This document refers to personal data, which is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.
The General Data Protection Regulation (GDPR) which is EU wide and far more extensive than its predecessor the Data Protection Act, along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of EU data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU and its storage within the EEA.
1 – SASA Rentals, based at 27 Springfield Road, Ashford, Middlesex, TW15 2LR, which hereafter for the purposes of this Privacy Notice will be referred to as the Owners, is pleased to provide the following information:
2 – Who we are
The Owners rent privately owned properties in Spain and Portugal for the means of Short term and Long term holiday rentals.
3 – Personal Data
a) For the purposes of booking you holiday rental The Owners will require personal data in accordance with Portuguese and Spanish Law. This data will be used solely for the purposes of processing your reservation, organising any requested transfer and will be made available to our management/representative in the related country.
b) For marketing purposes, the Owners may also use the contact details provided by you to respond to your enquiries, including making telephone contact and emailing information to you which the partnership believes may be of interest to you.
c) In making initial contact with the Owners you consent to Owners maintaining a marketing dialogue with you until you either opt out (which you can do at any time) or we decide to desist in promoting our services. The Owners do not broker your data and you can ask to be removed from our marketing database by emailing or phoning the Owners using the contact details provided at the end of this Privacy Notice.
d) Some basic personal data may be collected about you from the marketing forms and surveys you complete, from records of our correspondence and phone calls and details of your visits to our website, including but not limited to, personally identifying information like Internet Protocol (IP) addresses.
f) The Owners will only collect the information needed so that we can provide you with the services you require, the business does not sell or broker your data.
4 – Legal basis for processing any personal data
To meet our contractual obligations obtained from explicit client Consent and legitimate interest to respond to enquiries concerning the services provided.
5 – Legitimate interests pursued by The Owners
To promote interest of clients for property rental of properties owned by the partnership.
6 – Consent
Through agreeing to this privacy notice you are consenting to The Owners processing your personal data for the purposes outlined. You can withdraw consent at any time by using the postal, email address or telephone number provided at the end of this Privacy Notice.
7 – Disclosure
The Owners will keep your personal information safe and secure, only staff engaged in providing your accommodation will have access to your client data. Although our administration team will have access to your contact details so that they can make contact and manage your reservation. The Owners will not disclose your Personal Information unless compelled to, in order to meet legal obligations, regulations or valid governmental requests. The practice may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of its staff.
8 – Retention Policy
The Owners will retain you email and direct contact for at least 3 years unless otherwise advised. Emails will be retained on our mailing list unless a request to remove is given. The client may also unsubscribe at any time via email newsletter.
9 – Data storage
All Data is held in the United Kingdom. The Owners does not store personal data outside the EEA.
10 – Your rights as a data subject
At any point whilst The Owners are in possession of, or processing your personal data, all data subjects have the following rights:
• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that The Owners refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. At your request The Owners can confirm what information it holds about you and how it is processed.
11 – You can request the following information:
• Identity and the contact details of the person or organisation (The Owners) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of The Owners and information about these interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erasure, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
12 – To access what personal data is held, identification will be required
The Owners will accept the following forms of identification (ID) when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If The Owners is dissatisfied with the quality, further information may be sought before personal data can be released.All requests should be made to email@example.com by phoning +44 (0)7799140300 or writing to us at the address further below.
In the event that you wish to make a complaint about how your personal data is being processed by The Owners you have the right to complain to us. If you do not get a response within 30 days, you can complain to the ICO.
The details for each of these contacts are:
Mr Alistair McGee
Telephone 07799 140300 or email: firstname.lastname@example.org
Wycliffe House, Water Lane, Wilmslow, SK9 5AFTelephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/