1. Who We Are

Trading and site address: Wooldown Holiday Cottages, Sharlands Road, Marhamchurch, Bude, Cornwall, EX23 0HP.

Any reference in this policy to “you” means the customer, “we”, “us” or “our” means Wooldown Holiday Cottages.

We are committed to ensuring the best standards of practice in all our activities. Visitors to our web site can be assured that the protection of privacy and confidentiality are given the highest priority. All personal information is collected, held and used in strict compliance with the General Data Protection Regulation 2018.  

Under the General Data Protection Regulation 2018, we constitute the ‘data controller and processor’ in relation to the personal information that we collect about you.  As data controller we have specific legal obligations for maintaining records of personal data and processing activities, this includes how we collect, use and share your personal information.

2. Legal Grounds for Processing

The legal grounds we rely on to process your personal information, are that processing is necessary for:

a) Our legitimate business interests include enabling us to provide you with products, services and information about our products and services (marketing). Our legitimate business interests are not overridden by your interests or fundamental rights and freedoms in relation to the protection of your personal information;

b) Our performance of a contract made with you. This includes our providing you with products and services and our taking steps at your request towards, and in anticipation of, providing you with products and services;

c) Our compliance with legal or regulatory obligations.

3. Information We Collect

The types of personal information we collect from you include:

• Correspondence information may be collected if you contact us, we may keep a record of that correspondence.

• Contact you have had with us through social media platforms, email communication and phone calls including your contact details (i.e. your name, email address, phone number and postal address) and your bank account details.  

• Details of transactions you carry out through our sites and the fulfilment of the services we provide to you.

• Details of any surveys or other contact forms you may have filled in for us that we use for research purposes.

3.a. Information collected when you use our website, social media or enter competitions.

We do not collect any personal information from visitors to our website other than information that is knowingly and voluntarily given.

Anonymous information is collected, such as the number of visitors to the website in a given period or details of properties and dates selected for online bookings, but it is purely statistical and cannot be used to identify an individual user.

Cookies are used to remember when you visit our website in order for us to improve your online experience to suit your needs. For more information about the cookies and other similar technologies that we use, the purposes we use them for, and how to disable them, please visit our cookies policy.

Visitors interested in requesting more information can provide contact details via a fill-in form. Visitors cannot be contacted unless such information is given.

• Our Contact Form - If you send a message using the form on our website the information filled out will be sent by email to us and may be held in our records, unless you state otherwise, the information will only be used to provide you with a reply to your message.

• Our Request a Brochure Form - If you fill out this form your information may be held in our records and your personal information will only be used by us to fulfill your request of posting a copy of our brochure to your supplied physical address.

• Our Newsletter Subscribe Form - If you subscribe to our newsletter using a form on the website (or via alternative means) your email address will be held by our marketing platform provider (as detailed in Section 6 below), you can unsubscribe at any time via any communication received via this method or by contacting us using our contact details (section 12), your request will be actioned immediately or within 1 working day.

• Massage/Pamper Room Enquiry Form - If you submit this form your details input will be sent directly to the third-party provider (massage therapist) or this may be multiple providers so that the service can be fulfilled  by email, your details entered will also be sent to us and stored along with a record of any transactions relevant for the service to be carried out.

• Drinks ordering service - If you make an order for drinks to be delivered to the apartment or cottage before or during your stay, we will keep a record of the transaction, this record includes the total value of the transaction, your name, your email address and booking number. This information is required to cross reference with our booking system to check you have booked a stay in order to provide the service at the correct arrival date and also due to our licensing regulations, as this service is only available for persons who have booked a stay.  The information is required for legitimate interests to carry out the service and also to develop the range of products available to purchase.

Visitors are invited to give additional company information but a decision not to do so does not affect any subsequent negotiations or discussions.

3.b. Information collected when you visit the premises at Wooldown Holiday Cottages.

The following personal information may be collected when you visit and/or stay at the premises.

