GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
1. Introduction
MY PRIVATE VILLAS LTD. (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
2. Definitions
Data controller: A controller determines the purposes and means of processing personal data.
Data processor: A processor is responsible for processing personal data on behalf of a controller.
Data subject: Natural person
Website: www.myprivatevillas.com
Categories of data: Personal data and special categories of personal data
Personal data: The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified, in particular by reference to an identifier (as explained in Article 6 of GDPR). For example: name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data: The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing: Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party: A natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
3. Who are we?
MY PRIVATE VILLAS LTD. is the data controller. This means we decide how your personal data is processed and for what purposes. For all data matters, please contact Mr Paolo Macchiaroli (Director) via email at info@myprivatevillas.com, alternatively you can call +44 (0) 20 8672 7040, or write to My Private Villas Ltd, c/o Unit 102, 143 Acre Lane, London SW2 5UA, United Kingdom.
4. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
4.1 - We will use your name, address, telephone numbers, email address, credit card details and copy of your passport/ID card to complete your booking with us and make travel arrangements.
4.2 - For the purpose of completing your booking, we may have to disclose some of your information to the providers of the services making up your arrangements (who could be located outside the UK/EEA). We may also have to disclose some information to third parties in relation to customer services, credit card processing, or other services.
4.3 - We may from time to time contact you with information about special offers, benefits to our clients, brochures, new products, news about us, forthcoming events or competitions. At any time, you may request to discontinue receiving marketing correspondence by email, mail or phone from My Private Villas.
4.4 - We have taken all reasonable steps to have appropriate security measures in place to protect your information. Outside the European Economic Area, controls on data protection may not be as wide as the legal requirements in this country. The transmission of information via the internet is never completely secure. We exclude our liability for personal data lost in transmission to the website.
4.5 - At any time, depending on the specific processing, you may: revoke your consent to the processing, know which of your personal data we have in our possession, its origin and how it is used, request the update, correction or integration and in the cases provided for by the current provisions, the cancellation, the limitation of processing or oppose their processing. If you wish, you can request to receive your personal data in possession of MY PRIVATE VILLAS LTD in a format readable by electronic devices and, where technically possible, we can transfer your data directly to a third party indicated by you.
5. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
5.1 Personal data for order processing
The personal data you and the members of your party give us may include: your full name, address, e-mail address and phone number, financial and credit card information and a copy of your Passport or ID card. This is necessary for us to complete your booking and facilitate travel and other services requested by you.
We may also collect all or some of the following information relating to you or other members of your party:
- Special requirements such as those relating to any disability or medical condition, which may affect the chosen arrangements;
- Age of any children traveling with you, which may affect the booking arrangements;
Dietary requirements or restrictions (which may disclose your religious beliefs or any medical condition/s);
Information necessary to facilitate the booking, travel and any other services requested by you or members of your party.
You are responsible for ensuring that other members of your party are aware of the content of this Policy and consent to your acting on their behalf in all your dealings with us.
Some of the information we collect (such as about health or religion) may be considered “sensitive personal data” under the Data Protection Act 1998.
We collect it to cater to your needs or act in your interest, and we are only prepared to accept sensitive personal data from you on the condition that we have your positive consent.
So with your express consent, by analysing your personal data we can process information regarding your interests and preferences with respect to our products and services in order to present proposals and offers in line with your tastes. In case of authentication to the Myoox account through external social networks, we collect the data necessary for registration/authentication through Facebook and Google. We also collect information about you from third parties and, in particular, from Facebook and Google+. This information includes the following data categories: e-mail address.
We might collect information about your browsing on www.myprivatevillas.com, such as the pages you visit and how you interact with the single page and we save this information on our servers.
In the event that you provide personal data of third parties to MY PRIVATE VILLAS LTD, we will arrange for the third party to deliver the Privacy Notice at the time of the first communication. We remind you that the use of personal data of third parties is subject to the discipline regarding the protection of personal data.
We inform you that MY PRIVATE VILLAS LTD does not process personal data relating to minors. If you access www.myprivatevillas.com and use the services offered by MY PRIVATE VILLAS LTD, you declare that you are of legal age.
