GDPR: DATA PRIVACY NOTICE FOR CLIENTS AND SUPPLIERS
Introduction
PASSEPARTOUT HOMES LTD. (“We”) are committed to protecting and respecting your privacy.
This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
The rules on processing of personal data are set out in the General Data Protection Regulation (the “GDPR”).
1. Definitions
Data controller – A controller determines the purposes and means of processing personal data.
Data processor – A processor is responsible for processing personal data on behalf of a controller.
Data subject – Natural person
Website – www.passepartout-homes.com or www.passepartout-homes.com/blog
Categories of data: Personal data and special categories of personal data
Personal data – The GDPR applies to ‘personal data’ meaning any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier (as explained in Article 6 of GDPR). For example name, passport number, home address or private email address. Online identifiers include IP addresses and cookies.
Special categories personal data – The GDPR refers to sensitive personal data as ‘special categories of personal data’ (as explained in Article 9 of GDPR). The special categories specifically include genetic data, and biometric data where processed to uniquely identify an individual. Other examples include racial and ethnic origin, sexual orientation, health data, trade union membership, political opinions, religious or philosophical beliefs.
Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Third party – means a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
2. Who are we?
PASSEPARTOUT HOMES LTD is the data controller. This means we decide how your personal data is processed and for what purposes. Our contact details are: 161 BERKELEY TOWER, 48 WESTFERRY CIRCUS, LONDON E14 8RP. For all data matters contact PAOLA FIOCCHI, DIRECTOR on INFO@PASSEPARTOUT-HOMES.COM
3. The purpose(s) of processing your personal data
We use your personal data for the following purposes:
(a) We will use your name, address, credit card details and copy of your passport/ID card to complete your booking with us and make travel arrangements.
(b) For the purpose of completing your booking, we may have to disclose some of your information to the providers of the services making up your arrangements (who could be located outside the UK/EEA). We may also have to disclose some information to third parties in relation to customer services, credit card processing, or other services.
(c)We may from time to time contact you with information about special offers, benefits to our clients, brochures, new products, news about us, forthcoming events or competitions. At any time, you may request to discontinue receiving marketing correspondence by email, mail or phone by Passepartout Homes.
We have taken all reasonable steps to have appropriate security measures in place to protect your information. Outside the European Economic Area, controls on data protection may not be as wide as the legal requirements in this country. The transmission of information via the internet is never completely secure. We exclude our liability for personal data lost in transmission to the website.
4. The categories of personal data concerned
With reference to the categories of personal data described in the definitions section, we process the following categories of your data:
We may also collect all or some of the following information relating to you or other members of your party:
– Special requirements such as those relating to any disability or medical condition and age of any children traveling with you, which may affect the chosen arrangements;
– Dietary requirements or restrictions (which may disclose your religious beliefs or any medical condition);
– Information necessary to facilitate travel and other services requested by you or members of your party.
You are responsible for ensuring that other members of your party are aware of the content of this Policy and consent to your acting on their behalf in all your dealings with us.
Some of the information we collect (such as about health or religion) may be considered “sensitive personal data” under the Data Protection Act 1998. We collect it to cater to your needs or act in your interest, and we are only prepared to accept sensitive personal data from you on the condition that we have your positive consent. We will seek this consent when necessary.
5. What is our legal basis for processing your personal data?
Personal data (article 6 of GDPR)
Our lawful basis for processing your general personal data:
☐ Consent of the data subject;
X Processing necessary for the performance of a contract with the data subject or to take steps to enter into a contract
☐ Processing necessary for compliance with a legal obligation
☐ Processing necessary to protect the vital interests of a data subject or another person
☐ Processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller
☐ Processing necessary for the purposes of the legitimate interests of the data controller or a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of the data subject
6. Sharing your personal data
Your personal data will be treated as strictly confidential, and will be shared only in the following circumstances:
(a) For the purpose of completing your booking, we may have to disclose some of your information to the providers of the services making up your arrangements (who could be located outside the UK/EEA). We may also have to disclose some information to third parties in relation to customer services, credit card processing, or other services.
(b) We may need to disclose your information where required by law, where such a request is made by a legal authority.
(c) We may need to disclose our customer list including any personal information relating to you to a third party who acquires or attempts to acquire all or substantially all of the asset/ stock in our company or our website.
(d) We may also disclose information to organisations who act as “data processors” on our behalf, or to other organisations that perform business functions on our behalf, some of whom are outside the UK/EEA. These functions include administration, providing services (and contacting you where necessary), customer care, business management and operation, re-organisation/structuring/sale of our business (or our group companies), risk assessment, security and crime prevention/detection, research and analysis, marketing, monitoring, measuring and assessing customer purchasing preferences and trends, dispute resolution, credit checking and debt collection.
