1. INTRODUCTION
Welcome to Luxury Boltholes. We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you about how we look after your personal data when you visit our website and when you use our services, and it will tell you about your privacy rights and how the law protects you.
2. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this Privacy Policy
This privacy policy aims to give you information on how Luxury Boltholes collects and processes your personal data through your use of this website and our services, including any data you may provide when you book a property, register as a property owner, sign up to our newsletter, or take part in a promotion.
This website is not intended for children, and we do not knowingly collect data relating to children.
Controller
Luxury Boltholes is the controller and responsible for your personal data (referred to as "we," "us," or "our" in this privacy policy).
3. THE DATA WE COLLECT ABOUT YOU
Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped as follows:
For Guests:
- Identity Data: including first name, last name, title, date of birth
- Contact Data: including billing address, delivery address, email address, and telephone numbers
- Professional Data: including job title and employer (when required by property owners for vetting purposes)
- Financial Data: including bank account and payment card details
- Transaction Data: including details about payments to and from you and other details of products and services you have purchased from us
- Technical Data: including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website
- Profile Data: including your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses
- Usage Data: including information about how you use our website and services
- Marketing and Communications Data: including your preferences in receiving marketing from us and our third parties and your communication preferences
For Property Owners:
- Identity Data: including first name, last name, title, date of birth, identification documents
- Contact Data: including address, email address, and telephone numbers
- Financial Data: including bank account details, tax identification numbers, and other information required for HMRC financial data submissions
- Property Data: including details about your property, availability, pricing, and amenities
- Transaction Data: including details about payments to and from you
- Verification Data: including information collected through our third-party identity verification service
4. HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you including through:
Direct interactions
You may give us your Identity, Contact, Financial, and other data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Book a property or inquire about a booking
- Register as a property owner
- Subscribe to our service or publications
- Request marketing to be sent to you
- Enter a competition, promotion, or survey
- Give us feedback
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. We use:
- Google Analytics
- Google Search Console
- Microsoft Clarity
Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources such as:
- Identity verification services for property owners
- Analytics providers
- Advertising networks
- Search information providers
5. HOW WE USE YOUR PERSONAL DATA
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:
- Where we need to perform the contract we are about to enter into or have entered into with you
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
- Where we need to comply with a legal obligation
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data:
For Guests:
- To register you as a new customer
- To process and deliver your booking
- To share necessary information with property owners (including job title for vetting when required)
- To manage our relationship with you
- To administer and protect our business and this website
- To deliver relevant website content and advertisements to you
- To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences
For Property Owners:
- To register you as a property owner
- To verify your identity through our third-party verification service
- To process payments to you
- To submit required financial data to tax authorities including HMRC
- To manage our relationship with you
- To market your property to potential guests
- To administer and protect our business and this website
6. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes outlined in this privacy policy:
- Property owners (if you are a guest)
- Potential guests (if you are a property owner)
- Third-party identity verification services
- Tax authorities, regulators, and other authorities who require reporting of processing activities in certain circumstances
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets
- Service providers acting as processors who provide IT and system administration services
7. INTERNATIONAL TRANSFERS
We operate internationally and may transfer your data outside your country of residence. When we do, we ensure a similar degree of protection is afforded to it by implementing appropriate safeguards:
- Where we use providers based in the US, we may transfer data to them if they are part of frameworks which require them to provide similar protection to personal data shared between Europe, the UK, and the US.
- Where we transfer your personal data to countries not deemed to provide an adequate level of protection, we will use specific contracts approved for such transfers.
8. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized 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.
9. DATA RETENTION
We will only retain your personal data for as long as necessary to fulfill 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 unauthorized 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.
10. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data, including:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of these rights, please contact us.
11. STATE-SPECIFIC PRIVACY NOTICES (UNITED STATES)
California Privacy Rights
If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), including:
- The right to know what personal information we collect about you
- The right to delete personal information we have collected about you
- The right to opt-out of the sale or sharing of your personal information
- The right to non-discrimination for exercising your privacy rights
Virginia Privacy Rights
If you are a Virginia resident, you have specific rights under the Virginia Consumer Data Protection Act (VCDPA), including:
- The right to confirm whether we are processing your personal data
- The right to access your personal data
- The right to correct inaccuracies in your personal data
- The right to delete personal data
- The right to obtain a copy of your personal data
Colorado, Connecticut, and Utah Privacy Rights
Residents of Colorado, Connecticut, and Utah have similar rights regarding personal data under their respective state privacy laws.
12. COOKIES
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
13. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. This version was last updated on the date noted at the top of this policy. 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 if your personal data changes during your relationship with us.
14. CONTACT DETAILS
If you have any questions about this privacy policy or our privacy practices, please contact us at:
Luxury Boltholes North House, Chapel Lane, West Wittering, Chichester, West Sussex, PO20 8QG, United Kingdom
Website: https://www.luxuryboltholes.com Email: [email protected]
You have the right to make a complaint at any time to the supervisory authority for data protection issues in your country of residence.
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