escape-to-stives

ETSI PRIVACY POLICY

ESCAPE TO ST.IVES, with an office at: Unit 2A, Wheal Virgin House, Consols, St Ives, Cornwall TR26 2HW, herein referred to as ‘ETSI’ or ‘We’, have created this privacy statement (‘Statement’) in order to demonstrate our firm commitment to the privacy of the details that You provide to us when using this web site. In this Statement, references to ‘You’ and ‘Your’ are references to the user i.e. the person (or company) visiting www.escapetostives.co.uk (the ‘Site’). When You use the Site, You are consenting to the practices set forth in this Statement. It applies to information We collect about Users of our Site and amongst other things, this Statement describes what personally identifiable information ‘Personal Data’ We collect from You, how and when it is used, how We protect it and who has access to it. These Terms incorporates our Guest Booking Terms and Conditions, the Website Terms of Use and theETSI Cookie Policy by this reference. 

1. YOUR ACCEPTANCE OF THE STATEMENT

This Statement governs Your use of the Site and the Services, including any dispute concerning privacy. By using the Site and/ or the Services, you accept this Statement in full. You should read the Statement carefully and ensure that you understand its effect before proceeding to use the Site and/ or the Services. We reserve the right to modify this Statement at any time by posting the changes on this page. Your continued use of any portion of the Site following the posting of the updated Statement will constitute your acceptance of the changes.

2. WHAT INFORMATION IS COLLECTED AND, HOW IS THE INFORMATION USED?

PERSONAL DATA

The Site asks you to provide various types of Personal Data to enhance the quality of the Services We can provide to You and the more accurate the information You provide, the better We are able to customise Your request. As part of the process of using the Site and/ or the Services, ETSI need to collect details such as the names and addresses and or email addresses of the Homeowners or Guests or potential Homeowners or Guests. This Personal Data may need to be passed on to third party companies or service providers for the sole purpose of fulfilling the Services only and not for the purposes of making marketing communications, unless You have expressly consented to this being undertaken by a third party.

 

You acknowledge that Your Personal Data may be used by ETSI to contact You by post, phone or by Electronic Mail when necessary in connection with transactions entered into by You on the Site. From time to time, ETSI may contact You by post or by Electronic Mail, with information or offers regarding upcoming property rentals, promotions, services or customer surveys. If You do not wish to be contacted by ETSI in respect of future marketing communications such as these, please contact ETSI by emailing [insert email] or send Your request by post to ETSI at the contact address below.

Your Personal Data is used solely by ETSI for the sole purposes of enabling ETSI to carry out the Services and is not shared with any person or company including the Homeowner (if you are the Guest) or the Guest (if you are the Homeowner) without the express consent of the other in writing. Any Personal Data that is held with ETSI shall be retained in accordance with the Data Protection Act 1998 and related legislation and/ or our retention schedule culminating in its permanent deletion.

Other de-personalised information which does not record Personal Data as such, rather information such as the date of the visit to the Site, the path taken, the browser used, the IP address etc is used primarily to aid the technical administration of the Site, to better understand how the Site is functioning for Users and to draw conclusions upon demographic information.

FINANCIAL INFORMATION

In order to fully utilise and avail of the Services, We may require You to provide us with Financial Information like Your account or credit card numbers in order to authorise payment and bill You for the Services. When You make a Booking on the Site, your consent is given to provide your Financial or Personal Data to those third parties necessary to process Your transactions with us, such as credit card companies and banks. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction. To make and complete the purchase with Sage Pay, the policies of Sage Pay shall be applicable. To make and complete payment with Sage Pay via our Site, the policies of Sage Pay shall be applicable as between You and Sage Pay and can be found here. Except as provided above, we will not share Financial Information with third parties without Your prior consent.

 

3. WHO HAS ACCESS TO THE INFORMATION?

Disclosure of Your Personal Data and Financial Information in Compliance with Laws

You should be aware that We may release Your Personal Data or Financial Information when We believe it is necessary to comply with laws or regulations, to assist law enforcement, to enforce the terms under which You transacted with ETSI, or to protect the rights, property or safety of ETSI, Users of the Site or others. Your bank or Sage Pay may further release Your Personal Data as per their policies.

