Information about Secluded Escapes

Privacy policy

PRIVACY POLICY

Personal data is an increasing concern for individuals and it’s understandable that people are interested in how companies look after their data and privacy. Your privacy and protection of your data is of paramount importance to Secluded Escapes.

This Privacy Policy explains how Secluded Escapes:

  • Collect
  • Use
  • Disclose
  • Transfer, and,
  • Store your data

We may change this Privacy Policy from time to time, so please check back regularly to keep informed of any updates. This version of the Privacy Policy was updated on 28/12/2018.

In this Privacy Policy, we use the terms “we”, “us”, and “our” (and other similar terms) to refer to Secluded Escapes who act as a data controller for your personal information.

About Us

Secluded Escapes is an online marketplace that allows property owners to advertise and communicate directly with vacationers. Our website only facilitates the advertisement of properties by property owners to vacationers. A property owner can be an individual or a company and both a property owner and vacationer should refer to respective terms and conditions independently engaged between them regarding provisions for data, to which Secluded Escapes is not a party.  

Scope

This Privacy Policy applies to anyone whose data we process, including property owners, vacationers and visitors to our website. Services we provide to others as a data processor of personal data will be governed by a written agreement with the third party data controller and their own privacy policy.

Our commitment to you

Secluded Escapes is committed to protecting and respecting your privacy. We will consider the six data principles when making decisions regarding the data we have received. More information can be found at www.ico.org.uk.

The information you provide to us

We may collect and use personal information that you provide directly to us. Personal details are collected to make communication and use of service possible. Details can be used for communication between property owners and vacationers for direct communication between users. Some personal details are visible on the profile page of the user, but those details are voluntary (except name).

The types of personal information we may collect when you provide it to us include:

  • Basic details such as your name, address and contact details;
  • Company information;
  • Payment information;
  • Account information including username and password (stored in encrypted format);
  • Proof of ownership (including, but not limited to, utility bill, permit or license, deed or mortgage confirmation);
  • Pictures (the picture you provide to populate your user profile and properties);
  • Descriptions of properties;
  • Feedback information;
  • Details of visits to our website including your IP address, login information and other analytical information (please refer to our cookie usage information); and
  • Any other personal data we collect, or you chose to disclose to us, in the course of providing services or in operating our business.

Collect

Your data may be collected:

  • By telephone;
  • By correspondence including post, text, email or otherwise;
  • Via our website, for example, by completing and submitting your listing or by submitting an enquiry;
  • Via linked portals, for example, our payment and subscription portals;
  • Log information, including browser information, page views, IP addresses, and the website visited before navigating to our website;
  • Information collected by cookies and other tracking technologies;
  • From third parties such as other companies who have obtained your permission to share information about you, and or, have an identified lawful basis for doing so.

We may also obtain information from other sources and combine that with the information we collect through our website. For example, when you create or log into your account through a social media site, we will have access to certain information from that site, such as your name and account information, in accordance with the authorisation procedures determined by such social media sites except to the extent that your chosen social media platform allows you to disable this functionality. We may use publicly available tools, such as a Google Analytics, to better understand users’ preferences. Collection of data by third-party tools are subject to their respective privacy policies.

Use

In general we use your data to provide services as an online marketplace, including the following purposes:

  • Provide and deliver the services and send you service related information;
  • Send you technical notices, updates, security alerts, support messages, and administrative messages;
  • Respond to your comments, questions, requests, and provide customer service;
  • Provide, maintain, advertise, promote and improve our services;
  • Facilitate communication among users of our services;
  • Communicate with you about products, services, offers and promotions;
  • Monitor and analyse trends, usage, and activities in connection with our services; personalise and improve our services and provide content or features through the service that match user profiles or interests;
  • Link or combine with information we get from others to help understand your needs and provide you with better service; 
  • Prove property ownership and verify identity;
  • Process and respond to any queries, concerns or complaints;
  • Allow for billing and to obtain payment, including sending confirmations and invoices;
  • Facilitate marketing and business development (only with your consent); and
  • Carry out any other purpose for which the information was collected.

We will not use your data for automated decision making.

We rely on the following lawful bases for processing your personal information:

  • Consent: for marketing and business development activities including newsletter communications. Consent may also be used where a requirement arises during the day-to-day provision of services (in accordance with the 6 lawful bases);
  • Contractual necessity: we will process your personal data when it is necessary to perform a contract you have entered into, or in order to take steps at your request prior to entry into a contract;
  • Legal obligation: we will process your personal data when it is necessary to comply with a legal or regulatory obligation (e.g. identity checks, external auditing)
  • Legitimate interests: we will process your personal data when we, or a third party, have a legitimate interest in processing it. We only process for this reason if the legitimate interest is not overridden by your own interests or fundamental rights or freedoms. Please contact us if you would like more information on our, or a third party’s, legitimate interests and the balancing test we use to ensure processing is lawful.

We will only use your personal data for the purpose, or purposes, for which we have obtained it. If we reasonably consider that we need to use it for another reason we will only do so if that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will inform you and explain the legal basis which allows us to do so.

We may process your data without your knowledge or consent where this is required by law.

