PRIVACY NOTICE - COTTAGES & CASTLES LTD

Cottages & Castles is committed to protecting your privacy and the confidentiality of

your personal information. This privacy notice explains how we collect, use and protect your personal information. In this privacy notice, “our” and “we” means Cottages & Castles Limited. Any reference to “you” or “your” refers to anyone whose personal information we collect and process. 

1. Introduction

Our use of your personal information is governed by this privacy notice. Cottages & Castles is a controller for the personal information that we collect and use about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this privacy notice. In this privacy notice we explain; 

  • What personal information is
  • How we collect your personal information
  • The types of personal information we collect
  • How we use your personal information
  • The legal basis for processing your personal information
  • How we share your personal information
  • How long we keep your personal information
  • How we keep your personal information secure
  • Your rights in relation to your personal information
  • How to make complaints and how to contact us

2. What is personal information?

Personal information is any information that tells us something about you. This includes information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you. Some personal information is classified as special data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justification for collecting, storing and using this type of personal information. Any references to personal information in this privacy notice includes personal data, and where relevant, special categories of personal data.

3. What personal information do we collect?

The type of personal information that we collect from you will depend on the service that we are providing to you or the reason that you are engaging with us. In all cases of engagement with you we will collect your full name and contact details (such as phone numbers, email address and postal address) from you.

Depending on the service that we provide to you, or on your behalf, or on behalf of a client, we may also collect additional personal information as detailed below;

Owners of properties

If you are letting a property through us we will collect and use the following information about you:

  • Identification and contact information, such as your full name, date of birth, age, postal address, email address and telephone numbers
  • Your bank / building / similar account details to allow us to set up your rental payments
  • Tax status information for overseas landlords which will be provided along with your name, address and the tenanted property address to HMRC

Booking a property that we are advertising

If you apply to book a property that we are advertising on behalf of an owner we will require you to provide certain personal information to us as part of your booking application. If you fail to provide certain information when requested you may not be able to complete your booking. We also have statutory and regulatory obligations to collect certain personal information from you. We will collect personal information directly from you through the booking process.

We may collect and use the following information about you:

  • Identification  and contact information, such as your full name, date of birth, age, postal address, email address and telephone numbers
  • Specific access requirements to help assess whether a property is suitable for your needs
  • Your bank / building / similar account details to allow you to make payment for your booking
  • Your bank / building / similar account details to allow us to process any good housekeeping deposit

We may also collect information about you from other sources. This may include the following:

  • Publicly available information, from sources such as Companies House, the Electoral Roll, debt decrees and county court judgements and repossessions
  • Information you have shared publicly, including on social media
  • Information from third party databases or data suppliers

Other

If you subscribe to receive news or other market updates from us then in addition to the above we may collect details about the sector in which you work and the type of content that you would like to receive but only with your consent.

4. What is the legal basis of our data processing?

Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;

  • Where we need information to perform the contract we have entered into with you
  • Where we need to comply with a legal obligation
  • Where we have your consent
  • Where the processing is necessary for us to carry out activities for which it is in Cottages & Castles legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
    • processing your personal information in ways that you would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for this processing. This would include collecting and processing personal data for the purposes of matching you properties.
    • processing which is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns.  – this may include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
    • processing which is necessary to improve our knowledge of the self -catering holiday sector – this will include undertaking market analysis and research so that we better understand trends in the self-catering holiday sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
    • processing which is necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and creating a better understanding of you as a customer; 
    • processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialists in such services;
    • processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.

In more limited circumstances we may also rely on the following legal bases:

  • Where we need to protect your interests (or someone else's interests); and/or
  • Where it is needed in the public interest or for official purposes we may process special categories of personal with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

How we use your personal information

How we use the personal information that we collect from you will depend on the service that we are providing to you or the reason that you are engaging with us.

Owners of properties

If we are acting for you as an owner we use your personal information for our statutory obligations in the transaction and for the purposes of fulfilling our obligations to you to market and accept bookings on your behalf. We share your personal information with the booker, your suppliers, our suppliers and any other third parties necessary to facilitate the booking.

Bookers of properties        

If you are booking a property that we are advertising on behalf of an owner we use your personal information for the purposes of processing and completing the booking. We share your personal information with the owner, the owner’s suppliers, our suppliers and any other third parties necessary for us to process and complete your booking.

Other uses of your personal information

  • If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.
  • We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations.
  • We will share personal information with third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.
  • We may share your personal information with any person working within Cottages & Castles and certain CKD Galbraith LLP employees on a need to know basis to ensure we are able to perform our obligations to you.
  • We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by us to those which you have engaged us to provide or which you have requested to receive information about which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.

What happens if you do not provide information that we request?

We need some of your personal information to perform the services you have requested from us or to complete and process a booking For example:

  • where we are advertising and taking bookings for a property on your behalf we need to know your personal information so that we can advertise your property, update you with information on bookings and make payments to you
  • where you are booking a property that we are advertising we need to know your personal information to process and complete your booking
  • we also need some information so that we can comply with our legal obligations.  

If you do not provide the information required for these purposes, we will not be able to perform our contract with you or complete a booking on your behalf and we may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect personal information from you.

5. How we keep your information secure

The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:

  • Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes. 
  • All data is hosted in datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to, your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.
  • We ensure access to personal information is restricted to our employees and workers and certain CKD Galbraith LLP employees or other persons working within our business on a need to know basis.

6. How long do we keep your personal information?

The period we keep your personal information for will depend on the type of service we have provided you with. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period or where we may need to retain the information in case of a legal claim.  

7. Overseas transfers of your personal information

We ensure that the personal information we hold on your behalf is stored in locations within the UK and the European Economic Area (EEA). 

8. Your rights in relation to your personal information

You have a number of rights in relation to your personal information, these include the right to:

  • Be informed about how we use your personal information
  • Obtain access to your personal information that we hold
  • Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate
  • Request that we erase your personal information in the following circumstances:
  • If we are continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected
  • If we are relying on consent as the legal basis for processing and you withdraw consent
  • If we are relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing
  • If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)
  • If it is necessary to delete the personal information to comply with a legal obligation
  • Ask us to restrict our data processing activities where you consider that: 
  • personal information is inaccurate
  • our processing of your personal information is unlawful
  • where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim
  • where you have raised an objection to our use of your personal information
  • Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information
  • Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and
  • Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you would like to exercise any of your rights please contact tim.kirkwood@cottages-and-castles.co.uk.

9. Complaints and Contact Detail

If you have any complaints about the way we use your personal information please contact tim.kirkwood@cottages-and-castles.co.uk. If we cannot resolve any issue you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us by sending an email to tim.kirkwood@cottages-and-castles.co.uk.