5.2 Online Surveys and Reviews
We value opinions and comments from customers MY PRIVATE VILLAS LTD and you may have the opportunity to give us your feedback through Site surveys and reviews (eventually done by third parties). In conducting these surveys and reviews, we may ask for your Personal Information so that we (or third parties) can appropriately identify you. Survey, Review and Personal Information collected might be aggregated and used to make improvements to the Site and improve My Private Villas products and services. Participation in these surveys and reviews is completely voluntary and you therefore have a choice whether or not to disclose the required information.
5.3 Non-Personally identifiable information
Some non-personally identifiable information and statistical data is collected and stored automatically when a Data Subject visits the Website. If a Data Subject does nothing during its visit but browse through the Website, read pages or download information, we may gather and store certain statistical information about your visit automatically. This information does not identify a Data Subject personally. Our system collects data in the server log that may include: IP address, domain name, type of browser, operating system, online activity (including, without limitation, pages viewed, search requests, and purchases made). If the Data Subject linked to the Website from another web site, that website’s address may be logged. We may collate and aggregate this data and use it for statistical purposes. For example, the aggregated data helps us to determine the volume of its Website users’ interest in areas of the Website. It also helps us understand how it can improve the navigation and content of the Website. We may disclose this information to third parties.
5.4 How do we use the personal data we collect?
Your personal data has been acquired with us via one or more of the following:
· Telephone and/or E-mail communications/Enquiries
· Newsletter subscriptions and/or Update requests
· Chat or Call-Back request tools on our website
· Party Agencies that have contacted us as a Supplier
· Social Media requests/messages (i.e. LinkedIn connect requests, or Direct Messages)
· Representative Marketing and/or PA Agencies.
My Private Villas Ltd collects and processes your personal data for the following purposes:
· To receive offers related with the request that you’ve sent us. When you complete your request, we ask you for the personal data necessary for the execution of the properties search, such as your full name, your email address, your telephone, number, the composition of your group, the age of any children, etc.
· To conclude and execute the booking agreement offered via email or telephone or via www.myprivatevillas.com. When you complete your booking, we ask you for the personal data necessary for the execution of the agreement, such as payment, anti-fraud checks if you choose to pay by credit or debit card, billing, etc.
· Registration on the site and use of the services offered to registered users. Registration on the site is possible through the inclusion of some personal information which is necessary to ensure your identification and the performance of services offered to registered users.
· Provision of the services offered on www.myprivatevillas.com. For this purpose, in relation to each service and its characteristics, My Private Villas Ltd needs to collect the personal data necessary for the performance of the service requested by you.
· Management of requests to our Team, which uses the personal data you provide to meet your requests for information and requests for assistance.
· Sending of CVs. If you send us your CV to be considered for an application to an open position, we will use the information contained in your CV exclusively for this purpose. Your CV will be kept for a maximum period of six months, after which it will be deleted: if you wish, you can of course send us a new updated version.
· Statistical analysis and surveys. We use some information about your use of the site to perform statistical analysis and surveys in order to improve our offer and our services.
· Sending commercial and promotional communications following the request to book of one of the properties we represent, so-called soft spam. Following the request to book of one of the properties we represent, we will send you communications containing our business proposals and related products and services to the e-mail address that you provided us.
· Subject to your express consent, we may use the contact details you have provided for commercial communications on our products and services, in order to update you on news, new arrivals, exclusive products, our offers and promotions. In addition, always with your consent, we will be able to use your contacts as part of market research and surveys for the detection of satisfaction in order to improve our services and the relationship with our users. These communications will take place exclusively with the methods you have chosen (via e-mail, SMS, telephone, paper mail, Whatsapp).
· Only with your consent, My Private Villas Ltd will be able to personalise your experience as a registered user on www.myprivatevillas.com, proposing previews and offers in line with your tastes and sending you commercial communications tailored to your interests, these communications will only take place in the manner you selected (via e-mail, SMS, telephone, paper mail, Whatsapp). The personalisation will be done by analysing your previous requestews and bookings and other information described in the previous paragraphs.
