Privacy Policy
General Data Protection Regulation
(GDPR) Compliance
The Privacy of Your Data is Important to Us
1. Introduction
This privacy policy sets out how Vacation Rental Support Llp (Us, We, Our, VRS) uses and protects any information provided to us via our websites or other methods in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679.
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We are committed to safeguarding the privacy of our website visitors and service users.
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This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
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In this policy, "we", "us" and "our" refer to Vacation Rental Support Llp.
2. The Data Controller is:
Vacation Rental Support Llp
Registered Partnership number: SO306370
Registered Address: Summit House, 4-5 Mitchell Street, EDINBURGH, EH6 7BD, Scotland
Email:
Tel: 01479 42 00 42
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) [in the case of personal data that we did not obtain directly from you, the source and specific categories of that data];
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
3.2 We may process data about your use of our website and services (" usage data "). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is Google Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent.
3.3 We may process your account data (" account data "). The account data collected via this website or via other means such as email, phone, text or other websites such as OTA's (Online Travel Agencies, e.g., Airbnb, Booking.com, TripAdvisor, etc). The account data may include your name, address, telephone number, email address, profile pictures, gender, date of birth or any other information that you provide. We do not collect Sensitive Personal Data as defined by the GDPR. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or the Owner/s of the Vacation Rental accommodation you are booking, and/or taking steps, at your request, to enter into such a contract whether via website booking software, OTA, telephone or email.
3.4 We may process your information included in your personal profile (" profile data "). The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth and other data that you provide us with. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is the performance of a contract between you and us and/or the Owner/s of the Vacation Rental accommodation you are booking and/or taking steps, at your request, to enter into such a contract.
3.5 We may process your personal data that is provided in the course of the use of our services (" service data "). The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or the Owner/s of the Vacation Rental accommodation you are booking and/or taking steps, at your request, to enter into such a contract.
3.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (" enquiry data "). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services and /or goods to you. The legal basis for this processing is consent.
3.7 We may process information relating to our customer relationships, including customer contact information (" customer relationship data "). The customer relationship data may include your name, your contact details, and information contained in communications between us and you. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services and goods to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
3.8 We may process information relating to transactions, including purchases of services and goods, that you enter into with us and/or through our website (" transaction data "). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased services and goods and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (" notification data "). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.10 We may process information contained in or relating to any communication that you send to us (" correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.11 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
3.12 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
3.13 In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
3.14 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 Financial transactions relating to our website and services may be handled by our payment services providers, Stripe, or by bank transfer. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about Stripe at: Payments via OTAs such as Airbnb, TripAdvisor, HomeAway etc, will be handled in accordance with conditions displayed on the relevant site.
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Website Booking Information, Contact forms and Newsletter Subscriptions
5.1 If you choose to contact us using a contact form or other form of information submission such as a contact form on our website the email address that you submit will be stored in our website's platform 'Contacts' database, which we use for contacting you. We consider the website platform to be a third party data processor. Your email address will remain within the 'Contacts' database of our website for as long as we continue to use the platform or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that you used on the contact form.
5.2 Information that you provide us with when booking accommodation online via this website will be stored in our Smoobu account database. Smoobu's Privacy Policy can be viewed here: https://www.smoobu.com/en/privacy-policy/ .
6. About this website’s server
This website is hosted in data centres in the United States and Europe and has full-time security consultants, dedicated to the security of customer information.. The platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and as such adheres to the Privacy Shield Principles. Our website's platform is also compliant with the new EU General Data Protection Regulation (GDPR) effective from May 2018 and also has the following ISO/PCI security certifications:
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ISO 27001:2013 and ISO 27018:2014 Best Practices Certificate
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ISO 27108 Certificate
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PCIDDS Compliance Certificate
All traffic (transferal of files) between this website and your browser is encrypted and delivered over HTTPS.
This website's server platform uses cryptography hash functions to protect your information. Your password, if you have an account attached to this website, is stored as a hash digest and, in the event of a security breach, your original password cannot be recovered from the servers.
7. Retaining and deleting personal data
7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your data as follows:
(a) contact information will be retained for a minimum period of 3 years following first contact (e.g. website visit) and a maximum period of 10 years following termination of contract.
(b) personally identifiable property data will be retained for a minimum period of 3 years following first contact (e.g. website visit or start of service agreement) and a maximum period of 3 years following termination of contract.
7.4 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria based on the legitimate interest of the data subject
7.5 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8. Amendments
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8.3 We may notify you of significant changes to this policy by email.
9. Your rights
9.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
9.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
9.13 You may exercise any of your rights in relation to your personal data by written notice to us at Vacation Rental Support Llp, Summit House, 4-5 Mitchell Street, Edinburgh, EH6 7BD.
10. About cookies
Please refer to our Cookie Policy
11. Data breaches
We will report any unlawful data breach of this website’s database or the database(s) of any of our third party data processors to any and all relevant persons and authorities within 72 hours of our notification of the breach if it is apparent that personal data stored in an identifiable manner has been stolen.