7. How long do we keep your personal data?
We keep your personal data for no longer than reasonably necessary and we only retain your data for the following purposes:
(a) Marketing purposes such as sending you regular news, special offers, news about Passepartout Homes, surveys, competitions. You have the right to remove yourself from our database at any time.
8. Providing us with your personal data
You are under no statutory or contractual requirement or obligation to provide us with your personal data. But failure to do so will have the following consequences
(a) we may not be able to complete your booking or providing you with the services you may have requested in conjunction with your booking.
9. Your rights and your personal data
Unless subject to an exemption under the GDPR, you have the following rights with respect to your personal data:
10. Transfer of data abroad
For the purpose of completing your booking, we may have to disclose some of your information to the providers of the services making up your arrangements (who could be located outside the UK/EEA). We may also have to disclose some information to third parties in relation to customer services, credit card processing, or other services.
11. Further processing
If we wish to use your personal data for a new purpose, not covered by this Data Privacy Notice, then we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions.
12. External Links
Please note that our website contains certain literature and hyperlinks to websites owned by third parties. This privacy statement covers websites owned and controlled by us only. Links to other websites and any information collected by these sites are not covered by this privacy statement.
13. Security
We will make reasonable efforts to ensure that information provided by the User will be maintained in a secure environment. Unfortunately, no data transmission via the Internet can be guaranteed as being 100% secure. Consequently, while Pwe strives to protect your personal information, we cannot guarantee the security of any information transmitted to Passepartout Homes Ltd. or from the Website, and the User provides such information at its own risk.
The Website is hosted by a third party service provider which is neither controlled by nor affiliated with Passepartout Homes Ltd. We can make no representation or warranty as to the security measures of any third party, including, but not limited to, the host of the Website. We expressly excludes any and all liability arising out of or in connection with acts or omissions by any third party including, but not limited to, the host of the Website. Passepartout Homes Ltd recommends that you review the privacy policy of any third party prior to using any third party’s website.
14. Cookies
Non-personal information may also be collected with the use of cookies. “Cookies” are small text files a website can use to recognise repeat users. When someone visits the Website, a cookie is placed on the visitor’s machine (provided that the visitor’s web browser has been set to accept cookies) or is read if the visitor has visited the Website previously. We may collect aggregated Website-visitation statistics using cookies. For example, every time you log in to the Website, we may record your member ID and the name of your member account in the cookie file on your computer. Your password may also be recorded in this cookie file if you selected the “Save this password for automatic log-in” feature or similar options. If the User does not wish to accept cookies it should set its web browser to reject cookies or to warn the User prior to accepting cookies.
The third-party advertising providers may also use cookies or technologies to, for example, measure the effectiveness of their ads or provide advertisements about goods and services that may be of interest to you. Although no personally identifiable information about you is collected during this process, we have no access to or control over such cookies or technologies.
Since 26 May 2012, all websites registered in the United Kingdom are under an obligation to obtain your consent to download cookies onto your computer for any reason other than where it is strictly necessary to download cookies onto your computer, e.g. where a cookie is required to remember the holiday arrangements you have chosen in order to allow you to proceed to the checkout and purchase the arrangements. Therefore from this date, we request your consent to download cookies onto your computer for services where it is not strictly necessary to do so. You can choose to opt out and prevent us from downloading cookies from your system, however this will affect your user experience of our website and we may not be able to offer you all the services on our website as a result. Therefore, in order to provide you with the best experience of our website and offer you all of our services, we would recommend opting in and allowing us to download cookies on to your computer. If you would like to opt out please email us – INFO@passepartout-homes.com
To find out more information about cookies, please visit www.allaboutcookies.org.
15. Links to Third Party Website
Links to third party websites (not maintained by Passepartout Homes Ltd) which appear on this Website are provided solely as a convenience to our customers and visitors. If you use these links, you will leave this Website. Passepartout Homes Ltd. does not have control over and is not responsible for any of these websites or their content. Passepartout Homes Ltd. does not endorse or make any representations or warranties about such websites, or any information, opinions, software or other products or materials which may be found thereon, nor does Passepartout Homes Ltd make any representations or warranties about any results that may be obtained from using them. If you decide to access any of the third party websites linked to this Website, you agree that you do this entirely at you own risk. It is your responsibility to ensure that any links you select or program/software/data/material you download (whether from this Website or other websites) is free of viruses, Trojan horses, worms, defects and similar potentially harmful items. You should be aware that linked third party websites may contain rules and regulations, privacy provisions, confidentiality provisions, transmission of personal data provisions, and other provisions that differ from the provisions provided on this Website. Passepartout Homes Ltd. is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.
16. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy
17. How to make a complaint
To exercise all relevant rights, queries or complaints please in the first instance contact Passepartout Homes Ltd, The Director, 161 BERKELEY TOWER, 48 WESTFERRY CIRCUS, LONDON E14 8RP, UNITED KINGDOM
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England.
©Copyright Passepartout Homes Ltd. 2021.
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