• Drinks ordering service - If you make an order for drinks to be delivered to the apartment or cottage during your stay, the process as provided in 3.a. above applies. 

• WiFi - If you connect to our WiFi service during your stay, your IP address, MAC address and device type information is collected.  The information provided is used to provide the WiFi service to you and this is in the legitimate interests to provide you with WiFi across the premises. 

• CCTV - CCTV is in place across the public areas of the premises, including the entrance/exit lanes and main parking areas.  CCTV footage is used for the purposes of crime prevention and detection and to assist in monitoring and maintaining safety.  Where necessary this footage may also be shared with the authorities for law enforcement purposes.  This information is for our legitimate interests to ensure the safety of guests and employees on the premises and to assist with law enforcement.  The footage may also be used to exercise and defend our legal rights.

4. Use and Disclosure of Personal Information

We may use your personal information to provide our services more effectively to you.  As an example, this may include handling any special requests, communicating with you (including any offers and promotions), keeping up-to-date records about you and carrying out our obligations arising from any contracts entered into between you and us, also to make payments to you and receive payments from you (where applicable).

We will use your information to help identify, develop or improve products that may be of interest to you.  This information will be used to enable us to monitor and analyse our business and to carry out market research.  Your information may be provided to independent external bodies such as governmental departments and agencies to carry out research.

Permitted use of your data under the terms of General Data Protection Regulation may also apply and in cases whereby we are required by law or it is in the public interest to disclose the information.  Your information may also be used for other purposes for which you give your consent.

5. a. Marketing

We may use your information to send further details of our current activities or to send details of future initiatives or events or for other marketing reasons, of which is subject to us obtaining your specific consent under Article 4 of the General Data Protection Regulation.

We will ask for your consent at the time we collect your data to conduct marketing which will be communicated via email, SMS, letter, telephone and will be based on the preferences you select.

5. b. Your Right to Withdraw Consent for Marketing

You can inform us if you no longer require such information to be sent.  You have the right to withdraw your consent at any time, you can do this by letting us know using the details in the ‘Contact us’ section (Section 12) of this privacy notice in writing, email or telephone.  Your request will be actioned immediately or within 1 working day.

You will have the opportunity to unsubscribe from any electronic marketing communication such emails at any time this may be in the form of an option to unsubscribe or opt-out or you may do this by contacting us in either case your request will be actioned immediately or within 1 working day.

6. Transfers of Personal Information

For the purposes set out in the section ‘Use of Information’ (Section 3) we may permit selected third-party companies to use your personal information.  These third-party companies will not use your information to contact you. Selected third parties will be subject to obligations to process your personal information in compliance with the same safeguards that we deploy.  

We work with selected data processing companies, such as the following:

Company name/number: SuperControl® a registered trademark of SuperControl Ltd, registered in Scotland, SC 2495 31.

Company Details: SuperControl Ltd, Unit 2, Station Yard, Castle Douglas, DG7 1LA, Scotland.

Processing Activity: Provides our booking and management system. We will share your details with our booking system, SuperControl® for the purpose of them delivering their service to us.

Company name/number: The Rocket Science Group (Trading name: MailChimp)

Company Details: LLC. 675 Ponce de Leon, Ave NE, Suite 5000, Atlantia, GA 30308 UA.  

Processing Activity: Provides our marketing automation platform and system for some of our marketing communication.

Company name/number: The Sage Group (Trading name: Sage Pay Europe Limited)

Company Details: Sage Pay Europe Limited, North Park, Newcastle upon Tyne, NE13 9AA.

Processing Activity: Works alongside our booking and management system to process your card payments.

Company name/number: Jotform Inc.

Company Details: 111 Pine St. Suite 1815, San Francisco, CA 94111, USA.

Processing Activity: Used for customer forms, such as requests for amending or canceling bookings.

We may disclose and exchange information with law enforcement agencies and regulatory bodies should we be required to do so following a legal request or under a legal obligation.

