Privacy Policy
This is the privacy notice of Holidaycom
Limited trading as Lettings U Know, company registration number 7426555.
Our registered office is at 4 Chartfield
House, Castle Street, Taunton, UK, TA1 4AS.
Introduction
This notice describes how we
collect, store, transfer and use personal data. It tells you about your privacy
rights and how the law protects you.
In the context of the law and this notice,
‘personal data’ is information that clearly identifies you as an individual or
which could be used to identify you if combined with other information. Acting
in any way on personal data is referred to as ‘processing’.
This notice applies to personal
data collected through our Lettings U Know.co.uk website, e newsletters, emails,
online meetings (Zoom/’Teams’ etc) and through social media platforms,
including e.g., Facebook, Instagram, Twitter, Etsy, eBay and Amazon. (see
further clause 30 below).
Except as set out below, we do
not share, or sell, or disclose to a third party, any information collected
through our website.
Data Protection Officer
We have appointed a data
protection officer (‘DPO’) who is responsible for ensuring that our privacy
policy is followed.
If you have any questions about
how we process your personal data, including any requests to exercise your
legal rights, please contact our DPO at info@lettingsuknow.co.uk.
Personal data we process
1.
How we obtain personal
data
The information
we process about you includes information:
· you have directly provided to
us
· that we gather from third party
databases and service providers
· because of monitoring how you
use our website or our services
2.
Types of personal data we
collect directly
When you use our
website, for
example when/if you create an account on our website, we ask you
to provide personal data. This can be categorised into the following groups:
· personal identifiers, such as
your first and last names, your title and your date of birth
· contact information, such as
your email address, your telephone number and your postal addresses for
billing, delivery and communication
· account information, including
your username and password
· payment information, such as a
debit or credit card number and expiry date and bank account details
· records of communication
between us including messages sent through our website, email messages and
telephone conversations
· marketing preferences that tell
us what types of marketing you would like to receive
In addition, we may
also process:
· an image that shows your face,
such as may be included an image of your property that you add to our website
· documentation that confirms your
address, such as a tenancy agreement or rental contract
3. Types of personal data we
collect from third parties
We confirm some of the information you provide to us
directly using data from other sources. We also add to the information we hold
about you, sometimes to remove the need for you to provide it to us and
sometimes to be able to assess the quality of the services you offer.
The additional information we collect can be
categorised as follows:
· information that confirms your
identity
· business information, including
your business trading name and address, your company number (if incorporated),
and your VAT number (if registered)
· information that confirms your
contact information
· reviews and feedback about your
business on other websites through which you sell your services
· unsolicited complaints by other
users
4. Types of personal data we
collect from your use of our services
By using our website and our services, we process:
· your username and password and
other information used to access our website and our services
· information you contribute to
our community, including reviews and responses to our e newsletters
· your replies to polls and
surveys
· technical information about the
hardware and the software you use to access our website and use our services,
including your Internet Protocol (IP) address, your browser type and version
and your device’s operating system
· usage information, including
the frequency you use our services, the pages of our website that you visit,
whether you receive messages from us and whether you reply to those messages
· transaction information that
includes the details of any products or services you have bought from us and
payments made to us for those services
· your preferences to receive
marketing from us; how you wish to communicate with us; and responses and
actions in relation to your use of our services.
5. Our use of aggregated
information
We may aggregate anonymous
information such as statistical or demographic data for any purpose. Anonymous
information is that which does not identify you as an individual. Aggregated
information may be derived from your personal data but is not considered as
such in law because it does not reveal your identity.
For example, we may aggregate usage
information to assess whether a feature of our website is useful.
However, if we combine or connect
aggregated information with your personal data so that it can identify you in
any way, we treat the combined information as personal data, and it will be
used in accordance with this privacy notice.
6. If you do not provide
personal data we need
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 that contract.
In that case, we may have to stop
providing a service to you. If so, we will notify you of this at the time.
The bases on which we process information about you
The law requires us to
determine under which of six defined bases we process different categories of
your personal data, and to notify you of the basis for each category.
If a basis
on which we process your personal data is no longer relevant then we shall
immediately stop processing your data.
If the
basis changes then if required by law we shall notify you of the change and of
any new basis under which we have determined that we can continue to process
your information.
7. Information we process
because we have a contractual obligation with you
When you create an account on our
website, buy a product or service from us, or otherwise agree to our website terms
and conditions, a contract is formed between you and us.
To carry out our obligations under
that contract we must process the information you give us. Some of this
information may be personal data.
We may use it to:
· verify your identity for
security purposes when you use our services
· sell products to you
· provide you with our services
· provide you with suggestions
and advice on products, services and how to obtain the most from using our
website
We process this information on the
basis there is a contract between us, or that you have requested we use the
information before we enter a legal contract.