Transfer of Your Personal Data and Financial Information Outside Of the EEA

From time to time, We may transfer Your Personal Data and/or Financial Information to a related company, agent or contractor in order to improve our Services or to assist our security, credit risk or fraud protection activities. Such companies may be located outside of the EEA and You consent to the transfer of Your Personal Data and Financial Information to such companies for the purposes set out in this paragraph, in accordance with this Statement and as permitted by the Data Protection Act 1998 and related legislation from time to time. Further, Your bank or Sage Pay may further release Your Personal Data as per their policies.

Transfer of Personal Data in Event of Sale of Escape To St.Ives or Its Assets

In the event that ETSI is sold, or transfers some of its assets to another party, your Personal Data could be one of the transferred assets. If your Personal Data is transferred, its use will remain subject to this Statement. Your Personal Data will be passed on to a successor in interest in the event of a liquidation or administration of ETSI.

Other Sites/Third Party Vendors and their Privacy Policies

This Site may contain links to other web sites. ETSI is not responsible for the privacy practices or the content of such web sites or for the privacy policies and practices of other third parties (including those of Sage Pay), and so You should be careful to read and understand those web sites’ privacy policies independently.

4. HOW DO WE PROTECT YOUR INFORMATION?

The privacy and protection of Your Personal Data is important to us. In addition, any User statistics that We may provide to prospective partners regarding Your usage are provided in the aggregate only and do not include any individually identifiable information. You acknowledge that email messages sent over the internet are not encrypted and are not secure.  Despite efforts to protect Your Personal Data, We cannot ensure or warrant the security of any information You transmit to us, or to or from our online Services. You accept that ETSI cannot be held liable for any breaches of confidentiality that may occur as a result of the use of email. If there is any sensitive or confidential information which You do not wish to communicate by email, please contact ETSI by telephone or post to arrange an alternative method of communication. You transmit all such information at Your own risk. However, once we receive your transmission, We use our best efforts to ensure its security on our systems.

Once Your payment instructions are received by Sage Pay where applicable, Sage Pay have security measures in place to protect the loss, misuse and alteration of the Personal Data under their control. 128 bit industry standard Secure Server Software (SSL) is used as a minimum standard which encrypts all of Your Personal Data in respect of a transaction, including credit card number, name, and address, so that it cannot be read as the Personal Data travels over the Internet

5. COOKIES

For information about cookies and how they are used on this Site, please visit our ETSI Cookie Policy.

6. COMPLAINTS OR QUERIES
ETSI tries to meet the highest standards when collecting and using Personal Data. For this reason, We take any complaints We receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures. This Statement does not provide exhaustive detail of all aspects of ETSI’s collection and use of Personal Data. However, We are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below. If You have a complaint or query regarding a Sage Pay transaction, You can contact Sage Pay.

7. ACCESS TO PERSONAL DATA
ETSI tries to be as open as it can be in terms of giving people access to their Personal Data. Individuals can find out if we hold any Personal Data by making a ‘subject access request’ under the Data Protection Act 1998. If We do hold information about You We will let You have a copy of that information. To make a request to ETSI for any Personal Data that We may hold, You need to put the request in writing addressing it to the address provided below.

8. HOW TO CONTACT US
Requests for information about our Statement or a ‘subject access request’ can be emailed to info@scapetostives.co.uk or by writing to:

Internal Compliance Department
Escape To St.Ives

Unit 2A, Wheal Virgin House, Consols, St Ives, Cornwall, TR26 2HW

  1. DEFINITIONS

       In these Terms (except where the context otherwise requires) the following words shall have the following meanings:

Data Protection Legislation: the Data Protection Act 1998, the Data Protection Directive (95/46/EC), the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive (2002/58/EC), the Privacy and Electronic Communications (EC Directive) Regulations 2003 (SI 2426/2003) and all applicable laws and regulations relating to the processing of Personal Data and privacy, including where applicable the guidance and codes of practice issued by the Information Commissioner.
Electronic Mail: includes email, text, video, voicemail, picture and answerphone messages as per the Privacy and Electronic Communications (EC Directive) Regulations 2003.
Personal Data: as defined in the Data Protection Act 1998.

  1. CHANGES TO THIS STATEMENT

We keep our Statement under regular review. This Statement was last updated on 03 November 2014.

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