Exchange Holiday Homes

Website privacy Policy
Last updated on 27/04/2018

INTRODUCTION
Welcome to Exchange Holiday Homes privacy notice.
Exchange Holiday Homes respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Please use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1.  IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Exchange Holiday Homes collects and processes your personal data through your use of this website (which includes the domain https://www.exchangeholidayhomes.com/  all related subdomains and the domains related to The Getaway Company), including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
CONTROLLER
 “Exchange Holiday Homes” is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

CONTACT DETAILS
Our full details are:
Full name of legal entity: Exchange Holiday Homes
Email address: admin@exchangeholidayhomes.com
Postal address: R13, Liskeard Enterprise Centre, 1 Holman Road, Liskeard, Cornwall. PL14 3UT. England.
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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
The data protection law in the UK will change on 25 May 2018. Although this privacy notice sets out most of your rights under the new laws, we may not yet be able to respond to some of your requests (for example, a request for the transfer of your personal data) until May 2018 as we are still working towards getting our systems ready for some of these changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website currently does not but may in the future include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2.  THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

  • Identity Data includes first name, last name, username or similar identifier,
  • Contact Data includes home address, exchange property address, email address and telephone numbers
  • Transaction Data includes details of products (Credits) and services (Holiday Homes Exchange arrangements) you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile Data includes purchases or requests made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3.  HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your [Identity, Contact and Financial Data] by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • apply for or use our products or services;
    • subscribe to our service;
    • request marketing or content to be sent to you;
    • attend one of our events or meet us at an event hosted by a third party
    • correspond with our Sales or Customer Success teams
    • enter a competition, promotion or survey; or
    • give us some feedback.
  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We currently do not collect any personal data by using cookies, and other similar technologies.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
    • Technical Data from  analytics providers such as Google and Hubspot based outside the EU;
  • Identity and Contact Data from data brokers or aggregators.
  • Identity and Contact Data from Social Media Platforms
  • Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.

4.  HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the provision of services agreement we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.
PURPOSES FOR WHICH WE WILL USE 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.