We shall continue to process this
information until the contract between us ends or is terminated by either party
under the terms of the contract.
8. Information we process
with your consent
Through certain actions when otherwise
there is no contractual relationship between us, such as when you browse our
website or ask us to provide you more information about our business, including
job opportunities and our products and services, you provide your consent to us
to process information that may be personal data.
Wherever possible, we aim to obtain
your explicit consent to process this information, for example, we ask you to
agree to our use of non-essential cookies when you access our website.
If you have given us explicit permission
to do so, we may from time to time pass your name and contact information to
selected associates whom we consider may provide services or products you would
find useful.
We continue to process your
information on this basis until you withdraw your consent or it can be
reasonably assumed that your consent no longer exists.
You may withdraw your consent at
any time by instructing us at email info@lettingsuknow.co.uk.
However, if you do so, you may not be able to use our website or our services
further.
We aim to obtain and keep your
consent to process your information. However, while we take your consent into
account in decisions about whether to process your personal data, the
withdrawal of your consent does not necessarily prevent us from continuing to
process it. The law may allow us to continue to process your personal data if
there is another basis on which we may do so. For example, we may have a legal
obligation to do so.
9. Information we process for
the purposes of legitimate interests
We may process information on the
basis there is a legitimate interest, either to you or to us, of doing so.
Where we process your information
on this basis, we do after having considered:
· whether the same objective could
be achieved through other means
· whether processing (or not
processing) might cause you harm
· whether you would expect us to
process your data, and whether you would, in the round, consider it reasonable
to do so
For example, we may process your
data on this basis for the purposes of:
· improving our services
· record-keeping for the proper
and necessary administration of our business
· responding to unsolicited
communication from you to which we believe you would expect a response
· preventing fraudulent use of
our services
· exercising our legal rights,
including to detect and prevent fraud and to protect our intellectual property
· insuring against or obtaining
professional advice that is required to manage business risk
· protecting your interests where
we believe we have a duty to do so
10.
Information we process
because we have a legal obligation
Sometimes, we must process your
information to comply with a statutory obligation.
For example, we may be required to
give information to legal authorities if they so request or if they have the
proper authorisation such as a search warrant or court order.
This may include your personal
data.
11.
Information we process to
protect vital interests
In situations where processing
personal information is necessary to protect someone’s life, where consent is
unable to be given and where other lawful bases are not appropriate, we may
process personal information based on vital interests.
For example, we may inform
relevant organisations if we have a safeguarding concern about a vulnerable
person.
How and when we process your personal data
12.
Your personal data is not
shared
We do not share or disclose to a third party, any
information collected through our website.
13.
Information you provide
Our website allows you to post
information with a view to that information being read, copied, downloaded, or
used by other people.
For example, when you leave a
review or post a message on our website, we reasonably assume that you consent
for the message to be seen by others. We may include your username with your
message, and your message may contain information that is personal data.
Other examples include:
· tagging an image
· clicking on an icon next to
another visitor’s message to convey your agreement, disagreement or thanks
In posting personal data, it is up
to you to satisfy yourself about the privacy level of every person who might
use it.
We do not specifically use this
information except to allow it to be displayed or shared.
We do store it, and we reserve a
right to use it in the future in any way we decide.
We provide you with a public
profile page, the information on which may be indexed by search engines or used
by third parties. The information you provide on that profile page may be made
available to the public.
Once your information enters the
public domain, we have no control over what any individual third party may do
with it. We accept no responsibility for their actions at any time.
Provided your request is reasonable
and there is no legal basis for us to retain it, then at our discretion we may
agree to your request to delete personal data that you have posted. You can
make a request by contacting us at info@lettingsuknow.co.uk
14. Payment information
Any payment information if required for the future development of our site will never be taken by us or transferred to us either through our website or otherwise. Our employees and contractors never have access to it.
At the point of any payment, you are transferred to a secure page on the website of [WorldPay / Opayo / PayPal / MoneyBookers / Stripe] or some other reputable payment service provider. That page may be branded to look like a page on our website, but it is not controlled by us.
15.
Direct Debit information
Any direct debit information if
required for the future development of our site will proceed as follows.
If When you agree to set up a
Direct Debit arrangement, the information you give to us is passed to our own
bank Lloyds for processing according to our instructions. We do not keep a
copy.
We will be registered under the
direct debit guarantee scheme. This provides for the customer's bank to refund
disputed payments without question, pending further investigation. Direct Debits
can only be set up for payments to beneficiaries that are approved originators
of direct debits. To be approved, these beneficiaries are subjected to careful
vetting procedures. Once approved, they are required to give indemnity
guarantees through their banks.
