SAY TRAVEL’S DATA AND PRIVACY POLICY

INTRODUCTION 

1. Welcome to the SAY TRAVEL privacy policy. To keep things simple, we refer to ourselves as SAY TRAVEL and this  document as the Policy. SAY TRAVEL respects your privacy and is committed to protecting your Personal Data.  This Policy tells you: how we look after your Personal Data when you visit our website, regardless of where you live; about your privacy rights; and how the law protects you.

2. There is a lot of technical language about data processing so words in bold (except headings) are defined in this  policy. 

3. WHAT THIS POLICY DOES: SAY TRAVEL collects and processes information that relates to You or which can be  used to identify You (known as “Personal Data”) when you use our website, including any data you may provide  through the website when you sign up to our newsletter, purchase a product, create a wish list, send an image of  a product to an email or take part in a competition. We want you to be fully aware how and why we use your  Data. 

4. SAY TRAVEL is the Data Controller and responsible for your Personal Data. 

5. Sometimes we may ask for extra data and when we do, we will let you know why we need it. We keep this policy  under review, and you can request copies of older policies [email protected]

6. This website is not intended for children, and we do not knowingly collect Data relating to children. 

7. If you have any questions about this privacy policy, including any requests to exercise your legal rights please  contact our data privacy manager who is responsible for overseeing questions in relation to this privacy policy here <<[email protected]>>. 

8. You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would appreciate the chance to deal with  your concerns before you approach the ICO, so please contact us first and we will try to help. 

9. DATA WE COLLECT ABOUT You: SAY TRAVEL collects, uses, stores and transfers different kinds of Personal Data about you including: 

  • Identity Data such as your name, title, date of birth and gender. 
  • Contact Data such as your billing address, delivery address, email address and telephone numbers. 
  • Financial Data in some circumstances (such as where payment for refundable or cancellable Booking is made) we will keep your bank account and payment card details in case a refund becomes due. This information will  be deleted once You have completed Your stay in the Accommodation You booked. Transaction Data including details about payments to and from you and other details of products and  services you have purchased from us. 
  • Technical Data (including internet protocol (IP) address, your login data, browser type and version, time zone  setting and location and other technology on the devices you use to access the SAY TRAVEL website.
  • Profile Data including your username and password, purchases or orders made by you, your preferences and  any feedback and survey responses.  
  • Usage Data including information about how you use our website, products, and services.  
  • Marketing and Communications Data including your preferences in receiving marketing from us, third parties  and your communication preferences.

10. Personal Data does not include data where the identity has been removed (anonymous data). 

11. We do collect, use and share statistical or demographic data could be derived from your personal data but is not  considered personal data in law as this data will not directly or indirectly reveal your identity, which we call Aggregated Data. We do this to improve our service overall, but this is not considered Personal Data in law. If we  combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we  will treat the combined data as Personal Data and this Policy will apply to it. 

12. We do not collect any Special Categories of Personal Data about you (this includes details about your race or  ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership or information about your health.  

13. Please keep us informed if your Personal Data changes because it is important that the Personal Data we hold  about you is accurate and up to date. 

14. If you fail to provide Personal Data where we need to it by law, or under the terms of a contract we have with  you, we may not be able to perform that contract. In this case, we may cancel an order and notify you of this.

15. HOW IS YOUR PERSONAL DATA COLLECTED? We use different methods to collect Person Data from and about  you by using forms sent by email, post or phone and when you or get in touch with us, become a host, subscribe  to our newsletters or social media, complete a survey or enter a competition. 

16. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing  actions and patterns using cookies and other similar technologies and we may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy for more details. 

17. Sometimes we may receive Personal Data about you from third parties such as Google or other search engines and Contact, Financial and Transaction Data from providers of payment and delivery services. 

18. HOW WE USE YOUR PERSONAL DATA? We will only use your Personal Data as English law allows us to. We may use your Personal Data to complete our contract with you and make sure you get your order; where it is  necessary for our legitimate interests (or those of a third party); or where we need to comply with a legal  obligation. Generally, we do not rely on consent as a legal basis for processing your Personal Data, which is known  as the Lawful Basis for processing. 