· Should you wish to do not wish to receive further communications from My Private Villas Ltd or would like to limit the way in which to be contacted, you may interrupt these communications at any time by simply clicking on the appropriate unsubscribe link at the bottom of each communication.
· We inform you that you may receive further communications from us even after submitting your unsubscription request, as some submissions may have already been planned, our systems may take some time to process your request.
· In relation to all the activities mentioned above, we will process your personal data mainly through IT and electronic means; the means we use guarantee high safety standards, in full compliance with current legislation.
6. What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR).
Our lawful basis for processing your general personal data:
6.1 Consent of the data subject
As regards the execution of the contract, your consent to the processing of your personal data is not necessary. To respond to specifications that are beyond the scope of the contract we could:
- Telephone and/or E-mail communications/Enquiries
- Newsletter subscriptions and/or Update requests
- Sending proposals and commercial offers, telemarketing, marketing and statistics
- Sharing of your personal data with companies and professionals for the execution of contractual, tax, technological and legal activities
- Sharing of your personal data with companies and professionals for the execution of any services you might request us
- Live Chat or Call-Back request tools on our website
- Reviews via our web site or via third parties tool review providers
- Third Party Agencies that have contacted us as a Supplier
- Social Media requests/messages (i.e. LinkedIn connect requests, or Direct Messages)
- Representative Marketing and/or PA Agencies.
General Information and Offers
You agree to receive general information and offers from us as indicated in par 6.1 of our Privacy Policy
Marketing
You agree to receive marketing information from us as indicated in par 6.1 of our Privacy Policy
Promotions
You agree to receive promotional information from us as indicated in par 6.1 of our Privacy Policy
6.2 Processing is necessary for the performance of a contract
Processing is necessary for the performance of a contract with the data subject and in
particular, into the Booking Form Contract.
7. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only in the following circumstances:
7.1 - For the purpose of completing your booking, we may have to disclose some of your information to the owners, managers, and staff of properties and to providers of the services making up your arrangements (who could be located outside the UK/EEA). We may also have to disclose some information to third parties in relation to customer services, credit card processing, or other services.
7.2 - We may need to disclose your information where required by law, where such a request is made by a legal authority.
7.3 - We may need to disclose our customer list including any personal information relating to you to a third party who acquires or attempts to acquire all or substantially all of the asset/ stock in our company or our website.
7.4 - We may also disclose information to organisations who act as “data processors” on our behalf, or to other organisations that perform business functions on our behalf, some of whom are outside the UK/EEA. These functions include administration, providing services (and contacting you if/when necessary), customer care, business management and operation, re-organisation/structuring/sale of our business (or our group companies), risk assessment, security and crime prevention/detection, research and analysis, marketing, monitoring, measuring and assessing customer purchasing preferences and trends, dispute resolution, credit checking and debt collection.
8. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary, in any case no longer then 5 years from your last interaction with us and we only retain your data for marketing purposes such as sending you regular news, special offers, news about Passepartout Homes, surveys, competitions. You have the right to remove yourself from our database at any time.
9. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences:
10. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
- the right to request a copy of the personal data which we hold about you;
- the right to request that we correct any personal data if it is found to be inaccurate or out of date;
- the right to request your personal data is erased where it is no longer necessary to retain such data;
- the right to withdraw your consent to the processing at any time, where the consent was your lawful basis for processing the data;
- the right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), (where applicable i.e. where the processing is based on consent or is necessary for the performance of a contract with the data subject and where the data controller processes the data by automated means);
- the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- the right to object to the processing of personal data, (where applicable i.e. where processing is based on legitimate interests (or the performance of a task in the public interest/exercise of official authority); direct marketing and processing for the purposes of scientific/historical research and statistics).
11. Transfer of Data Abroad
For the purpose of completing your booking, we may have to disclose some of your information to the owners, managers, and/or staff of properties, and to the providers of the services making up your arrangements (who could be located outside the UK/EEA). We may also have to disclose some information to third parties in relation to customer services, credit card processing, or other services.