16.
Job application and
employment
If you send us information in
connection with any job application advertised on our website, we may keep it
for up to three years in case we decide to contact you later.
If we employ you, we collect
information about you and your work from time to time throughout the period of
your employment. This information will be used only for purposes directly
relevant to your employment. After your employment has ended, we will keep your
file for six years before destroying or deleting it.
17.
Information obtained from
third parties
Although we do not disclose your
personal data to any third party (except as set out in this notice), we
sometimes receive data that is indirectly made up from your personal data from
third parties whose services we use.
No such information is
personally identifiable to you.
18.
Third party advertising on
our website
Third parties may advertise on our
website. In doing so, those parties, their agents or other companies working
for them may use technology that automatically collects information about you
when their advertisement is displayed on our website.
They may also use other technology
such as cookies or JavaScript to personalise the content of, and to measure the
performance of their adverts.
We do not have control over these
technologies or the data that these parties obtain. Accordingly, this privacy
notice does not cover the information practices of these third parties.
19.
Credit reference
To assist in combating fraud, we
share information with credit reference agencies, so far as it relates to
clients or customers who instruct their credit card issuer to cancel payment to
us without having first provided an acceptable reason to us and given us the
opportunity to refund their money.
20.
Disputes between users
In the event of a dispute between
you and another user, if you consent, we may share your basic personal data,
business information and contact information with the other user.
At our discretion, we may share other information to enable the dispute to be resolved through litigation or alternative dispute resolution methods.
21.
Service providers and
business partners
We may share your personal data
with businesses that provide services to us, or with business partners.
As examples:
· we may pass your payment
information to our payment service provider to take payments from you
· we may use fraud prevention
agencies and credit reference agencies to verify your identity and we may pass
your information to those agencies if we strongly suspect fraud on our website
· we may pass your contact
information to advertising agencies to use to promote our services to you
22.
Referral partners
This is information given to us by
you in your capacity as an affiliate of us or as a referral partner.
It allows us to recognise visitors
that you have referred to us, and to credit to you commission due for such
referrals. It also includes information that allows us to transfer commission
to you.
The information is not used for any
other purpose.
We undertake to preserve the
confidentiality of the information and of the terms of our relationship.
We expect any affiliate or partner
to agree to reciprocate this policy.
Use of information we collect through automated systems
23.
Cookies
Cookies are small text files that are placed on your
computer's hard drive by your web browser when you visit a website that uses
them. They allow information gathered on one web page to be stored until it is
needed for use later.
They are commonly used to provide you with a
personalised experience while you browse a website, for example, allowing your
preferences to be remembered.
They can also provide core functionality such as
security, network management, and accessibility; record how you interact with the
website so that the owner can understand how to improve the experience of other
visitors; and serve you advertisements that are relevant to your browsing
history.
Some cookies may last for a defined period, such as
one visit (known as a session), one day or until you close your browser. Others
last indefinitely until you delete them.
Your web browser should allow you to delete any cookie
you choose. It should also allow you to prevent or limit their use. Your web
browser may support a plug-in or add-on that helps you manage which cookies you
wish to allow to operate.
The law requires you to give explicit consent for use
of any cookies that are not strictly necessary for the operation of a website.
When you first visit our
website, we ask you whether you wish us to use cookies. If you choose not to
accept them, we shall not use them for your visit except to record that you
have not consented to their use for any other purpose.
If you choose not to use cookies
or prevent their use through your browser settings, you may not be able to use
all the functionality of our website.
We use cookies in the following
ways:
· to track how you use our
website
· to record whether you have seen
specific messages we display on our website
· to keep you signed into our
website
· to record your answers to
surveys and questionnaires on our site while you complete them
· to record the conversation
thread during a live chat with our support team
We provide more information about the cookies we use in our cookie
policy. (LINK)
24.
Personal identifiers from
your browsing activity
Requests by your web browser to our
servers for web pages and other content on our website are recorded.
We record information such as your
geographical location, your Internet service provider and your IP address. We also
record information about the software you are using to browse our website, such
as the type of computer or device and the screen resolution.
We use this information in
aggregate to assess the popularity of the webpages on our website and how we
perform in providing content to you.
If combined with other information
we know about you from previous visits, the data possibly could be used to
identify you personally, even if you are not signed into our website.
25.
Re-marketing
Re-marketing involves placing a
‘tracking technology’ such as a cookie, a ‘web beacon’ (also known as an
‘action tag’ or a ‘single-pixel GIF’) to track which pages you visit and to
serve you relevant adverts for our services when you visit some other website.
