Introduction

Nutcombe Holiday Cottages are committed to protecting and respecting our visitors’ privacy in line with the General Data Protection Regulation 2018 (GDPR). The GDPR sets out the rules on processing of personal data.

This policy 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 how we will treat your personal data.

Definitions Appropriate to our use of Personal Data (Article 4 of GDPR)

Data controller – The person or entity that determines the purposes and means of processing personal data.

Data processor – The person or entity responsible for processing personal data on behalf of a controller.

Consent – Consent of the ‘Data Subject’ (see below), means any freely given, specific, informed and explicit consent by statement or action signifying agreement to the processing of their personal data.

Data subject –  A ‘Natural Person’ whose personal data is processed by a controller or processor.

Personal Data – Any information related to a natural person or ‘Data Subject’, that can be used to directly or indirectly identify the person in particular by reference to an identifier. For example, name, age (under 25’s), home address, phone numbers, email address and car registration. Online identifiers include IP addresses

Processing -  Any operation which is performed on personal data, 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 – means 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.

Data Erasure – Also known as the Right to Be forgotten entitles the data subject to have the data controller erase his/her personal data, cease further dissemination of the data, and potentially have third parties cease processing of the data.

Right to Access – Entitles the ‘Data Subject’ to have access to and information about the personal data that a controller has concerning them.

Who are we?

Nutcombe Holiday Cottages is the ’Data Controller’ and ‘Data Processor’. This means we are responsible for determine the purposes and means of processing personal data and for what purpose. Nutcombe Holiday Cottages is owned and managed by David & Jackie Penny at Nutcombe Farm, Nutcombe Hill, Combe Martin, North Devon EX34 0PQ Tel: 01271 889379, email nutcombecottages@googlemail.com

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:

• Personal data: name, phone number, address, email
• We have obtained your personal data directly from you or your booking agent in the case of Blue Chip Holidays, Trip Advisor, Cottages Direct, Country Cottages, The Holiday Cottages or IHA Holidays.

• Special categories personal data –We do not process any sensitive personal data.

The purpose of processing your personal data

We use your personal data for the following purposes:

• Making your booking to stay in one of our cottages
• Keeping in touch regarding your booking as follows:

• Confirmation of booking
• Receipt of money paid
• Directions to Nutcombe Cottages
• Information on key collection)

• Getting in touch should we have any queries about your booking
• Making repeat bookings using the data we have saved
• Staying in contact with you after you have stayed with us by means of:

• E-newsletters (annually)
• Special Offers
• Christmas cards
• Possible reviews

Our Lawful Basis for processing your personal data in line with Article 6 of GDPR

• Consent of the Data Subject

• You have provided the information needed to complete a Booking Form in order to secure a holiday at Nutcombe Holiday Cottages
• You have signed the Booking Form to say that you have read, understood and agreed to our Terms & Conditions and Privacy Statement
• You have asked us to provide information about our holiday cottages
• You have asked to be registered on our mailing list for special offer/late deals

• Contract
• By completing and signing a Booking Form you have entered into a contract to make a booking at Nutcombe Cottages subject to our Terms and Conditions

• Legal Obligation
• If you have made a booking with us, we will hold your information for 5 years after filing our Tax Return in line with Inland Revenue requirements for partnerships

Sharing your personal data

Your personal data will be treated as strictly confidential and will not be shared.  The only exception is if the Inland Revenue ask to see our Booking Forms to confirm our bookings.

How long do we keep your personal data?

• We keep your personal data used for making a booking for a period of 5 years after filing our tax return in order to comply with Inland Revenue accounting requirements.
• If you are on our mailing list we will keep the data for as long as you wish to remain on the list.  If you ask to be removed we will do that immediately.
• If you have simply enquired about a booking at Nutcombe Cottages, we will keep our joint email correspondence for 6 months as a record of what has been said in the event that you come back to us wishing to book a holiday.

 Providing us with your personal data

We require some personal contact data if you require further information from us in writing (either email/letter) which you cannot find on our website or if you wish to make a booking with us.

Security of your personal data

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect from our visitors.

We have also secured our office computers and paper filing systems which we also use to store your personal information.

Our website

Our website uses Cookies to monitor your web usage which you are asked to agree to.

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 consent was our 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).

Transfer of Data Abroad

We do not transfer any of your data abroad

Automated Decision Making

We do not use any automated decision making in our business

Further processing

If we wish to use your personal data for a new purpose, not covered by this Privacy Statement, 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.

Changes to our privacy policy

Any changes we may make to our privacy policy in the future will be posted on our website, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

How to make a complaint

To exercise all relevant rights, queries or complaints please in the first instance contact David & Jackie Penny at Nutcombe Farm, Nutcombe Hill, Combe Martin, North Devon EX34 0PQ Tel: 01271 889379 Email: nutcombecottages@googlemail.com

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 via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.