What information do we collect?
We collect two types of information from Users.
The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Site (“Non-personal Information”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in each case to the extent that it does not personally identify you. We may also collect other non-personal information on your activity on the Site.
The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information”).
Personal Information may include:
Contact information: for example, your name and email address;
Social information: for example, your social media handle(s);
Device information: for example, geolocation data, IP address, unique identifiers (e.g. MAC address and UUID); and
Usage information: for example, information which relates to your activity through the Site such as time spent on page, click-throughs, download errors and browsing patterns.
Grounds for processing your information
We will process your Personal Information to the extent that it is necessary for the performance of our contractual obligations towards you and providing you with our services, for legitimate business purposes, for compliance with legal and financial regulatory obligations to which we are subject and/or with your consent (as applicable).
How do we receive information about you?
We receive your Personal Information from various sources:
When you voluntarily provide us your personal details (including if you contact us via our Site);
When you use or access our Site in connection with your use of our services; and/or
From third party providers, services and public registers (for example, traffic analytics vendors).
How do we use your information?
We may use Users’ Personal Information for the following purposes:
To conduct statistical and analytical research, intended to improve the Site.
In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors.
- Hosting and operating our Site;
- Storing and processing such information on our behalf;
- Performing research, technical diagnostics or analytics.
We may also disclose information if we have reasonable grounds to believe that disclosure of such information is helpful or reasonably necessary: (i) to comply with any applicable law, regulation, legal process or governmental request; (ii) to enforce our policies, including investigations of potential violations thereof; (iii) to investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) to prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (vi) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
You may request to:
Receive confirmation as to whether or not Personal Information concerning you is being processed and receive access your stored Personal Information.
Request that we correct or update your Personal Information that is in our control.
Request erasure of your Personal Information.
Object to the processing of your Personal Information by us when we are relying on a legitimate interest.
Request to restrict processing of your Personal Information by us.
Request the transfer of your personal information (or some of it) to a third-party service provider.
Where you have provided your consent for something, in certain circumstances you may withdraw this consent (but we may continue to use your Personal Information if we have legal grounds for doing so).
However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.
If you wish to exercise any of the aforementioned rights, or receive more information, please contact our data protection lead using the details provided below:
In addition to the above, you may get in touch with the ICO (Information Commissioner’s Office) if you are concerned about the way in which we are handling your personal data. However, where possible, we would really appreciate you speaking with us first if you have any concerns.
We will retain your Personal Information for as long as necessary to provide our services, and as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, communications and anything else as required by applicable laws and regulations.
Subject to your rights referred to in the “User Rights” section above, we may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services.
The Site uses the following types of cookies:
a. ‘session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
b. ‘persistent cookies’ which are read only by the Site, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; and
c. ‘third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access.
We will not use any cookies/tracking technologies (or permit any third parties to place these on our Site) which are not strictly necessary for the operation of our Site, without first getting your consent.
You can manage your settings and block cookies/tracking technologies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access all or parts of our Site.
Third party collection of information
How do we safeguard your information?
Transfer of information outside the EEA
Please note that there may be some occasions where we need to transfer your information to a location outside the EEA. In such cases we will transfer your information only to such countries as approved by the European Commission as providing an adequate level of data protection, or we will put in place all necessary safeguards for such arrangement in order to ensure an adequate level of data protection.
If you have given appropriate consent or we have another legal ground to do so, we may use a third-party advertising technology to serve advertisements when you access the Site. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser).
If you have said we can, we may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.
We will provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.
Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.
We understand the importance of protecting children’s privacy, especially in an online environment. The Site is not designed for or directed at children. Under no circumstances shall we allow use of our services by minors without prior consent or authorization by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com.
How to contact us
If you have any general questions about the Site or the information we collect about you and how we use it, you can contact us at firstname.lastname@example.org.
Breaks Agency Limited
10 Chapel Place
London, EC2A 3DQ
Last Modified 18/11/2019