Secret Escapes Privacy notice

1. Secret EScapes approach to privacy

1. 1. The website and app that is linked to this privacy policy is operated by Secret Escapes Limited (“we” or “us”).

1. 1. We appreciate your interest in our website (our “site“) or our app (our “app“). Privacy protection is very important to us and we are committed to protecting you and respecting your privacy. This privacy notice sets out information about how we collect, store, process, transfer, share and use data that identifies or is associated with you (hereinafter “personal information“). It also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out in the “Accessing and Correcting your personal information” section.

1. 1. For the purposes of the applicable data protection legislation (including the General Data Protection Regulation), Secret Escapes Limited is the data controller of personal information we hold about you.

1. 1. You should also be aware that we use cookies to store and access information whilst providing access to our site or our app. You can find out more about our use of cookies in our cookie notice below.

1. Personal INFORMATION we COLLECT about you

1. 1. We collect personal information about you when you voluntarily submit information directly to us, our site or our app. This can include information you provide to us when you complete a form, correspond with us or agree to sell your rooms through our website.

1. 1. We also collect personal information from you indirectly such as information about the pages you look at on our site or our app or the device you use to view our site or connect to our app with.

1. 1. The list below sets out the categories of personal information we collect about you and how we use that information.

Contact details: We collect contact information such as your name, your email address and your telephone number.

Information about how you use and connect to our site or our app: We collect information about how you use our site or our app such as the pages you view on our site or our app, the time you access our site or our app and how long you use it for, the website from where you came to our site or our app or go to after leaving our site or our app and any selections and choices you make when using our site or our app.

We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our site or our app. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our site or our app through the device, your Internet service provider or mobile network, your IP address and your device’s telephone number (if it has one).

Typically, the information we collect about how you use or connect to our site is associated with your device and not you as a named individual. However, if you are logged into a registered account you have with us this information may also be associated with you directly.

Information about your location: Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may help us determine an approximate location. We will not collect or track your exact location without your consent.  Where necessary we will seek your consent before using information about your exact location.

All personal information: We will use all the personal information we collect to monitor and improve our site, our app and our procedures and processes. Our use of your personal information in this way will not result in information that was not previously publicly available being made public on our site or through our app.

1. How we use your personal information, and what our legal basis is for this use

1. 1. We process your personal information for the following purposes:

Where you give us consent, we will:

1. 1. 1. 1. Contact you for the purposes of discussing listing your property on our website

Place certain cookies and use similar technologies subject to consent requirements

As required to conduct our business and pursue our legitimate interest. In particular, we will:

1. 1. 1. 1. Use information about how you use and connect to our site and our app to optimise your experience of our site or our app on your device, to determine offers that may be of interest to you for marketing purposes and to assess the success of our marketing campaigns
         2. Monitor use of our site or our app for the purposes of detecting and preventing fraud or crime
         3. Use your personal information help us develop new products and services

For purposes which are required by law, such as requests by governments or law enforcement authorities conducting an investigation.

1. 1. We may anonymise and aggregate any of the information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our site and developing new products and features.
2. Information we share with third parties

1. 1. We may share your personal information with the following parties:

1. 1. 1. Companies in the same group of companies as us: our subsidiaries (i.e. any organisation we own or control) or our holding company or ultimate holding company (i.e. any organisation that owns or controls us) and any subsidiaries they own. These companies will only use your personal information in the same way as we can under this privacy notice.

1. 1. 1. Service providers and advisors: third parties who provide a service to us. For example, third party service providers help support our IT infrastructure, process payments from you on our behalf, develop analytical information for us about our products, services and marketing and provide professional services such as legal and accountancy services. These third parties will only be allowed to use your personal information in accordance with our instructions and will be required to keep your information secure.

1. 1. 1. Purchasers of our business: personal information may be disclosed or transferred to buyers or prospective buyers of our business or any of our assets as part of any such sale.

1. 1. 1. Law enforcement, regulators and other parties for legal reasons: third parties who we are under a legal obligation to disclose your personal information to or to whom we need to disclose your personal information to protect our rights, property or safety or to protect the rights, property or safety of others. For example, we may provide information to the United States Customs and Border Protection agencies if you are travelling to the USA. We may also disclose personal information to third parties to help detect and investigate illegal activities and breaches of any agreement we have with you.

1. 1. We may provide third parties with aggregate statistical information and analytics about users of our site or our app but we will make sure no one can be identified from this information before we disclose it.

1. ONLINE ADVERTISING
   1. We, or our advertising partners, may show advertisements to you on our site, our app or on other websites or apps. To do this we, or our advertising partners, may collect information about how you use or connect to our site, our app or the types of other web pages, social media services, content and ads you, or others who are using the device you connect to our site or app with, interact with, visit or view. The information collected might also include the IP address of the device you connect to our site or our app.

We, or our advertising partners, use the information that is collected to make sure the adverts you see either on our site, our app or other parties’ websites and apps (where our partners have advertising space) are more relevant to you.

Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our cookie notice below.

1. Storing and transferring your personal information

1. 1. Cookies and Local Storage: we may store information (which may include personal information) locally on your device using cookies and other browser and application storage methods. For further information please see our cookie notice below.

1. 1. Security: we implement appropriate technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change, or damage.

1. 1. International Transfers of your Personal Information: the personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in. Data may be transferred from the EEA to the USA and Singapore, principally due to our offices in those countries being able to access data, but also for the purposes of hosting our website servers on which data is held. Some of these jurisdictions offer differing levels of protection in respect of personal information and may, in certain instances, be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy notice. Where information is transferred outside the EEA and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision by the EU Commission, data is adequately protected by EU Commission approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor’s Processor Binding Corporate Rules. 

1. How Long we keep your personal Information

1. 1. Where we process registration data, we hold this for a period of 2 years or until you withdraw your consent for us to hold such data.
   2. Where we subsequently agree a contract for the sale of rooms in your property we will retain your registration data for the duration of our agreement and for up to six years thereafter. We will endeavour to ensure that the data that is retained beyond the expiry or termination of our agreement is limited to only that which is necessary to fulfil our legal obligations. 
2. Accessing and correcting your personal information

1. 1. You have the following rights in relation to your personal information:

(i) the right to be informed about how your personal information is being used;

(ii) the right to access and receive a copy of the personal information we hold about you;

(iii) the right to request the correction of inaccurate personal data we hold about you;

(iv) request for your data to be shared (ported) to another controller; and

(v) to request the blocking, restriction or deletion of your personal information.

In addition, you have the right to object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing). To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the “Contacting us” section below. 

1. 1. If there is personal information which you think we hold, please contact us using the contact details set out in the “Contacting us” section below. Please provide as much information as you can about the personal information you are looking for and we will be happy to try and help you find it. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work, or were you believe a breach may have occurred.

1. Links to third party sites

Our site may, from time to time, contain links to and from third party websites of our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

1. Changes to this Notice

We may update this privacy notice from time to time and so you should review this notice periodically. When we change this privacy notice in a material way, we will update the “last modified” date at the bottom of this privacy notice. Changes to this privacy notice are effective when they are posted on this page.

1. Notice to you

If we need to provide you with information about something, whether for legal, marketing or other business-related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our site. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy notice.

1. Contacting us

Questions, comments and requests regarding this privacy notice are welcome and should be addressed to:

Secret Escapes Limited,

4th Floor,

120 Holborn,

London

EC1N 2TD,

support@secretescapes.com

This Privacy Notice was last modified on 9 August 2018.