Welcome to the Ukcaravans4hire.com Limited (“Ukcaravans4hire.com”) privacy notice. This privacy notice applies to personal data collected on www.ukcaravans4hire.com (the “Website”).
Ukcaravans4hire.com respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our Website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) in order to purchase caravan hire from us, and tell you about your privacy rights and how the law protects you.
Please also refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Ukcaravans4hire.com collects and processes your personal data, including any data you may provide through this Website when you make a booking for caravan hire, when you sign up to our newsletter, when you take part in a competition, when you create a guest account as part of our booking process or when you create an owner account to list your holiday home.
This Website is not intended for children and we do not collect data in relation to children.
Ukcaravans4hire.com Limited, a company registered in England, with company number: 7061010 and registered office address of Unit 12, Dyson Wood Way, Bradley Business Park, Huddersfield, West Yorkshire, HD2 1GN, (referred to as “Ukcaravans4hire.com” "we", "us" or "our" in this privacy notice) is the data controller in relation to your personal data. This means that we are responsible for your personal data.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights please contact Gareth Irving.
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 16 April 2019 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
This Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party Websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy notice of every Website you visit.
2. Important payment information
Payment processing services for account holders on our Website are provided by Stripe and are subject to the "Stripe Connected Account Agreement", which includes the Stripe Terms of Service (collectively, the "Stripe Services Agreement"). By agreeing to this privacy notice or continuing to operate as an account holder on this Website, you agree to be bound by the Stripe Services Agreement, as the same may be modified by Stripe from time to time. As a condition of this Website enabling payment processing services through Stripe, you agree to provide accurate and complete information about you and your business, and you authorise us to share it and transaction information related to your use of the payment processing services provided by Stripe.
3. Important technical information
You can opt-out to the creation of a user profile, Hotjar’s storing of your usage on our Website and their use of tracking cookies on other websites by following this link.
4. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
(A) Identity Data
This includes data relating specifically to your identity, such as your first name, last name, username or similar identifier, title, date of birth and gender.
(B) Contact Data
This includes data relating to how you may be contacted, such as your home address, billing address, email address and telephone numbers.
(C) Financial Data
This include data relating to your means and methods of payment, such as your bank account and payment card details.
(D) Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
(E) Technical Data
This includes more technical data that we may obtain when you make use of our Website, such as your internet 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 this Website.
(F) Profile Data
This includes the data that we receive when you create a profile on our Website and make use of that profile, such as your username and password, bookings made by you, your interests, preferences, feedback and survey responses.
(G) Usage Data
This includes information about how you use our Website, products and services.
(H) Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
In other words, where we require details from you in order to facilitate your booking for your chosen caravan hire, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking on behalf of the relevant supplier, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms & Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason
5. How your personal data is collected?
We use different methods to collect data from and about you including through:
(A) Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us via our Website, or by post, phone, email or otherwise. This includes personal data you provide when you:
- make a booking on the Website;
- create an account on our Website;
- subscribe to our newsletter or other publications;
- request marketing materials to be sent to you;/li>
- enter a competition, promotion or survey;
- give us some feedback; or
- make an enquiry through the website.
(B) Automated technologies or interactions
As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
(C) Third Parties
We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- (i) analytics providers such as Google based outside the EU;
- (ii) mailing list providers such as Mailchimp based outside the EU; and
- (iii) payment services such as Stripe based outside the EU
- (iv) technological services such as Hotjar based within the EU
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe and Mailchimp, both of which are based in the United States.
6. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to facilitate your booking for caravan hire with the relevant supplier of the caravan hire
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- Where we need to comply with a legal or regulatory obligation
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
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 data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you.
To process and facilitate your caravan hire booking, for both owners and guests, including:
(a) Performance of a contract with you;
To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you;
To administer and protect our business and this Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for 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);
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, 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 goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To manage your enquiry
Necessary for our legitimate interests (to assist you with your enquiry)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive email marketing (such as newsletters) if, when you registered as a guest or made a booking on the Website, you opted-in to receiving such marketing communications.
We will get your express opt-in consent before we share your personal data with any third party company for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time by email or letter.
Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a booking or other such transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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 do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
7. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
(A) Internal Third Parties:
(B) External Third Parties, such as:
(i) Suppliers of the caravan hire available to book on the Website, all based in the UK and acting as independent data controllers;
(ii) Service providers acting as processors based both within and outside the EEA who provide IT and system administration services.
(iii) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based within the EEA who provide consultancy, banking, legal, insurance and accounting services.
(iv) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
(C) Specific third parties such as Stripe and Mailchimp, both of which are based outside the EU;
(D) Third parties to 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 notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions
8. International transfers
Some of 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US, such as Stripe and Mailchimp, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9. Data retention
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures 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.
10. Data security
How long will you use my personal data for?
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 satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for legal and tax purposes. If you are a visitor of the Website or make an enquiry, we will keep your Contact and Identity information for up to one year from when the information is provided.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object 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.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if 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 data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.