Website Privacy Policy
Policy version: 5th November 2022
https://boutiqueluxuryretreats.co.uk/ (our website) is provided by Hooley Time Ltd (‘we’, ‘our’ or ‘us’). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
This privacy policy should be read alongside, and in addition to, our Terms and Conditions, which could be found at: Terms and Conditions
This privacy policy is divided into the following sections:
• What this policy applies to
• Personal data we collect about you
• How your personal data is collected
• How and why we use your personal data
• Marketing
• Who we share your personal data with
• How long your personal data will be kept
• Transferring your personal data out of the UK and EEA
• Cookies and other tracking technologies
• Your rights
• Keeping your personal data secure
• How to complain
• Changes to this privacy policy
• How to contact us
What this policy applies to:
This privacy policy relates to your use of our website only.
Personal data we collect about you:
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
• your name and contact information, including email address and telephone number
• details of any information, feedback or other matters you give to us by phone, email, post or via social media
• your account details, such as username and login details
• your activities on, and use of, our website
• information about the services we provide to you
• your contact history, purchase history and saved items
• information about how you use our website and technology systems
• your responses to surveys, competitions and promotions
Unless we tell you that you have a choice, you must provide this personal data as it may prevent us from providing our services to you.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you register with us, contact us (including via email), send us feedback, post material to our website and complete customer surveys or participate in competitions via our website, and
- indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explain in the section on ‘Cookies and other tracking technologies’ below.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
| What we use your personal data for | Our reasons |
| Create and manage your account with us | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations |
| To enforce legal rights or defend or undertake legal proceedings | Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect our business, interests and rights |
| Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | Depending on the circumstances: —your consent —where we are not required to obtain your consent and do not do so, for our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Communications with you not related to marketing, including about changes to our terms or policies or changes to our services or other important notices | —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us manage our business, e.g. in relation to our financial performance, user base or other efficiency measures | For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price |
| Updating and enhancing customer records | Depending on the circumstances: —to comply with our legal and regulatory obligations —where neither of the above apply, for our legitimate interests, eg making sure that we can keep in touch with our customers about existing orders and new products |
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, e.g. to record and demonstrate evidence of your consents where relevant. | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former customers | For our legitimate interests, i.e. to promote our business to existing and former customers See ‘Marketing’ below for further information |
| External audits and quality checks, e.g. for the audit of our accounts | Depending on the circumstances: —to comply with our legal and regulatory obligations — in other cases, for our legitimate interests, i.e. to assess our record keeping and accounting so |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances: —to comply with our legal and regulatory obligations —in other cases, for our legitimate interests, ie to protect, realise or grow the value in our business and assets |
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We may use your personal data to form a view on what we think you may want or need, or what may be of interest to you.
We may then use your personal data to send you marketing communications from us if you have requested information from us or purchased from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by using the ‘unsubscribe’ link in emails.
Who we share your personal data with
We routinely share personal data with:
- third parties we use to help deliver our services to you, e.g. retreat site owners;
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data.
We or the third parties mentioned above occasionally also share personal data with:
● external auditors, e.g. in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
● professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
● law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
● other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is needed.
Transferring your personal data out of the UK
The EEA, UK and other countries outside the EEA and the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK/EEA. In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
- in the case of transfers subject to UK data protection law, the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
- in the case of transfers subject to EEA data protection laws, the European Commission has decided that the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries the European Commission has currently made adequacy decisions in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Where we transfer your personal data outside the EEA we do so on the basis of an adequacy decision or (where this is not available) legally-approved standard data protection clauses issued further to Article 46(2) of the EU GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the EEA unless we can do so on the basis of an alternative mechanism or exception provided by applicable data protection law and reflected in an update to this policy.
Cookies and other tracking technologies
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.
For further information on cookies, our use of cookies , when we will request your consent before placing them and how to disable them, please see our Cookies Policy
Your rights
You generally have the following rights, which you can usually exercise free of charge:
Access to a copy of your personal data | The right to be provided with a copy of your personal data |
Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
To object to use | The right to object: —at any time to your personal data being used for direct marketing (including profiling) —in certain other situations to our continued use of your personal data, eg where we use your personal data for our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defence of legal claims |
Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by emailing info@boutiqueluxuryretreats.co.uk detailing this request clearly Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner may be contacted at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
This policy was last updated on: 5th November 2022
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example by including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
How to contact us
You can contact us by post or email if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our email address is info@boutiqueluxuryretreats.co.uk, and our address is Well Furlong, Little Comberton, Worcestershire, WR10 EP.