The benefit of re-marketing
technology is that we can provide you with more useful and relevant adverts,
and not show you ones repeatedly that you may have already seen.
We may use a third-party
advertising service to provide us with re-marketing services from time to time.
If you have consented to our use of such tracking technologies, you may see
advertisements for our products and services on other websites.
We do not provide your personal
data to advertisers or to third-party re-marketing service providers. However,
if you are already a member of a website whose affiliated business provides
such services, that affiliated business may learn of your preferences in
relation to your use of our website.
Other matters
26.
Your rights
The law requires us to tell you
about your rights and our obligations to you regarding the processing and
control of your personal data.
We do this now, by requesting that
you read the information provided at http://www.knowyourprivacyrights.org
27.
Use of our services by
children
We do not sell products or
provide services for purchase by children, nor do we market to children.
28.
Encryption of data sent
between us
We use Secure Sockets Layer (SSL) certificates to verify our
identity to your browser and to encrypt any data you give us.
Whenever information is transferred between us, you can
check that it is done so using SSL by looking for a closed padlock symbol or
other trust mark in your browser’s URL bar or toolbar.
29.
Delivery of services using
third party communication software
With your consent, we may
communicate using software provided by a third party such as Facebook
(WhatsApp), Apple (Facetime), Microsoft (Skype/’Teams’) or Zoom Video
Communications (Zoom).
Such methods of communication
should secure your personal data using encryption and other technologies. The
providers of such software should comply with all applicable privacy laws,
rules, and regulations, including the GDPR.
If you have any concerns about using a particular software
for communication, please tell us.
30.
Control over your own
information
It is important that the personal
data we hold about you is accurate and up to date. Please inform us if your
personal data changes.
At any time, you may contact us
to request that we provide you with the personal data we hold about you.
At
any time, you may review or update personally identifiable information that we
hold about you, by signing into your account on our website.
To
obtain a copy of any information that is not provided on our website you should
contact us to make that request.
When we receive any request to
access, edit or delete personal data we first take reasonable steps to verify
your identity before granting you access or otherwise taking any action. This
is important to safeguard your information.
Please be aware that we are not
obliged by law to provide you with all personal data we hold about you, and
that if we do provide you with information, the law allows us to charge for
such provision if doing so incurs costs for us. After receiving your request,
we will tell you when we expect to provide you with the information, and
whether we require any fee for providing it to you.
If you wish us to remove personally
identifiable information from our website, you should contact us to make your
request.
This may limit the service we can
provide to you.
We remind you that we are not
obliged by law to delete your personal data or to stop processing it simply
because you do not consent to us doing so. While having your consent is an
important consideration as to whether to process it, if there is another
legitimate basis on which we may process it, we may do so on that basis.
31.
Communicating with us
When you contact us, whether by
telephone, through our website, online meeting or by email, we collect the data
you have given to us to reply with the information you need.
We record your request and our
reply to increase the efficiency of our business.
We may keep personally
identifiable information associated with your message, such as your name and
email address to be able to track our communications with you to provide a high-quality
service.
32.
Complaining
If you are not happy with our
privacy policy, or if you have any complaint, then you should tell us by email
at info@lettingsuknow.co.uk
When we receive a complaint, we
record the information you have given to us based on consent. We use that
information to resolve your complaint.
If your complaint reasonably
requires us to notify some other person, we may decide to give to that other
person some of the information contained in your complaint. We do this as
infrequently as possible, but it is a matter for our sole discretion whether we
do give information, and if we do, what that information is.
We may also compile statistics
showing information obtained from this source to assess the level of service we
provide, but not in a way that could identify you or any other person.
If a dispute is not settled then we
hope you will agree to attempt to resolve it by engaging in good faith with us
in a process of mediation or arbitration.
If you are in any way dissatisfied
about how we process your personal data, you have a right to lodge a complaint
with the Information Commissioner's Office (ICO). This can be done at https://ico.org.uk/make-a-complaint/.
We would, however, appreciate the opportunity to talk to you about your concern
before you approach the ICO.
33.
Retention period
Except as otherwise mentioned in
this privacy notice, we keep your personal data only for as long as required by
us:
·
to provide you with the
services you have requested
·
to comply with other law,
including for the period demanded by our tax authorities
· to support a claim or defence in court
34.
Compliance with the law
Our privacy policy complies with the law in the United Kingdom, specifically with the Data Protection Act 2018 (the ‘Act’) accordingly incorporating the EU General Data Protection Regulation (‘GDPR’) and the Privacy and Electronic Communications Regulations (‘PECR’).
35.
Review of this privacy
policy
We shall update this privacy
notice from time to time, as necessary.