Page Updated : 3rd April 2019
Willow Lodge is a privately owned holiday home rental, which is managed by a services company based in the UK called Reliance Managed Services (RMS). The information in these pages relate to the privacy practices of the company, (herein referred to as “Willow Lodge”, “RMS”, “we”, “our” or “us”). RMS is the data controller of any personal data processed within Willow Lodge, including in relation to this website.
RMS respects your right to privacy and we take our related legal obligations seriously. We aim to be transparent at all times about our treatment of your information. You can read the full policy below for details about how your information will be used, when it may be disclosed to others and your rights in relation to the information we hold.
In the course of providing you with our services and through your interactions with us, RMS may collect information about you and about your use of our services. We are committed to being transparent in our handling of personal information and we endeavour to comply with applicable privacy and data protection laws in the territories within which we operate. This policy describes the types of information we might collect, how we may use it and the circumstances in which we might disclose or transfer it:
If you have any questions or comments about this policy or our approach to privacy please contact us at: dataprivacy@RMS.Limited We aim to reply to any queries within three working days.
1. SCOPE OF THIS POLICY AND YOUR CONSENT
This policy governs our processing of your information in relation to the products and services we supply to you. Your use of our services constitutes your consent to the processing of your information described herein.
2. INFORMATION WE MAY COLLECT
The type of information we collect will depend on the service you are using. To book a break at Willow Lodge we need your name, names of all guests listed in your booking, your address, ages of all guests listed in your booking, email address, mobile number and payment information. Generally speaking, we will collect information relating to you and/or your use of our services in the following ways:
Personal information provided by you:
This is usually information that identifies you as an individual or that enables us to contact you and can include your name, home address, telephone number, e-mail address, names of all guests listed in your booking, ages of all guests listed in your bookings, payment information.
Information collected automatically during your use of our services:
When you use our services we automatically record information about your usage of those services, your interaction with our adverts and our emails as well as information about the device you are using and your internet connection.
We do this in two ways:
Log data: When you use our services, certain information gets recorded in our log files such as your device’s Internet Protocol (IP) Address, its unique ID, its operating system and location, and your browser type, the pages you viewed, cookie information and referral links (the link that sent you to a particular page).
Tracking technologies (cookies): In conjunction with our log data we may use tracking technologies such as tags on our web pages and small data files which we store on your device (known as “cookies”). These technologies enable us to recognise your device and to track your interaction with our services, emails and adverts. We do not use these technologies to identify you and we do not intentionally collect or record personally identifiable information through these technologies. See our Cookies Policy for more information.
Information collected via social media and other third parties:
3. HOW WE USE YOUR INFORMATION AND LEGAL BASIS FOR PROCESSING
We will use your information: (i) to deliver, improve and personalise our services to you in accordance with your preferences: and (ii) for our own legitimate business purposes and needs. Specifically, we may use your information to: Where Reliance Managed Services Limited proposes using your personal information for any other uses we will ensure that we notify you first. You will also be given the opportunity to withhold or withdraw your consent for your use other than as listed above.
Purposes for which we will use your personal data
Under the new data protection legislation we are required to advise you the legal basis for processing your personal data.We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer||(a) Identity|
|Performance of a contract with you|
|To process your booking including:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity|
(D) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
(b) Necessary to comply with a legal obligation
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
4. SHARING & DISCLOSING YOUR INFORMATION
Information shared with our suppliers
We use a number of third parties to perform business functions on our behalf, such as sending our newsletters, hosting our online services, providing our customer services and fulfilling product orders and processing payments. We only disclose the information necessary to enable these third parties to perform their services. Our suppliers are contracted to comply with our instructions and we require that they do not use your personal information for their own business purposes.
Information shared with other parties
Generally, we will only disclose your data to other parties with your consent, for example if you choose to share content via social media functionality. We may also disclose your personal information to law enforcement agencies, government/regulatory bodies, internet service providers and content protection organisations as required or allowed by law. For example, if you post inappropriate or objectionable content on our services or where we reasonably believe you may be in breach of the law, we may report your content and behaviour to relevant parties.
Sale or transfer of all or part of our business or assets
We will not transfer or sell your personal information.
5. WHERE WE WILL STORE AND USE YOUR INFORMATION
As described in the previous section, we may share your information with contracted third party service providers. These companies may be located in, or use IT equipment located in, countries different to that in which your information is collected. Where this is the case, we will take steps to ensure that your information receives an equivalent level of protection.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
6. HOW LONG WE WILL KEEP YOUR INFORMATION
We will hold your personal information on our systems for as long as is necessary for the relevant service or as long as is set out in any relevant contract you hold with us. Where you contribute to one of our online services, we will generally only keep your content for as long as is reasonably required for the purpose(s) for which it was submitted. After this time, your personal information will either be securely deleted or anonymised so that it can be used for analytical purposes.
7. CHILDREN USING OUR SERVICES
Except where otherwise indicated, we do not knowingly collect or store any personal information from children under the age of 13. If you are aged 12 or under, we request that you do not provide us with information relating to you or to others. Please seek the guidance of your parent or guardian before using our services.
If you are the parent or guardian of a child who is aged under 13 and you become aware that your child has provided us with information without your consent, please contact us at dataprotection@RMS.limited We will delete such information from our records within a reasonable time.
Depending on the service, we may also seek to obtain the consent of your parent or guardian if you are under the age of 16. Further, we only send commercial marketing communications to individuals aged 16 or over.
If appropriate, we will take steps to determine the age of persons submitting their information to us.
8. HOW WE SECURE YOUR INFORMATION
We maintain appropriate organisational and technological safeguards to help protect against loss, misuse or unauthorised access, disclosure, alteration or destruction of the information we hold about you. We also seek to ensure our service providers do the same. Unfortunately, no system can be guaranteed as completely secure and there is an inherent risk in transmitting information over the internet. It may be possible for an unrelated party to intercept or access such transmissions unlawfully.
If you believe that your personal information under our control has been compromised, including access to any accounts you hold with our services, please contact us immediately using the details below.
9. YOUR RIGHTS & CHOICES
Your Legal Rights
You have the following rights:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you would like to know what information we hold about you, you may submit a request to us by using the contact details below.
We will require you to prove your identity before granting access to your personal information. You will not have to pay a fee to access your personal data (or to exercise any of the other rights detailed below). However, we may be entitled to charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We will process your request within the timeframe required.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure (deletion) of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
If you would like us to delete your information from our records then please contact us using the details below and we will respond within a reasonable time but within no more than 3 working days. Please note that we may be required to retain certain information by law and/or for own legitimate business purposes.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw.
Communication Preferences and Opt-outs
If you wish to stop receiving marketing communications from us then please click on the “unsubscribe” link at the bottom of the relevant newsletter. Please note that this will not unsubscribe you from all communications, only the newsletter in the question and as such you will need to perform this action for each of the newsletters you are subscribed to. If you wish to opt-out completely then please contact us at using the details provided below. Please note that you cannot unsubscribe from some service related messages.
In accordance with industry standards, we reserve the right to retain a minimal amount of data necessary to ensure we do not contact you in the future.
11. CONTACT US
If you have any questions or comments about this policy or our approach to privacy please contact us at:
Data Protection Officer
Reliance Managed Services Limited
Hampshire RG27 9TD
We will do our very best to resolve any complaint. However if you feel we have not resolved your complaint you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk).