Data Protection Framework
Lakeland Village will complete the applicable Privacy Impact Assessments (also known as Data Protection Impact Assessments under GDPR) for activities related to this website if they meet the necessary criteria, and these are available upon request from the Lakeland Village Data Protection Officer (see Section 12).
This privacy notice aims to give you information on how Lakeland Village collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our deal alert newsletter, complete the enquiry or contact forms or the Holiday Planner.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.
Lakeland Village is the controller and responsible for your personal data (collectively referred to as “Lakeland Village”, “we”, “us” or “our” in this privacy notice). We have appointed a data protection officer 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 the data protection officer using the details set out at the end of this document.
1. Customer and Citizen Data
You may decide to send us your personal information via this website if you are seeking more information about rental accommodation or ownership at Lakeland Village, signing up for newsletters or deal alerts (marketing), contacting us or for other similar purposes. Your decision to disclose your personal data is entirely voluntary, and by doing so, you are taking an affirmative action by providing us with specific consent to use your personal data only for the purposes for which you have disclosed it to us.
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).
1.1 How data is collected
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name last name, title.
- Contact Data includes address, email address and telephone numbers.
- Technical Data includes 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.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. We use different methods to collect data from and about you including through:
- 1.1.1 Direct interactions You may give us your Identity and Contact Data by purchasing apartment / lodge holiday rental, holiday ownership, filling in online forms or by corresponding with us by phone, email, or otherwise. This includes personal data you provide when you:
- Request information about holiday rentals or holiday ownership;
- Request marketing to be sent to you in the form of deal alerts or newsletters;
- Enter a competition, promotion or survey;
- Purchase holiday ownership;
- Renting an apartment; or
- Providing feedback and / or reviews.
- 1.1.3 Third parties or publicly available sources We may receive personal data about you from various third parties and public sources as set out below:
- Technical Data from the following parties:
- Analytics providers such as Google based outside the EU;
- Search information providers based both inside and outside the EU.
1.2 How we use your personal data
Lakeland Village will only use your personal data when the law allows us to and only for the specified purpose for which you have submitted it to us.
Most commonly, we will use your personal data in the following circumstances:
(a) provide information to you
(b) make contact with you,
(c) provide contracted services to you,
(d) perform the contract between us,
(e) 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
(f) where we need to comply with legal and regulatory obligations or
(g) maintain the operations and security of the website and services we provide to you.
You will receive marketing communications from us if you have:
- Requested information from us, rented holiday accommodation with us or purchased holiday ownership products at Lakeland Village;
- If you have provided us with your details and confirmed you want to receive marketing communications; and You have the right to withdraw consent to marketing at any time by contacting us (at firstname.lastname@example.org) or by clicking the un-subscribe link (opt-out) in our emails. Whatever preference you may affirm or change from time to time, GDPR permits us to send communications where a legal requirement arises, or legitimate interest prevails.
1.3 Promotional offers from us
We may use your Identity, Contact, Technical and Usage 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 under the basis of contract or legitimate interest (we call this marketing).
1.4 Data Storage
We will, at all times, handle and store your personal data in accordance with industry best practice for information security. This includes the activities and procedures undertaken by our own personnel and authorised third parties (see Section 5), and the technical controls which we have implemented to prevent unauthorised access, compromise or theft of information from our applications, supporting computer systems and premises. With regard to the Lakeland Village website, these include removal of all personal data from the local and staging website, removal of data migration plugin, password prompts to access the staging site and two-factor authentication and email verification to access the back-end of the site. User access is limited. Information sent between your browser and our website is encrypted using SSL (Secure Sockets Layer). We have put in place procedures to deal with any suspected data breach including disaster planning and will notify you, and any applicable regulator, of a breach where we are legally required to do so. We limit, where possible, access to your personal data to employees and third parties including data processors, who have a business need to know such data. They will only process your data on our instructions and are subject to a processing agreement duty of confidentiality. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for including satisfying any legal, accounting or reporting requirements. By law we keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data, please see Section 4 below. 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.
