This privacy policy is to tell you what personal data we collect from you and why and what we will do with this data. It also tells you about some of the key rights which you have under data protection laws. You and your personal data are protected by the EU General Data Protection Regulation (which is otherwise known as GDPR) and the UK Data Protection Act 2018. In this privacy policy, we refer to this legislation as data protection laws.
We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are otherwise permitted to do in accordance with data protection laws.
When we refer to “you” in this privacy policy, we mean every person who communicates with us in respect of a booking, booking request, enquiry or for any other reason and all persons for whom a booking or booking request is made.
For the purposes of data protection laws, we, Hammerton Caribbean Limited, are a data controller in respect of the personal data you provide us with.
When we refer to personal data, we mean any information which relates to an identified or identifiable individual.
Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties and erasing it.
In order to respond to an enquiry, administer and fulfil your booking or send you a brochure or other promotional material, we need to process personal data we obtain from you. This personal data may be obtained from you directly or through any travel agency with whom you make your booking or booking enquiry.
Where you wish to make a booking, the personal data we need to collect and process is likely to include the following (depending on the services which are requested);
For an enquiry, the personal data we will need to process is likely to include the name and contact details (e-mail address and telephone number(s)) of the person making the enquiry.
For a booking or booking enquiry, we will process your personal data (other than any data which comes within special categories of personal data - see below) on the basis that this is necessary for the performance of your contract with us or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency situation).
If you would like to receive promotional material from us, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address.
Personal data which concerns your health or which reveals your racial or ethnic origin, religious beliefs or sexual orientation are special categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the booking and provision of travel arrangements.
Generally speaking, the processing of special categories of personal data requires your explicit consent.
Accordingly, information concerning any disability, medical condition or restricted mobility which may affect your travel arrangements (and related requirements) as well as dietary restrictions which may disclose your religious beliefs are special categories of personal data. We will ask for your consent to our processing this information at the time you make your booking or your booking enquiry.
Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen arrangements together with any other third party who needs this information so that we can arrange for your holiday to be provided.
Suppliers and other third parties are likely to include the following depending on the arrangements booked;-
Credit card details may be provided to villa management companies for the purpose of providing a security deposit, to pay for certain additional facilities for which a charge is applicable (such as cots and rollaway beds) and to enable groceries to be purchased in advance of your arrival where requested.
Personal data may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.
We may also provide personal data to any marketing companies we use such as those who carry out e-mail marketing on our behalf or who request holiday reviews from you.
We only provide third parties with the personal data they require in order to deliver their requested services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.
Your personal data will be processed within the UK and those countries in the Caribbean where our villas and suppliers are located. It may also be processed in any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein.
Data protection laws outside the EEA may not be as strong as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
We will only retain and use your personal data for marketing purposes where you have specifically consented to this or we are permitted to do in accordance with data protection laws (including as set out below).
We may send you e-mail marketing where we comply with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR). PECR permits us to e-mail you information about the holiday services we offer where you have previously provided us with your e-mail address in the course of entering into a contract with us for holiday arrangements or negotiations for such arrangements and we wish to e-mail you marketing material about our similar services or products. You will of course be given the opportunity to opt out of receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send you any e-mail marketing.
Where you have previously requested or agreed to receive information about our holiday services from us by post, we may continue to send you such information in the same way until you ask us not to (which you can do by telephone, e-mail or post). Everything we send you will tell what you should do if you no longer wish to hear from us. We will send you this information as this is necessary for the purposes of our legitimate interests in communicating with you unless it is or becomes clear that our interests are overridden by your interests or fundamental rights and freedoms in which case we will cease communicating with you.
You may provide your consent to receiving marketing information from us by opting to receive marketing material either on-line or by telephone. You may also choose in what ways you are happy to receive communications from us. You may, for example, be happy to receive information and offers by post and e-mail but not by telephone.
Yes, you can withdraw your consent to receiving marketing material or other communications from us, either generally or in any particular way, at any time by e-mailing us at lisa@hammertoncaribbean.com. Alternatively you can telephone us.
You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within 1 month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.
If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within 3 months if the rectification request is complex.
We will not process your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.
Where your personal data has been provided for the purpose of the holiday arrangements or other services you have contracted, we are entitled to retain this data for a period of at 6 years after those arrangements have been completed. In certain limited circumstances, we may be able to retain it for a longer period.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
Yes, you can ask us to erase your personal data in certain circumstances, for example where you have withdrawn your consent to further marketing material where the data in question has only been processed for this purpose. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.
Yes, from time to time we may need to make changes to this privacy policy. These may be required as a result of changes in data protection laws or in the guidance issued by regulators such as the Information Commissioner’s Office (which is usually referred to as the ICO) or where we make changes to our procedures. The latest version of this privacy policy can be found on our website at www.hammertonbarbados.com/privacy
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to lisa@hammertoncaribbean.com. We will investigate and respond to you as soon as we reasonably can. If you remain dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see www.ico.org.uk
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