SYKES GROUP PRIVACY POLICY

Sykes is committed to protecting the privacy and security of your personal data. This Privacy Policy describes how we collect, use and look after your personal data when you visit our website (regardless of where you visit it from), including when you book a holiday, sign up to our services, join our mailing lists or loyalty scheme, sign up to our newsletter or enter competitions. It also tells you about your rights and how the law protects you.

This Privacy Policy is provided in a layered format, so you can click through to the specific areas set out below. The Glossary sets out the meaning of terms used in this Privacy Policy.

Important information

Updates and links

The data we collect

How personal data is collected

How we use personal data

Disclosure of personal data

International transfers

Data security

Data retention

Your legal rights

Schedule

1.Important information

This Privacy Policy covers our dealings with people who have booked or are looking to book a holiday either as an individual or as part of a group booking (our customers) and people who have let or are looking to let their holiday property though us and use our services (our clients). Where you are completing a booking on behalf of other people, this Privacy Policy will apply to all personal data provided and you are required to bring this Privacy Policy to their attention so that they are also informed of how we will process their personal data.

This Privacy Policy supplements the other notices and terms published on our website (including our terms of use (Terms)) and is not intended to override them.

Sykes is made up of different legal entities. The following are all part of the Sykes Group:

  • Cornish Cottage Holidays
  • Devonshire Cottage Holidays
  • Helpful Holidays
  • West Country Cottages
  • Lakes Cottage Holidays
  • Hogans Irish Cottages
  • Manor Cottages
  • Hideaways
  • Dream Cottages
  • Coast & Country Cottages

This Privacy Policy is issued on behalf of the Sykes Group so when we mention "Sykes", "we", "us" or "our" in this Privacy Policy, we are referring to the relevant company in the Sykes Group responsible for processing your data. Sykes Cottages Ltd is the controller of, and is responsible for, this website.

To assist you further in understanding this Privacy Policy, we have set out in the Schedule a glossary of terms used in this Privacy Policy, examples of types of personal data we collect, how we use it, the lawful basis for processing such data and further details of your rights.

If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact our DPO in writing, either by:

Email: dpo@sykescottages.co.uk

Post: One City Place, Chester, Cheshire, CH1 3BQ, United Kingdom

You have the right to make a complaint at any time to the ICO (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Our website is not intended for children and other than in connection with a booking, we do not knowingly collect data relating to children.

We keep our Privacy Policy under review and any changes will be made by updating this page. This Privacy Policy was last updated on 19th December 2018.


Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. We have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy policies, therefore you should also read their privacy policies to understand what personal data they collect about you and how they use it.

3. The data we collect

Part 1 of Schedule 1 lists the types of personal data that we may process. We will only collect special categories of personal data where this is provided by you or on your behalf and you or the person providing the information on your behalf have specifically requested that we process the same in order to ensure any specific requirements you have can be catered for, for example, if you require lift access/wheelchair access, have food allergies or other catering requirements.

We also collect, use and share aggregated data. However, if we combine aggregated data with your personal data so that it can directly or indirectly identify you, we treat this as personal data.

We do not collect any information about criminal convictions and offences.

Failure to provide personal data

If we are required by law, or under the terms of a contract we have with you, to collect your personal data and you fail to provide it, we may not be able to enter into or perform the contract with you and, we may have to cancel your booking and/or our service to you. We will notify you of this at the relevant time.

4. How personal data is collected

We collect personal data in the following ways:

Direct interactionsPersonal data may be provided by you or on your behalf as part of our booking journey, or otherwise in connection with a booking by the lead passenger. You may also provide personal data (including identity, contact and financial data) when you complete online forms, send webchat messages, request products/services, create a user account, subscribe to our services, join our mailing lists or loyalty schemes, enter competitions or request promotional codes, take customer or client satisfaction surveys, provide feedback or otherwise or correspond with us (by post, phone or email)
Automated technologyWe automatically collect personal data (technical and usage) when you browse or interact with our website, by using cookies, server logs and other similar technologies. We may also receive technical data and usage data about you if you visit other websites which use our cookies. More information concerning our use of cookies is available in our cookies policy which can be accessed via our website.
Publicly available sourcesWe may collect personal data from publicly availably sources such as TripAdvisor, Feefo, Companies House and the Electoral Register and credit reference agencies, based inside the EU.
Third partiesWe may receive personal data from: (a) analytics providers based outside the EU (such as Google); (b) advertising networks who may be based outside the EU (such as Facebook); and (c) search information providers such as Google based outside the EU; (d) our suppliers such as payment providers, delivery services, website support, maintenance providers and telemarketing companies; (e) data brokers or aggregators based inside the EEA.

