This Privacy Policy sets out how we, Hollybank House, collect, store and use information about you when you use or interact with our website, www.hollybankhouse.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1st September 2020.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Hollybank House, Hollybank Lane, Emsworth, Hants PO10 7UN
Summary
This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.
- Data controller: Hollybank House
- How we collect or obtain information about you:
When you provide it to us (e.g. by contacting us on the telephone via our website, or making a booking via our website or one of our booking partners, Free To Book, Booking.com, AirBnB and Expedia (or any others).
- Information we collect: name, contact details and booking details, (such as when you want to stay, how many people and for how long)
- How we use your information: for administrative and business purposes (particularly to process your booking you place on the telephone following a visit to our web site, or via one of our booking partners to fulfil our contractual obligations to you and in connection with our legal rights and obligations.
- Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights
- Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
- How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
- How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting payments you make on or via our website using Secure Sockets Layer (SSL) technology, only granting access to your information where legally necessary.
- Use of cookies and similar technologies: We do not use any cookies on our web site at this time. If we choose to do so later we will update this policy.
- Transfers of your information outside the European Economic Area: We will only transfer your information outside the European Economic Area if we are required to do so by law.
- Use of automated decision making and profiling: We do not use automated decision making and/or profiling.
- Your rights in relation to your information:
• to access your information and to receive information about its use
• to have your information corrected and/or completed
• to have your information deleted
• to restrict the use of your information
• to receive your information in a portable format
• to object to the use of your information
• to withdraw your consent to the use of your information
• to complain to a supervisory authority
- Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us for more information, please see the main section below entitled Sensitive Personal Information
Our details
The data controller in respect of our website is Hollybank House, Hollybank Lane, Emsworth, Hants PO10 7UN. You can contact the data controller by writing to Hollybank House, Hollybank Lane, Emsworth, Hants PO10 7UN or sending an email to info@hollybankhouse.com
If you have any questions about this Privacy Policy, please contact the data controller.
Information we collect when you visit our website
We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.
Web server log information
We use a third party (Siteground) server to host our website. Our website server may automatically log the IP address you use to access our website as well as other information about your visit such as, the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.
The servers are located in the European Economic Area (EEA) and the United States of America.
Use of website server log information for IT security purposes.
The privacy policy of Siteground can be viewed at: https://www.siteground.co.uk/viewtos/privacy_policy?scid=2&lang=en
We AND/OR our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.
Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.
Legal basis for processing:
1. Compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).
2. We have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.
3. our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
4. We and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.
Information we collect when you contact us
We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.
When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).
Where your message relates to us providing you with a booking for a room, or a service that we offer at your request prior to providing you with that service (for example, providing you with information about our rooms, facilities and services), we will process your information in order to do so).
Legal basis for processing:
1. Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
2. Our legitimate business interests responding to enquiries and messages we receive and keeping records of correspondence
3. necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Transfer and storage of your information
We use a third party email provider to store emails you send us.
Emails you send us will be stored within the European Economic Area or United States of America.
Phone
When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.
We do not record phone calls.
Where our telephone conversation relates to us providing you with a booking for a room, or a service that we offer at your request prior to providing you with that service (for example, providing you with information about our rooms, facilities and services), we will process your information in order to do so).
Legal basis for processing
1. Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
2. Our legitimate business interests responding to enquiries and messages we receive and keeping records of correspondence
3. Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Post
If you contact us by post, we will collect any information you provide to us in any postal communications you send us.
Where our postal communication relates to us providing you with a booking for a room, or a service that we offer at your request prior to providing you with that service (for example, providing you with information about our rooms, facilities and services), we will process your information in order to do so).
Legal basis for processing
1. Our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
2. Our legitimate business interests responding to enquiries and messages we receive and keeping records of correspondence
3. Necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).
Information we collect when you interact with our website
Information collected when you book a room at Hollybank House on our Web Site
We use a third party room booking software partner Freetobook to process reservations of our rooms online. Their privacy policy can be found at: https://www.freetobook.com/diary/profile/privacy
Effectively when you make a reservation online for one of our bedrooms this is carried out on the Freeetobook.com web site. Their privacy policy is available throughout the reservation process.
In the context of providing online booking Freetobook and Hollybank House shall together operate as joint data controllers for the processing of your personal data. The information supplied to Freetobook at the time of booking is available to Hollybank House in order to process the booking and provide the service to you.
At the time of booking on the Freetobook system you are asked for your name, address, telephone number and email along with payment information and “the names of any guests travelling with you”. This may also include your IP address. This information is stored in the Freetobook System in order to process your booking.
We also collect optional information from you during the booking and registration process such as how you heard about Hollybank House.
