Last updated May 2018
We are Mulberry Cottages Ltd., a company registered in England and Wales under company number 05309699.
We are a data controller registered with the Information Commissioner, and this document along with our Booking Conditions & General Information will tell you what to expect from us regarding the data we collect from you and how we use it.
This document doesn’t form part of any contract, but please read it carefully before using our services to ensure that you agree with our policies. We may update this statement at any time.
If you have any concerns or questions about your data, you can contact us here:
Data Protection Officer
17 New Dover Road
Why do we collect your personal information?
The information that you provide us allows us to do the following:
- Fulfil your holiday bookings with us.
- Provide you with offers and other relevant marketing information in which you might be interested.
- Monitor the use of our site by users and improve our service.
- Conduct surveys and gather feedback in relation to our service.
What personal information do we collect from the people that visit our website or use our service?
When do we collect information?
We collect information from you in the following ways:
Information provided by you
- When you make a booking or enquiry with us, either over the phone or online via our website.
- When you enter a competition or promotion sponsored by us.
- When you report a problem with our site or with your booking.
- When you contact our support or customer service teams.
- When you complete surveys or feedback forms that we use for research purposes.
Information collected automatically about you
- We collect information about you during your visit and use of our website.
- We may make recordings of your telephone calls with our sales and customer service teams.
- We collect further information generated when you book with us, such as transaction IDs with the third-party payment platform.
What information are we collecting?
We may collect the following information from you:
- Your name, title, date of birth, and gender.
- Your postal address, phone number, and email address.
- Information about your holiday, including house booked, the dates included, the cost, payment history, and limited information about other occupants of the house (names, ages, gender).
- Limited payment information for your booking, including final four digits, payment card expiry date, payment processor reference number. At no point are your full card details captured or entered into our systems.
- Your communications with us, including email correspondence, telephone calls, web-chat logs.
- Information from your cookies, if you have allowed us to collect them.
How do we use your information?
We use the information we collect from you in the following ways:
- To fulfill your booking with us.
- To inform owners and/or housekeepers of how they can contact you, should they need to assist in any way with your stay, or in the case of an emergency.
- For our own records and internal research to help improve our products and services.
Your Use of the Website
- To personalise your experience and allow us to deliver the type of content and product offerings in which you are most interested.
- To allow you to participate in any interactive features of our website should you choose to.
- To allow us to better match our offerings to what our customers want and improve our services to you.
- To carry out internal operations that allow us to diagnose and resolve website issues, and generally maintain safety and security.
Customer Service and Training
- To help us resolve any issues you raise with our customer service team.
- To notify you about changes to our service.
- For monitoring purposes.
- Some of your personal data may also be used to help better train our members of staff.
At the time of purchase or elsewhere on the site, you may choose to sign up to our newsletter and receive regular content from us. We use the information we collect from you when you sign up in the following ways:
- To administer contents, promotions, surveys, or other site features.
- To send you periodic emails regarding our products and services you may be interested in.
You have the right to ask us to stop processing your data for marketing purposes at any time. You can do this by either unsubscribing from the footer of any of our marketing emails, or by contacting us at email@example.com.
How do we protect your information?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible, and we regularly scan for malware and other similar infections.
Any personal data that we store is done so behind secured networks, and is only accessible by a limited number of persons who have special access rights to such systems, and who are required to keep the information confidential.
Any third parties we use are required to take appropriate security measures in-line with our policies, and can only use your data for the purposes we instruct. These third parties have a duty of confidentiality regarding the data we provide them and as such are trusted to never share it with others.
You can choose to disable cookies in your browser settings, however this may hamper your ability to effectively use our site or manage your booking. We can claim no responsibility for any technical difficulties caused on our website by doing so.
We do not sell, trade, or otherwise transfer to outside parties your personal data given to us via a purchase or any other use of our site, other than to the parties and for the reasons listed below. We only use partners that are fully GDPR compliant and your data is always protected under these terms.
