Cornish Secrets ("We") are committed to protecting and respecting your privacy.
Our site is not to be used by children and we do not offer any booking services to children. However, a parent or guardian may provide details of children who will be staying at the property during the booking process for the purpose of ensuring that the property is not over-occupied and suitable for the relevant party of guests.
You may be asked to provide personal data whilst you are in contact with us. Personal data is information that can be used to identify or contact you. You do not have to provide the personal data that we request, however, if you choose not to, we may not be able to provide you with the services that you have requested.
If we combine personal data with non-personal data, the combined information will be treated as personal data for as long as it remains combined. Personal data does not include data where the identity has been removed (anonymous data).
For the purpose of the General Data Protection Regulations ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation and the Data Protection Act 1998 (“Data Protection Legislation”) the data controller is Cornish Secrets a business registered in England and Wales with registration number 2290134 whose registered office is at Brooklyn, Helscott Road, Marhamchurch, Bude, Cornwall, EX23 0JE. Our Data Protection Registration Number is ZA345579
Information we may collect from you and how we use it
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing our legitimate interests, namely monitoring and improving our website and services.
- account data ("account data"). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and the property owner and/or taking steps, at your request, to enter into such a contract.
- information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
- information contained in any enquiry you submit to us regarding or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is consent.
- information relating to transactions, including renting properties, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of fulfilling the holiday booking and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
- information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
- information contained in or relating to any communication that you send to us, including when you enter into a competition, promotion or survey ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
We may also provide you with information about offers and services that are similar to those that you have already received or we feel may interest you. If you:
- have already concluded a contract with us (for example, allowing us to rent out your property), we will only contact you by electronic means (e-mail or text) with information about offers and services similar to those which were the subject of a previous contract. If you do not want to be on our mailing list, you can opt out at any time by contacting us or unsubscribing by using the links provided in our electronic communications and at the point of providing your details.
- are a potential new customer (e.g. enquiring about our properties or services), we will contact you by electronic means only if you have provided your explicit consent to this. If you are happy for us to use your personal data in this way, please tick the relevant box situated on the website page on which we collect your details. Again, if you do not want us to use your data in this way, you can opt out at any time by contacting us or unsubscribing by using the links provided in our electronic communications.
In addition to the specific purposes for which we may process your personal data set above, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
When using our site, we do not collect any information about criminal convictions and offences.
Where we store your personal data
Some of the third parties whom we work closely with are based outside of the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside of the EEA.
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.
Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Change of purpose
Disclosure of your information
You agree that we may disclose your information (including personal data) to the following categories of third parties:
- suppliers and sub-contractors (which may include housekeepers) for the performance of any contract we enter into with them or you;
- analytics and search engine providers that assist us in the improvement and optimisation of our site; and
- data storage providers, in connection with cloud storage and file hosting services.
Your personal data will not be shared with third parties for third party marketing purposes unless you have provided your express consent.
We may disclose your personal data to third parties:
- where we have your consent to do so;
- to provide and/or improve our services;
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if Cornish Secrets or substantially all of our assets are acquired by a third party, in which case personal data held by us about you will be one of the transferred assets; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights of Cornish Secrets, our customers, owners, guests or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Under Data Protection Legislation, in certain circumstances you have the following rights in relation to your personal data:
- Right to access. You have the right to request access to information held about you. We will provide you with a copy of your personal data held by us free of charge (providing your request is not excessive or for multiple copies, in which case we may charge a reasonable fee to cover our costs) and certain information about the processing of your personal data and the source of such data (if not directly collected from you by us). You also have the right to request that your personal data is transferred to a third party.
- Right to object to data processing. You may withdraw your consent to the processing of your personal data at any time by contacting us or ticking a box to opt out of receiving marketing materials. Upon receipt of your notification, we shall promptly stop any processing of your personal data and (if requested by you) erase such information if we are not required to retain it for legitimate business or legal purposes.
- Right to restrict processing. You may ask us to suspend the processing of your personal data in the following circumstances:
- if you do not think your personal data is accurate;
- where we are found to be processing unlawfully but you do not want us to erase your personal data;
- where you need us to continue holding your personal data to establish, exercise or defend legal claims; or
- you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
- Right of rectification and right of erasure. You have the right to request that we correct or erase any inaccuracies in your personal data if such information would be incomplete, inaccurate or processed unlawfully.
Where we are relying on consent to process your personal data, you may withdraw consent at any time. 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 services to you. We will advise you if this is the case at the time you withdraw your consent.
You can also exercise these rights at any time by contacting us at firstname.lastname@example.org. We may reject requests that are unreasonable or require disproportionate effort (for example, such a request would result in a fundamental change to our existing practice) or risk the privacy of others.
Our site may, from time to time, contain links to and from third party websites. 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 these policies. Please check these policies before you submit any personal data to these websites.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Personal data retention
We may retain information about you, including personal data, for the period necessary to fulfil the purposes for which it was first collected unless a longer retention period is required or permitted by law. In determining data retention periods, we take into considerations contractual obligations, legal obligations and the expectation and requirements of our customers. When personal data is no longer needed, we will securely delete or destroy it.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
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.
If you have any cause for complaint about our use of your personal data, please contact us using the details provided above and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office (www.ico.org.uk).