Legal basis for processing
1. Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). The storage of your information may be necessary to perform the contract that you have with Hollybank House to provide accommodation.
2. Legitimate Interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
3. We have a legal obligation to keep accounting records, including records of bookings and financial transactions
Information collected or obtained from third parties
This section sets out how we obtain or collect information about you from third parties.
We receive reservations from our third-party booking partners, the companies e-mail us details of the booking and it is processed via our Freetobook online booking software.
Booking.com’s privacy policy can be found at: https://www.booking.com/content/privacy.html
Expedia’s privacy policy can be found at: https://www.expedia.co.uk/p/support/privacy
AirBnB’s privacy policy can be found at: https://www.airbnb.co.uk/terms/privacy_policy
We use a third-party room booking software partner Freetobook to process reservations of our rooms online. Their privacy policy can be found at: https://www.freetobook.com/diary/profile/privacy
In the context of providing online booking Freetobook and Hollybank House shall together operate as joint data controllers for the processing of your personal data. The information supplied to Freetobook at the time of booking is available to Hollybank House in order to process the booking and provide the service to you.
Where a third party has passed on information about you to us (such as your name and email address) in order for us to provide services to you, we will process your information in order to take steps at your request to enter into a contract with you and perform a contract with you (as the case may be).
If we receive information about you from a third party in error and/or we do not have a legal basis for processing that information, we will delete your information.
Legal basis for processing
1. Performance of a contract (Article 6(1)(b) of the General Data Protection Regulation). The storage of your information may be necessary to perform the contract that you have with Hollybank House to provide accommodation.
2. Legitimate Interest: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
3. We have a legal obligation to keep accounting records, including records of bookings and financial transactions
Disclosure and additional uses of your information
This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.
Disclosure of your information to service providers
We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business. These include, but are not limited to, the following:
• Email provider(s), including. AWNET, Siteground, Google, Microsoft
• Hosting provider(s), including AWNET, Siteground, Google, Microsoft
• We use a third-party room booking software partner Freetobook to process reservations of our rooms online.
• We share information with our accountants for tax purposes. For example, we share invoices we issue and receive with our accountants for the purpose of completing tax returns and our end of year accounts.
• Sharing your information within our business’ group of companies, including, but not limited to, Williams International, Rosemary Williams, Ian Williams for internal administrative purposes, including client, customer and employee information.
Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.
Legal basis for processing
1. legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
2. Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.
3. Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract (Article 6(1)(b) of the General Data Protection Regulation).
4. Legitimate Interests: Running our business efficiently
How long we retain your information
This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.
Retention periods
Server log information: we retain information on our server logs for at least 1 month.
Reservation Forms and booking details: We retain that information for six years following the end of the financial year of your reservation, in accordance with our legal obligation to keep records for tax purposes.
Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email, or by phone, we will retain your information for as long as it takes to respond to and resolve your enquiry, and for 3 further years(s) after which point we will delete your information.
In any other circumstances, we will retain your information for no longer than necessary, whilst ensuring we comply with any relevant legislation.
How we secure your information
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secure servers to store your information
• using Secure Sockets Layer (SSL) software to encrypt any information you submit to us and any payment transactions you make.
Transmission of information to us by email
Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.
We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.
Transfers of your information outside the European Economic Area
We do not transfer any of your personal information outside the European Economic Area.
Your rights in relation to your information
Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by writing to Hollybank House, Hollybank Lane, Emsworth, Hants PO10 7UN or sending an email to info@hollybankhouse.com
• to request access to your information and information related to our use and processing of your information;
• to request the correction or deletion of your information;
• to request that we restrict our use of your information;
• to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
• to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
• to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
In accordance with Article 77 of the General Data Protection Regulation, you also have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the General Data Protection Regulation.
For the purposes of the UK, the supervisory authority is the Information Commissioner’s Office (ICO), the contact details of which are available here: https://ico.org.uk/global/contact-us/
Sensitive Personal Information
We do not knowingly or intentionally collect sensitive personal information from individuals, and you must not submit sensitive personal information to us.
If, however, you inadvertently or intentionally transmit sensitive personal information to us, you will be considered to have explicitly consented to us processing that sensitive personal information under Article 9(2)(a) of the General Data Protection Regulation. We will use and process your sensitive personal information for the purposes of deleting it.
Changes to our Privacy Policy
We update and amend our Privacy Policy from time to time.
Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.
Where we make major changes to our Privacy Policy we will post a notice on our website.
Children’s Privacy
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying regulations protect the privacy of children using the internet. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
Copyright
This Privacy Policy is owned by Hollybank House. All rights reserved.
Hollybank House, Hollybank Lane, Emsworth, Hants PO10 7UN –Tel: 01243 377866