You can opt out of this service at any time either by changing your preferences or unsubscribing from the footer of our mailing list emails, or by requesting that we amend or remove your details from our mailing list to firstname.lastname@example.org.
Booking and enquiry management
We use Sage Pay as our independent payment platform. When you book with us, we only capture the final four digits of your card, card type, and the transaction date and ID. At no point are your full card details captured by or entered into our system.
When you choose to pay via direct debit, we use GoCardless in order to process your payment. Just like with Sage Pay, when you choose to pay via this method your payment information is never captured or stored on our system in order to maximise the security of your payment.
Google Analytics is the industry standard method for tracking how a site is used, and we use this to help improve our service. This data is largely anonymised and we do not use any information gathered in this way to identify individuals.
We also use Google Adwords Search and Display Network in order to serve advertising for users who are searching for a holiday. In the process of this, we may use cookie information to serve you more relevant advertising if you have visited our website or interacted with our service in other ways previously.
This processing of limited personal data is done so under the same group of policies outlined in the section ‘Google Analytics’ above, and you can choose to opt out of this form of processing in the same fashion should you wish to.
How long do we store information for?
We store different types of personal information for different lengths of time, depending on the reasons for which it was collected, and our ongoing justification for using it.
For data obtained via consent, we typically hold this for as long as we continue holding your consent.
For data obtained to fulfil a contract, we usually hold on to this data for a period of six years in order to fulfil legal and financial auditing purposes, after which time we will typically either anonymise this data, or remove it.
Data held in order to fulfil legitimate interests is held for varying lengths of time depending on the interest. Your rights to privacy as an individual are never overruled by our legitimate interests.
Legal requirements to disclose information
We may on occasion by obliged by law to disclose certain personal information to legal or other similar entities. Whenever possible and when is allowed by law, we will inform the affected parties that we have done so. However, on some occasions we may be legally obligated to do so without informing those affected.
Your rights to object to our use of your data, or to complain
In most cases, you have the right to object to our use of your data if you feel it is not justified.
You also generally have the right to receive copies of this data, as well as the rights to have this data amended if it is incorrect, the right to have us stop processing it if our reasons for doing so are no longer valid, or to have the data removed if our basis for keeping it is not legally justified. Please note that these rights are not universal and do not all apply in every case.
Wherever possible, we will comply with legitimate requests for any of the above within one month of the request being made, either verbally or in writing. We may ask you to follow any verbal requests with written confirmation in order to ensure our records are accurate, but we will still honour the date of the original verbal request.
Where it is not possible to fulfil any request, we will provide full reasons why this is the case, as well as provide you with avenues to appeal should you not be satisfied. You will not be charged a fee for any request listed above except in exceptional circumstances.
If you wish to make a complaint about any aspect of our data use, you can do so either by contacting our Data Protection Officer at email@example.com, or directly to the Information Commissioner’s Office via their website. There you can also find a full explanation of your rights regarding your data.
Additional Privacy Information for Owners
If you are an owner, there are additional pieces of information in conjunction with those listed above that we may need to collect in order to fulfil our contractual obligations with you and provide our service.
The same protections and rights apply to this data as to those already listed.
What additional data do we collect?
When letting a property with us, we collect as well:
- Addresses of your properties with us.
- Historical booking information.
- Photographs and videos of your properties.
- Written correspondence between you and members of our team.
- Copies of any identification, insurance, or utility forms necessary for the commencement of your contract with us.
Why do we collect this additional information?
- To carry out and fulfill our contracts with you.
- In order to provide you with a full and personal service, which includes the marketing of your property to guests.
- To ensure that all of our holiday lettings are adhering to legal requirements and to provide proof of this.
- To provide records for any internal or external financial or commercial auditing processes.
- To help train our staff, and to improve our service for you and other owners in the future.
At no point do we share any of your personal data referred to here with any other owners.
This data is typically held for six years after the date at which you cease being an owner with us, after which time it is usually either anonymised, or removed.