5. How we use personal data

We will only use personal data when the law allows us to. Most commonly, we will use your personal data:

  • to perform the contract we are to enter into or have entered into with you;
  • to comply with a legal obligation; and
  • where it is necessary to carry out our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Part 2 of Schedule 1 sets out the lawful basis we will rely on to process your personal data.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your information.

Marketing

We strive to provide you with choices regarding how we process your personal data and how we communicate with you for marketing purposes. Where possible, we aim to give you the option to adjust your preferences for receiving personalised marketing and advertising from us or our third party affiliates. You can do this by visiting the preferences section on your account details or calling us or contacting us by any other means which we notify you of (please see section 1 above).

Please also see below regarding our use of Cookies on our website and how these can be turned off by you.

Promotional offers from us

We may analyse and use your personal data to form a view on what holiday properties, services, offers or other things we think may be of interest to you.

You will receive marketing communications from us if you have requested information from us, booked a holiday with us or purchased services from us and you have not opted out of receiving that marketing or if we are otherwise able to market to you under existing marketing and data protection laws.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. However, we may share your personal data with our own third party affiliates who carry out marketing services on our behalf (for example, organisations which we use to send e-mails to our customers or clients), where we have the right to do so.

How to opt out

You can ask us or third parties to stop sending you marketing messages (whether electronic, telephone or postal marketing) at any time by following the opt-out links on any marketing message sent to you at any time, by logging into your account on our website (where you have an account with us) to manage your marketing preferences or by contacting our DPO and asking us to stop sending the messages (as appropriate).

Even if you opt out of receiving marketing, we may still use your personal data for other purposes provided we have a lawful basis to do so, for example in connection with your holiday or the letting of your holiday property.

Change of purpose

We will only use your personal data for the purpose that we originally 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.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to use your personal data in this manner.

We may process your personal data (without your knowledge or consent) where this is required or permitted by law.

Cookies

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 become inaccessible or not function properly. More information concerning our use of cookies is available in our cookies policy which can be accessed via our website.

6. Disclosure of your personal data

We may have to share your personal data with Third Parties set out in Part 4 of Schedule 1. We require all Third Parties to respect the security of your personal data and to treat it in accordance with the law. Such Third Parties can only process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

We share your personal data within the Sykes Group. This will not involve transferring your data outside the European Economic Area (EEA).

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.

Many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe with our services providers;
  • we may transfer data to US based service providers under the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We operate appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Access to your personal data is restricted to individuals who have a business need to know it, are under confidentiality obligations and can only process it on our instructions.

We also have procedures in place 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.

9. Data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of our marketing activities and satisfying any legal, 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.

We may update our data retention practices from time to time. Please contact us if you require further details of this. We are required to keep basic information about our customers and clients (including contact, identity, financial and transaction data) for six years after the end of the tax year in which they cease being customers or clients, for tax purposes.

We may also anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. Anonymised data may be used indefinitely without further notice to you.

We will process your financial data such as credit card details for the purpose of processing payments, however we do not retain any credit card details once the payment has been accepted.

Your legal rights in relation to your personal data are set out in Part 3 of Schedule 1. If you wish to exercise any of your rights, please contact our DPO.

You will not have to pay a fee to exercise any of your rights, unless your request is unfounded, repetitive or excessive. Where this is the case, we may charge a reasonable fee for information or refuse to comply with your request.

We may ask you to provide further information to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who does not have the right to receive it.

We aim to respond to requests within one month. If your request is particularly complex or you have made a number of requests it may take us longer to respond and in this case, we will notify you and keep you updated.