We have taken all reasonable steps to have appropriate security measures in place to protect your information. Outside the European Economic Area, controls on data protection may not be as wide as the legal requirements in this country. The transmission of information via the internet is never completely secure. We exclude our liability for personal data lost in transmission to the website.
12. Automated Decision Making
We don’t use any form of automated decision making in our business.
13. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
14. External Links
Please note that our website contains certain literature and hyperlinks to websites owned by third parties. This privacy statement covers websites owned and controlled by us only. Links to other websites and any information collected by these sites are not covered by this privacy statement.
15. Security
We will make reasonable efforts to ensure that information provided by the User will be maintained in a secure environment. Unfortunately, no data transmission via the Internet can be guaranteed as being 100% secure. Consequently, while we strive to protect your personal information, we cannot guarantee the security of any information transmitted to My Private Villas Ltd. or from the Website, and the User provides such information at its own risk.
The Website is hosted by a third party service provider which is neither controlled by nor affiliated with My Private Villas Ltd. We can make no representation or warranty as to the security measures of any third party, including, but not limited to, the host of the Website. We expressly exclude any and all liability arising out of or in connection with acts or omissions by any third party including, but not limited to, the host of the Website. My Private Villas Ltd. recommends that you review the privacy policy of any third party prior to using any third party’s website.
16. Cookies
Non-personal information may also be collected with the use of cookies. “Cookies” are small text files a website can use to recognise repeat users. When someone visits the Website, a cookie is placed on the visitor’s machine (provided that the visitor’s web browser has been set to accept cookies) or is read if the visitor has visited the Website previously. We may collect aggregated Website-visitation statistics using cookies. For example, every time you log in to the Website, we may record your member ID and the name of your member account in the cookie file on your computer. Your password may also be recorded in this cookie file if you selected the “Save this password for automatic log-in” feature or similar options. If the User does not wish to accept cookies it should set its web browser to reject cookies or to warn the User prior to accepting cookies.
The third-party advertising providers may also use cookies or technologies to, for example, measure the effectiveness of their ads or provide advertisements about goods and services that may be of interest to you. Although no personally identifiable information about you is collected during this process, we have no access to or control over such cookies or technologies.
Since 26 May 2012, all websites registered in the United Kingdom are under an obligation to obtain your consent to download cookies onto your computer for any reason other than where it is strictly necessary to download cookies onto your computer, e.g. where a cookie is required to remember the holiday arrangements you have chosen in order to allow you to proceed to the checkout and purchase the arrangements. Therefore from this date, we request your consent to download cookies onto your computer for services where it is not strictly necessary to do so. You can choose to opt out and prevent us from downloading cookies from your system, however this will affect your user experience of our website and we may not be able to offer you all the services on our website as a result. Therefore, in order to provide you with the best experience of our website and offer you all of our services, we would recommend opting in and allowing us to download cookies on to your computer. If you would like to opt out please email us – info@myprivatevillas.com
To find out more information about cookies, please visit www.allaboutcookies.org.
17. Links to Third Party Website
Links to third party websites (not maintained by My Private Villas Ltd.) which appear on this Website are provided solely as a convenience to our customers and visitors. If you use these links, you will leave this Website. My Private Villas Ltd. does not have control over and is not responsible for any of these websites or their content. My Private Villas Ltd. does not endorse or make any representations or warranties about such websites, or any information, opinions, software or other products or materials which may be found therein, nor does My Private Villas Ltd. make any representations or warranties about any results that may be obtained from using them. If you decide to access any of the third party websites linked to this Website, you agree that you do this entirely at your own risk. It is your responsibility to ensure that any links you select or program/software/data/material you download (whether from this Website or other websites) is free of viruses, Trojan horses, worms, defects and similar potentially harmful items. You should be aware that linked third party websites may contain rules and regulations, privacy provisions, confidentiality provisions, transmission of personal data provisions, and other provisions that differ from the provisions provided on this Website. Passepartout Homes Ltd. is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.
18. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
19. How to make a complaint
To exercise all relevant rights, queries or complaints please, in the first instance, contact My Private Villas Ltd., c/o Unit 102, 143 Acre Lane, London SW2 5UA, United Kingdom.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
