INTRODUCTION

 

Lead Actions Capital Limited, company number 12812187, with registered office address Suite 523 (515A), 83 Victoria Street, SW1H 0HW London, United Kingdom (referred to as "we", "us""our" or "Eurobeds" in this Privacy Policy) usually respects your privacy and your is committed to protecting your (or a guest's) personal data. This Privacy Policy will inform you as to how we look after your (or guest's) personal date. We usually collect the information about guests, providing they are over 18 years of age.

This Privacy Policy is provided in a layered format so that you can easily click through to the specific areas set out below.

Please also refer to the Glossary that we have set out at the end of the Privacy Policy, if there is any terminology used in this Privacy Policy that you are unfamiliar with or that you don’t fully understand.

 

 

Data Controller

 

 

(A)         Identity Data

 

This includes data relating specifically to your identity or the identity of guests, such as your first name, maiden 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 billing address, delivery address, email address and telephone numbers. We may also require the contact details of guests.

 

(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, purchases or orders 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 communications 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 (or a guest’s) 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 (or a guest’s) 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 Policy.

 

Special Categories of Personal Data

 

We collect dietary requirements which may disclose your (or a guest’s) religious or philosophical beliefs.

 

We collect and process the above data only where it is strictly necessary to do so in order to deliver special requests. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

 

You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to accommodate the special requests that you have made or are attempting to make.

 

 

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 provide you with your chosen accommodation if you do not provide us with the necessary details then we will not be able to provide the accommodation 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, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.

 

We use different methods to collect data from and about you including through:

 

(A)         Direct interactions

 

You may give us your (or a guest’s) Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

 

·                 make bookings or booking enquiries;

·                 book accommodation;

·                 create an account on our website or become a member;

·                 subscribe to our newsletter or other publications;

·                 request marketing to be sent to you;

·                 when you take part in any of our loyalty schemes;

·                 enter a competition, promotion or survey; or

·                 give us some feedback.

       

(B)         Automated technologies or interactions

 

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

 

We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

 

(C)         Third parties

 

We may receive personal data about you from various third parties as set out below:

 

·       Technical Data from the following parties: Google analytics, Facebook, Linkedin, Twitter, Salesforce various suppliers.

·       Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SafeCharge, Barclays Bank based inside the EU.

 

Please note that when using our website, you may be able to share information through social networks like Facebook, Twitter, Linkedin or Instagram. For example, when you ‘like’, ‘share’ or review our services. When doing this, your personal information may be visible to the providers of those social networks and/or their other users. Please remember it is your responsibility to set appropriate privacy settings on your social network accounts so you are comfortable with how your information is used and shared on them. This will not be the responsibility of Eurobeds.

 

HOW WE USE YOUR (OR A GUEST’S) PERSONAL DATA

We will only use your (or a guest’s) personal data when the law allows us to. Most commonly, we will use your (or a guest’s) personal data in the following circumstances:

 

Purposes for which we will use your (or a guest’s) personal data

 

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer.	(a) Full name b) Identity (Identity card or passport) c) Contact.	Performance of a contract with you.
To process and deliver your booking including:   (a) Manage payments, fees and charges; (b) Collect and recover money owed to us.	(a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:   (a) Notifying you about changes to our terms or Privacy Policy; (b) Asking you to leave a review or take a survey.	(a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey.	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Identity (b) Contact (c) Technical	(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); (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical	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	(a) Technical (b) Usage	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	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to develop our products/services and grow our business).
To monitor our communications with you in order to check any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to defend legal claims.	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (to assist us in training our employees and defend our business in the event of a claim).   (b) Necessary to comply with a legal obligation;

 

Marketing

 

We have established the following personal data control mechanisms:

•        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).

 

•        Third-Party Marketing

 

We will get your express opt-in consent before we share your personal data with any company outside the Eurobeds for marketing purposes.

 

•        Opting Out

 

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out or “unsubscribe” links on any marketing message or email sent to you or by contacting us at any time.

       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 purchase of travel services or other such transactions.

 

•        Monitoring Communications

 

We may monitor, record, store and use any telephone, email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

 

•        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.

 

 

(A)         External Third Parties as set out in the Glossary.

(B)         Specific third parties

(C)         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 Policy.

 

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 you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your (or a guest’s) personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your (or a guest’s) personal data to countries outside the EEA ( as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your (or a guest’s) personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.

 

 

·               We will only transfer your (or a guest’s) 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, 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 (or a guest’s) personal data out of the EEA.

We have put in place appropriate security measures to prevent your (or a guest’s) personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your (or a guest’s) personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your (or a guest’s) 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.

 

How Long Will You Use My Personal Data For?

 

 

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

 

Under certain circumstances, you have rights under data protection laws in relation to your (or a guest’s) personal data. Please click on the links below to find out more about these rights:

 

(A)         Request access to your (or a guest’s) personal data.

(B)         Request correction of your (or a guest’s) personal data.

(C)         Request erasure of your (or a guest’s) personal data.

(D)        Object to processing of your (or a guest’s) personal data.

(E)         Request restriction of processing your (or a guest’s) personal data.

(F)          Request transfer of your (or a guest’s) personal data.

(G)        Right to withdraw consent.

 

If you wish to exercise any of the rights set out above, please contact us .

 

No fee usually required

 

 

 

 

 

 

LAWFUL BASIS

 

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 (or a guest’s) personal data for our legitimate interests. We do not use your (or a guest’s) 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 (or a guest’s) personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

·               External Third Parties

 

i.               Suppliers of accommodation acting as processors based in the UK who provide the accommodation that makes up any booking of accommodation that you make with us.

ii.             Service providers acting as processors based in the UK and Spain who provide IT and system administration services.

iii.           Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers 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.

 

YOUR LEGAL RIGHTS

You have the right to:

 

• Request access

to your (or a guest’s) 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 (or a guest’s) 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 (or a guest’s) 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 (or a guest’s) 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 (or a guest’s) 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 (or a guest’s) 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 (or a guest’s) personal data. This enables you to ask us to suspend the processing of your (or a guest’s) 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 (or a guest’s) personal data to you or to a third party. We will provide to you, or a third party you have chosen, your (or a guest’s) 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 (or a guest’s) 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.