19. WHEN WE WILL USE YOUR PERSONAL DATA: We may process your Personal Data on more than one lawful  ground depending why we are using it. The table below shows some ways we might process your Personal Data:

    legitimate interest Registering you as a Guest or as  a host

o Identity  

o Contact Performing our contract with you

Processing your  request/delivering our services: 

(a) Managing payments, fees, and charges 

(b) Collecting and recovering money owed to us

 

o Identity  

 

o Financial 

o Contact  

o Profile  

o Usage  

o Marketing & 

Communications

Performing our contract with you 

Necessary for our legitimate interests (to  recover debts due to us

 

Managing our relationship with  You including 

(a) Notifying you about changes  to our terms or privacy policy 

(b) Asking you to leave a review  or take a survey

 

o Identity  

o Contact  

o Profile  

o Marketing & 

Communications

Performing our contract with you 

Necessary to comply with a legal  

obligation 

Necessary for our legitimate interests (to  keep our records updated and to study  how customers use our  

products/services)

To enable you to partake in a  competition or complete a  survey

o Identity  

o Contact  

o Profile  

o Usage  

o Marketing & 

Communications

 

Performing our contract with you 

Necessary to comply with a legal  

obligation 

Necessary for our legitimate interests (to  keep our records updated and to study  how customers use our  

products/services)

To enable you to partake in a  competition or complete a  survey

o Identity  

o Contact  

o Profile  

o Usage  

o Marketing & 

Communications

 

Performing our contract with you. Necessary for our legitimate interests; to  study how customers use our products &  services to develop them and grow our  business

 

To administer and protect our  business and this website  (including troubleshooting, data  analysis, testing, system  maintenance, support, reporting  and hosting of data)

o Identity 

o Contact 

 

o Technical

Necessary for our legitimate interests in running our business; administration, IT,  network security, fraud prevention,  business structure 

Comply with a legal obligation

To deliver relevant website  content & advertisements to you  and measure or understand the  effectiveness of the advertising  we serve to you

o Identity 

o Contact  

o Profile  

o Usage  

o Marketing & Communications 

o Technical

Necessary for our legitimate interests; to  study how customers use our  

products/services, to develop them, to  grow our business and to inform our marketing strategy

To use data analytics to improve  our website, products/services,  marketing, customer  relationships and experiences

o Technical  

o Usage 

Necessary for our legitimate interests; to  define types of customers for our  

products and services, to keep our  website updated and relevant, to

    develop our business and to inform our  marketing strategy To make suggestions and  recommendations to you about  locations, accommodation or our  services that may be of interest  to you

o Identity  

o Contact  

o Technical 

o Usage  

o Profile  

o Marketing & Communications

Necessary for our legitimate interests; to  develop our products/services and grow  our business

 

20. MARKETING: We strive to provide you with choices regarding Personal Data uses, particularly around marketing and advertising. You can update your preferences <<here>>. You can withdraw consent to marketing at any time [email protected] 

21. PROMOTIONAL OFFERS FROM US: We may use your Identity, Contact, Technical, Usage and Profile Data to form  a view on what we think you may want or need, or what may be of interest to you. This is how we decide which  products, services and offers may be relevant for you (we call this marketing). You will receive marketing  communications from us if you have requested information from us or purchased goods from us and you have not  opted out of receiving that marketing. 

22. THIRD-PARTY LINKS: This website includes links to third-party websites, plug-ins, and applications. Clicking on  those links or enabling those connections may allow third parties to collect or share data about you. We do not  control these third-party websites and are not responsible for their privacy statements. When you leave our  website, we encourage you to read the privacy policy of every website you visit. 

23. THIRD-PARTY MARKETING: We will get your express consent before we share your Personal Data with any third  party for marketing purposes.  

24. OPTING OUT: You can ask us or third parties to stop sending you marketing messages at any time by following the  opt-out links on any marketing message sent to you. 

25. Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a  result of a product purchase, warranty registration or other transactions. 

26. COOKIES: Cookies that are responsible for functionality of our website and most are accepted automatically. We  need your permission to accept third-party cookies and cookies for marketing purpose, if you do not accept these  cookies, you still can navigate on the website. You can set your browser to refuse all or some browser cookies, or  to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of  this website may not function properly. For information about the cookies we use, click cookie policy.

27. CHANGE OF PURPOSE: We will only use your Personal Data for the purposes we collected it for, unless we  reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. You can ask us for more details about this by contacting us [email protected]

 

28. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain how we  want to use it. Please note that we may process your Personal Data without your knowledge or consent, in  compliance with the above rules, where this is required or permitted by law.

29. DISCLOSURES OF YOUR PERSONAL DATA: We may share your Personal Data with the parties shown and for the  purposes listed in the table above.  

30. We require all third parties to respect the security of your Personal Data and to treat it in accordance with the  law. We do not allow our third-party service providers to use your Personal Data for their own purposes and  only permit them to process your Personal Data for specified purposes and in accordance with our instructions.