Please contact us if you would like further information on the exact lawful basis for any specific data processing activity.

Disclose

We will share your data with carefully selected third parties when:

  • You specifically request it, or a disclosure is required in-order-for us to provide our services and/or fulfil our contractual obligations to you;
  • We are under a legal or regulatory duty to disclose your information; or,
  • As a result of any changes in business ownership or organisation.

We may share your personal information, where required and to the extent permitted and on which we have a lawful basis, with:

  • Vendors, consultants, and our service providers who need access to such information to carry out work on our behalf as requested through the services;
  • With third parties to provide marketing and promotional purposes on our behalf, provided that they have agreed to handle personal information in a manner consistent with this Privacy Policy;
  • In response to a request for information, if we believe disclosure is in required by applicable law, regulation, or rule; or administrative, judicial, or other government order;
  • Law enforcement agencies;
  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company;
  • Analytics and search engine providers who assist in improving our website; and,
  • Any other third party you may ask us to share your data with.

Our service providers include:

  • Sharetribe who provide website hosting and support (https://www.sharetribe.com/privacypolicy.html)
  • Chargebee who provide subscription and billing services (https://www.chargebee.com/privacy/)
  • Stripe who provide payment gateways services (https://stripe.com/gb/privacy)

Transfer

Your personal information may be transferred to, and processed in, countries different to the country where you reside. This can be outside of the European Union (EU) / European Economic Area (EEA) where protection laws may differ to the laws of your residing country. We, and our service providers, will only transfer personal data outside of the EU/EEA with adequate safeguards required by applicable data protection law. We ensure that any of our third-party service providers to whom a data transfer is made has appropriate safeguards in place to protect your personal information. The adequacy mechanism may be adequate country status (based in a country that the European Commission has deemed "adequate"), contractual controls and mechanisms, or EU-US and Swiss-US Privacy Shield.

Specifically, the servers of our online services are located in the US, and group companies of our service providers and third party service providers operate around the world. This means that when we collect your personal information we may process it in any of these countries.

Store

Secluded Escapes has in place physical, electronic and operational procedures intended to safeguard and secure the information we collect.

Data is stored using Amazon Web Service (AWS) cloud hosting, located in the East USA Data Centre. Our service provider has signed a Data Protection Agreement with AWS that includes the Model Clauses that the EU currently requires to make sure the data storage partner outside EU area is trusted enough to be used. The data is stored in a MySQL database where there is limited access only to personnel who need it for work. With some critical information we take extra measures, for example, user passwords are only stored in an encrypted format and credit card details are not stored on our servers at all, only at the payment provider services that specialise in payment data handling.

Your personal data will be retained only for as long as necessary to fulfil the purposes defined in this Privacy Policy. When the personal data is no longer required by law or rights or obligations by us or you, we will delete the personal data. In most cases, personal data will be deleted upon termination or expiry of the agreement between you and us or upon your written request. Please note that we may have a right to retain some data even after termination of the agreement for billing purposes.

Exceptionally, we may retain personal data for a longer period if we have a legitimate reason or an obligation to store data for the purposes of criminal investigation or other corresponding reason.

Your rights

You have the right to access and obtain a copy of data held about you upon request. Such request shall include information that is necessary for retrieving the data and shall be made using a personally signed document which can be addressed to info@secludedescapes.com. Secluded Escapes rectifies, erases or supplements possibly erroneous, unnecessary, incomplete or obsolete personal data at its own initiative or at the request of the individual concerned. You should contact info@secludedescapes.com to correct any possibly erroneous data. 

You have the right to prohibit Secluded Escapes from processing personal data for purposes of direct marketing. We advise you to notify Secluded Escapes of such possible prohibitions in writing.

You also have a right to data portability to the extent granted by applicable data protection rules. Data portability refers to a right to receive own personal data in a structured, commonly used machine-readable format and transmit your personal data to another data controller.

If you think there is a problem with the way Secluded Escapes is processing personal data, you should firstly contact Secluded Escapes to discuss and seek remedy. If your concern is not resolved to your satisfaction you have the right to raise a concern at any time to the Information Commissioner’s Office (“ICO”) who is the UK supervisory authority for data protection issues. For more information on submitting a concern, or the data protection regime in general, please visit the ICO’s website.

Cookies

Cookies are pieces of data which are received and transmitted by a user's device when the user is using Secluded Escapes services or website. We may use cookies and similar techniques to provide functionality of the services, to enhance the user experience and to identify users and how they use the services. We use cookies, for example, to login and logout authentication, to remember session allowing users to continue the session in case of time-out and to prevent unauthorised use of the services. The user may prohibit the use of cookies or remove cookies from the browser settings. However, cookies are important part of how the service works, so limiting the use of cookies may affect the functionality of the Service.

Secluded Escapes uses third party cookies for various purposes. We may use third party cookies for statistical purposes to compile anonymous, aggregated statistics, such as to estimate number of users and detect which parts of the service users find most useful, and identify features that could be improved. For such purposes, we use third party cookies, such as Google Analytics, to help analyse how our users use the service. The technical usage information (including IP address) generated by the cookie about use of the service is transmitted to such third parties to compile statistical reports.