Villas Portugal Privacy and Cookie Policy

Privacy Policy

Introduction

Villas Portugal Ltd is committed to protecting our customer privacy and takes its responsibility regarding the security of customer information very seriously. We will be clear and transparent about the information we are collecting and what we will do with that information.

This Policy sets out the following:

• What personal data we collect and process about you in connection with your relationship with us as a customer and through your use of our website, and online services;
• Where we obtain the data from;
• What we do with that data;
• How we store the data;
• Who we transfer/disclose that data to;
• How we deal with your data protection rights;
• And how we comply with the data protection rules.  
• All personal data is collected and processed in accordance with UK and EU data protection laws.  

 

Data Controller

 

Villas Portugal Ltd (referred to as “we”, “us”, “our” or “VP Ltd” in this policy) in this policy primarily refers to Villas Portugal Ltd is the “data controller” of all personal information that is collected and used about our customers. Villas Portugal Ltd is registered in the UK with registration number 05038893 and registered offices at Stag Gates House, 63/64 The Avenue, Southampton SO17 1XS.

 

What personal data we collect

 

Personal data means any information relating to you which allows us to identify you, such as your name, contact details, payment details and information about your access to our website.

We may collect personal data from you when you book a villa with us (either directly or indirectly through our trusted third party partners), use our website and other websites accessible through our website or when you contact us.

Specifically, we may collect the following categories of information:

a. Name, home address, e-mail address, telephone number, passport or other recognized personal ID card numbers and details, credit/debit card or other payment details;

b. Portuguese Immigration information, which includes your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;

c. Medical conditions for passengers who have special medical requirements and/or dietary requirements;

d. Travel history, including information related to your flights and services booked in connection with your flights;

e. Information you provide about your and your companions’ travel preferences;

f. Information about your use of our website;

h. The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.

 

What do we use your personal data for and for how long

 

Your data may be used for the following purposes:

a. Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your holiday;

b. Contacting you in the event of a changes to your holiday including cancellation: we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;

c. Administrative or legal purposes: we use your data for statistical and marketing analysis, customer surveys, and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. Any profiling activity will be carried out with your prior consent only and by making best endeavours to ensure that all data it is based on is accurate. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;

d. Immigration/customs control safety: we may be obliged to provide your information to border control agencies and in particular the Portuguese agencies;

e. Security, health, administrative, crime prevention/detection:  we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;

f. Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us; 

g. Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your travel with us and to personalise the services we offer to you, such as special arrangements for disabled aids, or assistance with children;

h. Marketing: from time to time we will contact you with information regarding future holidays via e-communications. You will have the choice to opt in or opt out of receiving such communications. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.

In most cases we will need to process your personal data so we can enter into our contract of villa rental with you.

We may also process your personal data for one or more of the following:

• To comply with a legal obligation (e.g. Immigration or customs requirements);
• You have consented to us using your personal data (e.g. for marketing related uses);
• To protect your vital interests or those of another person (e.g. in case of a medical emergency);
• It is in our legitimate interests in operating as a holiday booking agent (e.g. for administrative purposes).

Only children aged 16 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required. 

We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.  

 

Security of your personal data

 

We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. We will delete any information of a travel companion collected without the companion’s consent, as soon as we become aware of it.

 

Sharing your personal data

 

Your personal data will be shared with our villa manager in order to prepare for your holiday.

We may also share your personal data with the following third parties for the purpose described in this Privacy Policy:

a. Government authorities, law enforcement bodies and regulators;

b. Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment to process payment or ensure the security of your payment transaction;

c. Legal and other professional advisers, law courts and law enforcement bodies in the UK and Portugal in order to enforce our legal rights in relation to our contract with you;

 

Data Protection Officer

 

We have appointed a Data Protection Officer (“DPO”) to oversee compliance with this policy. You have the right to make a complaint at any time to a supervisory authority such as the UK Data Protection Commissioner.

 

Your Data Protection Rights

 

Under certain circumstances, by law you have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below).
• Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically useable format and to be able to transfer your data to another party in an electronically useable format.
• Withdraw consent. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

If you want to exercise any of these rights, then please send a request to .

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Changes to Privacy Policy

 

Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you by way of an e-mail or a notice on our website.

 

May 2018

Hyperlinks to Other Websites:

• Villas Portugal Ltd may provide links on our site that direct to external, third party websites.
• We have no control over the content other sites, nor the usage of information they gather.
• We recommend that you always review the privacy policies at any third party sites you visit; they may not follow the same policies as us.

Our Use of Cookies

The Villas Portugal Ltd website cookie

The Villas Portugal Ltd website uses a “session cookie” to identify your browser “session” as you move between pages on the website and perform activities. The cookie is named c2brockwoodservices_eztnu4htxk1 and will last for 3 months.

The website cookie allows our website to recognise each subsequent request from your browser as being the same browser that made the initial request to our website.

By knowing that each subsequent request is related to the first, our website is able to track your actions as you move around the website and to provide interactive features. By analysing how our website is being used in general, we can improve the website experience for future visitors. Should you experience any problems in using our website, our website developers may be able to use this information to track down your specific “user journey” and investigate and fix any issues that might arise.

The cookie itself is a very small text file that is stored on your device (for example, your PC or your phone) by your web browser. It contains a simple text code that your browser sends back to our website each time you browse to a new page. This allows the website to look up your specific session and associate data for that session with your browser. The data itself is not stored in your cookie but on the server(s) operating the website.

Each page on our website is generated by a sophisticated Content Management System (CMS). This system provides a number of interactive features where your experience may be tailored according to your past activity on the website. Such features require the “session cookie” to operate.

The session cookie provides the ability for you to log on to our website using your unique user name (or e-mail address) and password.

Each page on our website may be tailored to you uniquely, based on your past activity on the website, for example to show your name.

The session cookie provides the means to remember your log on state and hence your discussion forum preferences, such as your nickname and the date of your last post.

The session cookie provides the means for you to take part in votes (or polls) on the website.

The session cookie provides the means to remember that you have submitted a form so that you are not asked to re-submit it.

The session cookie provides the means to remember which files you have requested to be sent to you by email and the date and time at which such requests were made.

The session cookie provides the means to remember whether you have ‘like’d our Facebook page.

As we improve our website over time, similar and more advanced features may be added that also require a “session cookie” to operate.

Google Analytics

The Villas Portugal Ltd website uses cookies to allow Google Analytics to function correctly. Google Analytics is a free web analytics tools that helps us understand how visitors engage with the Villas Portugal Ltd website. These cookies have names that begin with __utm such as __utma and __utmz.

Google Analytics collects information anonymously; it reports website trends without identifying individual visitors. The cookies store information such as the number of visits to the website and what site referred the visitor to the web page. We use the information to view reports about how visitors interact with the website and to help us improve the website. A different set of cookies is used for each website, and visitors are not tracked across multiple sites.

Information about these cookies and how to reject or delete them: https://www.google.co.uk/intl/en/analytics/privacyoverview.html and https://www.google.com/intl/en/policies/privacy/ads/#toc-analytics.

To opt out of being tracked by Google Analytics across all websites visit https://tools.google.com/dlpage/gaoptout.
Google’s privacy policy: https://www.google.com/intl/en/privacypolicy.html

How to control and delete cookies

You may restrict or block the cookies which are set by the Villas Portugal Ltd website, or any other website, through your browser settings.

To find out more about cookies and how to manage them, visit www.aboutcookies.org.

Please be aware that restricting cookies may impact on the functionality of the Villas Portugal Ltd website.