As part of the process of providing you with the product or service requested, we may undertake certain checks or exchange information through various fraud and credit-check databases.

Your personal information may be accessed by staff or suppliers, in, transferred to, and/or stored at, a destination outside the European Economic Area (EEA) in which the data protection laws may be of a lower standard than in the EEA.  Regardless of location or whether the person is an employee or contractor the data protection safeguards that we deploy inside the EEA will be imposed.

Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal information to these jurisdictions.

In countries which have not had these approvals, we will either ask for your consent to the transfer, or transfer it subject to European Commission approved contractual terms that impose equivalent data protection obligations directly on the recipient unless we are permitted under applicable data protection law to make such transfers without such formalities.

Under the General Data Protection Regulations 2018, when personal information is being transferred outside the EEA, we as a data controller and processor, are under an obligation to ensure that such transfers are performed in a manner than ensures that your personal information is adequately protected.

7. Safeguarding Your Information

We take appropriate measures to safeguard the information we hold from unauthorised access or improper use. Our database is stored in a secure, password protected location. Only users authorised by us have access to this data.

Our credit card processing vendor that works alongside our booking system uses security measures to protect your information both during the transaction and after it is complete.

8. Integrity and Retention of Data

We take all reasonable measures to ensure that the information we hold is accurate, to the extent that you provide us with the information we need to do so. In particular we use reliable collection methods and destroy or convert to an anonymous form, any out-of-date data. Individuals may request details of all personal information held by us so as to contest inaccurate or incomplete data, verify the information and have it corrected as appropriate.

We will retain your information for as long as needed to provide you with our services or to deal with queries, complaints or legal claims you may have.  If we have not provided you with a service, e.g. when you expressed an interest in our products or services then we will not keep your personal information for longer than necessary.

9. Your Rights in Relation to Your Personal Information

If you have any questions in relation to our use of your personal information, you should first contact us. Please see the ‘Contact us’ in Section 12 below. You have the right to request a copy of the information which we hold about you. This is called a Data Subject Access Request and is in reference to the following:

– Provide you with further details as to how we use your personal information
– Provide you with a copy of personal information we have collected about you
– Update any inaccuracies in the personal information we hold
– Delete any personal information that we no longer have lawful grounds to use.
– Object to our use of your personal information if our use of your personal information is causing you undue harm. In such cases we must cease using your personal information for that purpose

We want to make sure that your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate. We will acknowledge and respond to your request within one month of receiving your request. We will inform you of the third parties to whom your data has been disclosed.

We may charge an administrative fee when a request is manifestly unfounded or repetitive. We may also charge a further administrative fee when you request for us to provide further copies of the information already provided to you.

Information will be provided without delay and within one month of receipt. This time span can be extended upwards of an additional two months depending on the complexity or amount to which have been requested. You will be informed if an extension is required within one month of the receipt of the request.

10. Third Party Content

We may maintain presences on social media platforms such as Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us through a social media platform is done at your own risk without any expectation of privacy. The actions of other users of these platforms or the actions of the platforms themselves are beyond our control. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.

Our website or other material provided by us (e.g. in the form of an email) may include links to third-party websites. Our website or other material provided by us may include links to other websites, whose privacy practices may be different from ours. If you submit Personal Information to any of those sites, your information is governed by their privacy policies, therefore, we encourage you to read the privacy policy of any third party website you visit.

11. Children

Our website is not targeted at children but in any event personal information will not knowingly be collected from children under fourteen years without parental consent.

12. Contact Us

If you have any questions or concerns or if you want to update, delete or change any personal information we hold or if you have a concern in which the way we have handled any privacy matter, please contact us through our website, by email (holidays@wooldown.com) or by post: Wooldown Holiday Cottages, Sharlands Road, Marhamchurch, Bude, Cornwall EX23 0HP.

13. Changes to Our Privacy Policy

We keep our privacy policy under regular review, updates will be on this page.  

Our privacy policy was last updated on the 18 December 2023.