, Titular information (such as official titles which may lead to SCD classification) etc.
SCD is held, processed, erased or destroyed in line with our stringent security protocols, however if you wish not to provide us with SCD, please contact us in advance to make alternative arrangements if possible.
- Retention and deletion
Exmoor Character Cottages will not retain data longer than is necessary to fulfil the purposes for which it was collected or as required by applicable laws or regulations. Subscribers to Exmoor Character Cottages marketing services will be regularly contacted to provide options to opt-out of receiving news and information.
Third party Data Processors and Joint Data Controllers may have to retain data under legitimate interest to fulfil regulatory obligations. For payment processing firms, data may be securely held for up to seven years following the date of transaction.
- Acceptance of these Conditions
We assume that all Visitors of our website have carefully read this document and agree to its contents. If someone does not agree with this privacy policy, they should refrain from using our website. We reserve the right to change our privacy policy as necessity dictates. Continued use of Exmoor Character Cottages website after having been informed of any such changes to these conditions implies acceptance of the revised privacy policy. This privacy policy is an integral part of Exmoor Character Cottages.
- Our Legal Obligation to Disclose Personal Information
We will reveal a user’s personal information without his/her prior permission only when we have reason to believe that the disclosure of this information is required to establish the identity of, to contact or to initiate legal proceedings against a person or persons who are suspected of infringing rights or property belonging to Exmoor Character Cottages or to others who could be harmed by the User’s activities or of persons who could (deliberately or otherwise) transgress upon these rights and property. We are permitted to disclose personal information when we have good reason to believe that this is legally required.
- Data Protection Officer
Exmoor Character Cottages have an external ‘Data Protection Officer’ who is responsible for matters relating to privacy and data protection. This Data Protection Officer can be reached at the following address:
- For Further Information
If you have any further questions regarding the data Exmoor Character Cottages collects, or how we use it, then please feel free to contact us by email at: dpo@exmoorcharactercottages.co.uk