2. Sensitive Personal Data
GDPR specifies a set of personal data categories which are “sensitive”, and which require special consideration by Data Controllers. This website, and any services available from this website, do not knowingly collect or process any sensitive personal data, and supporting Privacy Impact Assessments (also known as Data Protection Impact Assessments under GDPR) are available upon request from the Lakeland Village Data Protection Officer (see Section 12).
3. Children’s Personal Data
- This website, and any services available from this website, are not directed to children under the age of 13. If you learn that a child under the age of 13 has provided us with their personal information without having parental consent, please contact the Lakeland Village Data Protection Officer (see Section 12) immediately so that we can take appropriate action.
4. Customer and Citizen Data Rights
- As prescribed within data protection regulations, you have specific rights connected to the provision of your personal data to Lakeland Village using this website. These include your rights to request we:
- Confirm to you what personal data we may hold about you, if any, and for what purposes;
- Change the consent which you have provided to us in relation to your personal data;
- Correct any inaccurate or incomplete personal data which we may hold about you;
- Provide you with a complete copy of your personal data for you to move elsewhere;
- Stop the processing of your personal data, whilst an objection from you is being resolved; and
- Permanently erase all your personal data promptly, and confirm to you that this has been done (there may be reasons why we may be unable to do this)
- To contact Lakeland Village, please see Section 12 below.
4.1 Exercising your rights 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.
- 4.1.1 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.
- 4.1.2 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. If Lakeland Village does not address your request within one month or fails to provide you with a valid reason why we have been unable to do so, you have the right to contact the Information Commissioner’s Office to make a compliant. They can be contacted via their website (www.ico.org.uk) or by telephone +44 (0) 303 123 1113.
5. Declaration of Processing and Sub-Processing
To make an informed decision on whether to provide your personal data to Lakeland Village using this website, we need to make you aware of the following organisations who act as Data Processors for us in the provision of our services to you:
- Mail Chimp (Sub Processor), based in the United States, a marketing platform that deals with the processing and automated processing of email contact and engagement information, via the Lakeland Village website and online forms. Campaign Monitor complies with their requirements under the GDPR. Access to Campaign Monitor is limited and password protected.
- SuperControl (Sub Processor), based in Scotland, a reservation and booking platform for rental accommodation. which complies with their requirements under the GDPR
- 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. Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. Please email us at email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA. The activities within which each of these Data Processors participates will be recorded within the applicable Lakeland Village Privacy Impact Assessment records (also known as Data Protection Impact Assessments under GDPR) if required and these will be available upon request from the Lakeland Village Data Protection Officer (see Section 12).
6. Website Cookies
- Make our website work efficiently and smartly
- Save you having to remember login details every time you visit us
- Remember your settings during and between visits
- Improve our site’s speed so it’s quicker to browse
- You share pages on social networks like Facebook
- Collect any personally identifiable information (without your permission)
- Collect any sensitive information
- Pass data to any advertising networks or third parties
7. External Links
- This Lakeland Village website may include relevant hyperlinks to external websites not controlled by us.
- Whilst all reasonable care has been exercised in selecting and providing any such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the on-going suitability of external links, nor do we continually verify the safety or security of the contents that may be subsequently provided to you.
- You are advised, therefore, that your use of external links is at your own risk and we cannot be responsible for any damages or consequences from your use of them.
8. International Transfers
- Lakeland Village does not transfer your personal data outside the European Economic Area (EEA).
- However, our data processors may use third party services that may transfer your personal data outside the European Economic Area (EEA), so their processing of your personal data will involve a transfer of data outside the EEA.
9. Data Security
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 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 satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available from request from us by contacting us.
12. Contacting Lakeland Village
The Data Protection Officer
The Coach House
The Lakeland Village