 

31. INTERNATIONAL TRANSFERS: We share your Personal Data with Hosts and with our payment providers so that  Your Booking and/or Booking Fees can be fulfilled and processed. This is a lawful basis and this may involve  transferring your data overseas. By creating a Listing and/or placing a Booking You accept that Your Data can be  transferred to facilitate Your Booking, receive, or pay the Booking Fee and/or pay You the Booking Fees You are  due (if You are a Host). We will only provide the minimum amount of data necessary to fulfil your contract with a  Host or with Us. 

32. DATA SECURITY: We have put in place appropriate security measures to prevent your Personal Data from being  accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to  your Personal Data to those employees, agents, contractors and other third parties who have a business need to  know. They will only process your Personal Data on our instructions, and they are subject to a duty of  confidentiality.  

33. We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any  applicable regulator of a breach where we are legally required to do so. 

34. HOW LONG WILL WE USE YOUR PERSONAL DATA FOR? We will only retain your Personal Data for as long as  reasonably necessary to fulfil the purpose we collected it for, including for the purposes of satisfying any legal,  regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in  the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship  with you.

 

35. When we decide how long to keep your data for, we consider the amount, nature and sensitivity of the data, the  potential risk of harm from unauthorised use or disclosure of it, the purposes for which we process it and whether  we can achieve those through other means, as well as the applicable legal, regulatory, tax, accounting or other  requirements. 

36. In some circumstances we might anonymise your Personal Data (so that it can no longer be associated with you)  for research or statistical purposes, in which case we may use this anonymous information indefinitely.  

37. IT’S YOUR DATA, YOU HAVE THE RIGHT TO: 

Request access to your Personal Data (commonly known as a "data subject access request"). This enables you to  receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it. 

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or  inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

 

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where  there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your  Personal Data where you have successfully exercised your right to object to processing (see below), where we  may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific  legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third  party) and there is something about your particular situation which makes you want to object to processing on  this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object  where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate  that we have compelling legitimate grounds to process your information which override your rights and  freedoms. 

Request restriction of processing of your Personal Data or ask us to suspend our processing of your Personal  Data because:  

(a) you want us to establish the data's accuracy. 

(b) our use of the data is unlawful, but you do not want us to erase it. 

(c) you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend  legal claims.  

(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate  grounds to use it.  

Request transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you  have chosen, your Personal Data in a structured, commonly used, machine-readable format. This right only  applies to automated information which you initially provided consent for us to use or where we used the  information to perform a contract with you.  

Withdraw your consent to us processing your data at any time. This will not affect the lawfulness of any  processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to  provide certain products or services to you. We will advise you if this is the case at the time you withdraw your  consent. If you withdraw your consent, we must keep a record of that request. 

 

You will not have to pay a fee to access your Personal Data or to exercise the rights above. We may charge a  reasonable fee if your request is clearly unfounded, repetitive, or excessive and we can refuse to comply in these  circumstances. 

38. If you want to request, object or withdraw your consent to our processing p[email protected]

39. When you may a request, we may need to request specific information from you to help us confirm your identity  and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security  measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also  contact you to ask you for further information in relation to your request to speed up our response. 

 

40. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month  if your request is particularly complex or you have made several requests. In this case, we will notify you and keep  you updated. 

41. TERMS WE USE IN THIS POLICY:

Data Controller means the party who determines the purpose of processing Personal Data and how it is  undertaken. 

Data Processor means the party responsible for processing Personal Data on behalf of a controller. 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to  give you the best service/product and the best and most secure experience. We make sure we consider and  balance any potential impact on you (both positive and negative) and your rights before we process your Personal  Data for our legitimate interests. We do not use your Personal Data for activities where our interests are  overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).  You can obtain further information about how we assess our legitimate interests against any potential impact on  you in respect of specific activities by contacting us. 

Performance of Contract means processing your data where it is necessary for the performance of a contract to  which you are a party or to take steps at your request before entering into such a contract. 

 

Comply with a legal obligation means processing your Personal Data where it is necessary for the purposes of  fulfilling a legal obligation that we are subject to. 

42. THIRD PARTIES WE MAY SHARE DATA WITH: We may share Personal Data with 

End users and Customers of Say Travel’s services. 

Internal Third Parties who are other companies who are partners of SAY TRAVEL or who sub-contract with Us and who are based in Europe, the US and Asia and provide IT and system administration services and undertake reporting to SAY TRAVEL. 

External Third Parties such as Service and payment providers who will process Your payments and who are acting  as processors. 

Our Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and  insurers based in the UK. 

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the  United Kingdom who require reporting of processing activities in certain circumstances. 

Fraud prevention agencies who may be asked to undertake identity verification in certain circumstances. 

Logistics agencies who will provide delivery of goods to you, so that they can locate you and identify you. 

ANY OTHER THIRD PARTIES, for example, market researchers, fraud prevention agencies, price comparison sites  and so on.

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