Schedule 1

Part 1 - Types of personal data

Contact dataBilling address, delivery address, holiday property address, email address and telephone numbers.
Financial dataBank account and payment card details.
Identity dataFirst name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and photographs (where we hold photographs of your property and you are in that photograph).
Marketing and communication dataYour preferences in receiving marketing from us and our third parties and your communication preferences.
Profile dataYour username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage dataInformation about how you use our website, products and services including your browsing actions and patterns on our website (which helps us to improve our website and personalise marketing).
Technical dataInternet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Transaction dataDetails about payments to and from you and other details of products and services you have purchased from us.

Part 2 - Lawful basis for processing and processing activities

The lawful basis upon which we may rely to process your personal data are:

ConsentYou have given your express consent for us to process your personal data for a specific purpose.
ContractThe processing is necessary for us to perform our contractual obligations with you under our contract, or because you have asked us to take specific steps before entering into a contract with you.
Legal obligationThe processing is necessary for us to comply with legal or regulatory obligation.
Legitimate interestsThe processing is necessary for our or a third party’s legitimate interest e.g. in order for us to provide the best service to you via our website. Before we process your personal data on this basis we make sure we consider and balance any potential impact on you, and we will not use your personal data on this basis where such impact outweighs our interest.

Set out below are specific details of the processing activities we undertake with your personal data and the lawful basis for doing this.


Purpose/Activity Type of data Lawful basis for processing
To register you as a new customer/client or to register your account on our website.Identity, contact & profile.
  • To perform our contract with you.
To process manage and deliver your holiday booking or lettings, travel arrangements and insurance and to manage payments, collections, fees and charges and debt recovery. Identity, contact, financial, transaction, profile and marketing & communications
  • To perform our contract with you.
  • As necessary for our legitimate interest in recovering debts due to us.
To manage our relationship with you, notify you about changes to our Terms or Privacy Policy and ask you to leave a review or complete a customer or client satisfaction survey. Identity, contact, profile, usage and marketing & communications
  • To perform our contract with you.
  • As necessary to comply with a legal obligation.
  • As necessary for our legitimate interests in keeping our records updated and analysing how customers/clients use our services.
To enable you to partake in our loyalty scheme, prize draws, competitions, receive promotional codes or complete customer/client satisfaction surveys. Identity, contact, profile, usage & marketing & communications
  • To perform our contract with you.
  • As necessary for our legitimate interests in analysing how customers book holidays and use our services and how clients use our 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). Identity, contact & technical
  • As necessary for our legitimate interests in running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise.
  • As necessary to comply with any legal obligations.
To deliver relevant website content/advertisements (including personalised brochures and marketing materials) to you and to measure or understand the effectiveness of our advertising. Identity, contact, profile, usage, marketing & communications and technical
  • As necessary for our legitimate interests in studying customers holiday requirements, how customers and clients use our services and to develop them, to grow our business and to inform our marketing strategy.
To use data analytics to improve our website, holiday offerings, services, marketing, and customer and client relationships and experiences. Technical & usage
  • As necessary for our legitimate interests to define types of customers for our holidays and services, and types of clients and properties, 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 holidays, properties or services that may be of interest to you, including promotional offers. Identity, contact, technical, usage & profile
  • As necessary for our legitimate interests to develop our services, property and holiday offerings and grow our business
To analyse whether you may still be interested in our products and services if you have not visited our website in a while. Contact and usage
  • As necessary for our legitimate interests (to develop our services, property and holiday offerings and grow our business).

Part 3 - Your legal rights

You have the following legal rights in relation to your personal data:

Access your data You can ask for access to and a copy of your personal data and can check we are lawfully processing it.
Correction You can ask us to correct any incomplete or inaccurate personal data we hold about you.
Erasure You can ask us to delete or remove your personal data where:
  • (a) there is no good reason for us continuing to process it;
  • (b) you have successfully exercised your right to object (see below);
  • (c) we may have processed your information unlawfully; or
  • (d) we are required to erase your personal data to comply with local law.
We may not always be able to comply with your request for specific legal reasons, which will be notified to you at the time of your request
Object You can object to the processing of your personal data where:
  • (a) where we are relying on our legitimate interest (or those of a third party) as the basis for processing your personal data, if you feel it impacts on your fundamental rights and freedoms;
  • (b) 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 and in such circumstances, we can continue to process your persona data for such purposes.
Restrict processing You can ask us to us to suspend or restrict the processing of your personal data, if:
  • (a) you want us to establish the accuracy of your personal data;
  • (b) our use of your personal data is unlawful, but you do not want us to erase it;
  • (c) you need us to hold your personal data (where we no longer require it) as you need it to establish, exercise or defend legal claims; or
  • (d) you have objected to our use of your personal data, but we need to verify whether we have overriding legitimate grounds to use it.
Request a transfer You can request a transfer of your personal data which is held in an automated manner and which you provided your consent for us to process such personal data or which we need to process to perform our contact with you, to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format.
Withdraw your consent You can withdraw your consent at any time (where we are relying on consent to process your personal data). This does not affect the lawfulness of any processing carried out before you withdraw your consent.

Part 4 - Third Parties

Group companies Other companies in the Sykes Group acting as joint controllers or processors and who are based in the United Kingdom and the Republic of Ireland.
Service providers Acting as processors who provide IT, system administration services, website hosting and support, marketing services and other services (who may be based inside or outside of the EU).
Professional advisors Acting as processors or controllers including lawyers, bankers, auditors and insurers based in the United Kingdom or Republic of Ireland who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue & Customs, regulators and other authorities Acting as processors or controllers based in the United Kingdom or the Republic of Ireland who require reporting of processing activities in certain circumstances.
Third party service providers
  • Clients, property owners/management companies to facilitate your booking and holiday, including to arrange for the collection of keys etc.
  • Payment service providers, including:
    PayPal (Europe) S.à r.l. et Cie, S.C.A. Attention: Legal Department, 22-24 Boulevard Royal L-2449, Luxembourg
    Sage Pay Europe Limited, North Park, Newcastle upon Tyne, NE13 9AA
    Syntec Ltd, 18 The Avenue, London W13 8PH
    Apple Inc., One Apple Park Way, Cupertino, CA 95014, USA
  • Websites such as Feefo and TripAdvisor who provide platform for our customers to leave reviews.
  • Marketing service providers, including:
    Intilery.com Ltd, Beech House, Park West Business Park, Sealand Road, Chester, CH1 4RJB
    Emailcenter UK Limited, West Tithe, Pury Hill Business Park, Alderton Road, Towcester, Northamptonshire, NN12 7LS
    Ant Protect Limited, Antenna House, St Mary's Gate, Sheffield, S2 4QA
    TripAdvisor LLC, 400 1st Avenue, Needham, MA 02494, USA
  • Ferry operators (where you need to book a ferry). The ferry companies we use are: Wightlink Ltd, PO Box 59, Portsmouth, PO1 2XB
    Irish Ferries Limited, Ferryport, Alexandra Road, Dublin 1, Ireland. Eircode D01 W2F5
    Stena Line Limited, Stena House, Station Approach, Holyhead, Anglesey, LL65 1DQ
  • Insurance providers where you have chosen to purchase travel insurance as part of your booking. The insurance providers we use are:
    ITC Compliance Limited
    Towergate Underwriting Group Ltd.
  • Postal services who send out our brochures and leaflets.
  • Local businesses aiming to attract tourism such as pubs/restaurants, activity companies and rental car/bicycle companies.
  • Third parties whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
Property Owners We will share your personal data with property owners who have a need to know for the purpose of the booking. If you provide feedback on a property, we may also share this with the owner of the property which may include disclosing your personal data.

Part 5 - Glossary

Aggregated data information such as statistical or demographic data which may be derived from personal data, but which cannot by itself identify a data subject.
Controller a body that determines the purposes and means of processing personal data.
Data subject an individual living person identified by personal data (which will generally be you).
Personal data information identifying a data subject from that data alone or with other data we may hold but it does not include anonymised or aggregated data
Processor a body that is responsible for processing personal data on behalf of a controller.
Special categories of personal data information about race, ethnicity political opinions, religious or philosophical beliefs, trade union membership, health, genetic, biometric data, sex life, sexual orientation.
ICO Information Commissioner’s Office, the UK supervisory authority for data protection issues.