Last updated: 8th May 2018
1.1 We are committed to safeguarding the privacy of our website visitors.
1.2 This policy applies where we are acting as both a data controller with respect to the personal data of our website visitors (in other words, where we determine the purposes and means of the processing of that personal data) and as a data processor (in other words where we can only make limited ‘non-essential’ decisions about how to go about processing data for the purposes determined by the controller).
1.4 In this policy, “we”, “us” and “our” refer to Robert Green Marketing, owners of the website www.brixhamholidaycottages.net.
2.1 This document was created using a template from SEQ Legal.
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website (“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. 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 is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process data for the purposes of affiliate marketing. This may include information such as click through time, affiliate identifier, IP address etc which will be combined with information captured at the point of sale to ascertain whether a valid transaction has been driven by an affiliate. This applies to the processing of personal data as individuals travel from the publisher website to advertiser websites, via affiliate marketing domains, tracking the confirmation of the transaction and the subsequent reporting available in the user interface. The affiliate marketing networks we use consider that the the legal basis for processing personal data under GDPR is legitimate interest.
3.4 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.5 We may process 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.
3.6 We may process information contained in or relating to any communication that you send to us (“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.
3.7 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.
3.8 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.
3.9 In addition to the specific purposes for which we may process your personal data set out in this Section 3, 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.
3.10 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose specify personal data category or categories to our suppliers or subcontractors insofar as reasonably necessary for specify purposes.
4.4 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure 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. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
5.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.2 The hosting facilities for our website are situated in Canada. The European Commission has made an “adequacy decision” with respect to the data protection laws of this country. Transfers to this country will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
6. Retaining and deleting personal data
6.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
6.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
6.3 In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on our reasonable requirements:
6.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention 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.
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
8. Your rights
8.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
9. About cookies
9.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
9.2 Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
9.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
11. Cookies used by our service providers
12. Managing cookies
12.1 You can manage your cookie preferences using the Cookie Control function which is presented to you when you first visit the website and can be accessed on subsequent visits.
12.2 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.3 Blocking all cookies will have a negative impact upon the usability of many websites.
12.4 If you block cookies, you will not be able to use all the features on our website.
13. Our details
13.1 This website is owned and operated by Robert Green Marketing.
13.2 Our principal place of business is at Halwell Barn, Dittisham, Dartmouth, Devon, TQ60JF.
13.3 You can contact us:
(a) by post, to the postal address given above;
(b) by telephone – 01803 722446; or
(d) by email, using the email address published below.
14. Data protection officer
14.1 Our data protection officer’s name is Robert Green and he can be contacted at email@example.com.
More About Affiliate Marketing
This website is designed to make it easier for you to find holiday cottages, houses and apartments in Brixham and the surrounding area.
This site features a number of holiday cottages, houses and apartments from a range of holiday cottage letting agencies.
Many of these agencies use affiliate marketing to drive consumers to their websites.
What is Affiliate Marketing?
Advertisers and retailers (merchants) use affiliate marketing to drive consumers to their website as part of their sales activities.
Many of these merchants and advertisers are small businesses using affiliate “networks” to manage their online sales channels. Affiliates and publishers are essentially their “online sales forces” and they use a variety of ways to encourage consumers to a website to make a sale via links generated by a network on behalf of a merchant or advertiser.
For further information on affiliate marketing see www.iabuk.net/disciplines/affiliate-marketing.
Why Are You Telling Me This?
We are telling you this as we want to be as transparent with you as possible.
If you click through to one of the holiday letting agencies or other advertisers from this site and subsequently book a holiday property or purchase some other goods or service, a commission may be paid to the owners of this site by the retailer/merchant.
You will not pay any extra for the goods or service you receive compared to visiting the retailer’s website directly. In some cases you may even pay less or be offered special promotions.
A cookie is set when a user clicks on an affiliate link and is redirected to the advertiser’s website. The purpose of the cookie is to store information related to the click.
What type of cookies do you use?
Many Affiliate networks use first party tags for tracking the activity of their affiliates and rewarding them on behalf of our advertisers. Their first party tags are used solely to identify when a user has clicked on one of our affiliate’s links.
How are the cookies used?
A cookie is set when a user clicks on an affiliate link and is redirected to the advertiser’s website. The purpose of the cookie is to store information related to the click.
Why is this necessary?
The cookie is necessary because the information it stores, such as click through time, affiliate identifier, IP address will be combined with information captured at the point of sale to ascertain whether a valid transaction has been driven by an affiliate.
What data file is stored on a user’s terminal?
A standard text cookie is set on the user’s machine. It will remain in place for a pre-defined period of time, which is determined by the advertiser.
How do affiliate networks inform the user that cookies will be placed on their terminal?
Who generates the cookie?
The cookie is generated by the retailer or affiliate network, however it will be read as a first party cookie.
Does the cookie enable you to create a profile of an individual’s browsing activity?
Is the cookie used to target online ads?
Does the cookie save information about a user’s previous activity on the site?
How long is information stored for?
Transaction data is stored by affiliate networks and/or retailers indefinitely in order to address any possible historical issues as well as maintain an audit trail. Information stored on a consumer’s machine is according to the set cookie period for that particular programme (e.g. industry standard being 30 days)
How would you describe the intrusiveness of the cookie?
Low (It is generally accepted within the industry that affiliate tracking is low-risk in terms of intrusiveness as it does not capture data about a user’s browsing behaviour).
Is any information collected passed to a third party?
The owners of this site do not collect or deal with any customer information. Retailers & affiliate networks undertake not to pass information to third parties.
This website features affiliate links which means that we may get a commission if you decide to book accommodation with the agencies featured. This commission allows us to keep this website running. You will not pay more when booking accommodation through one of these links. Find out more about affiliate links here.