PRIVACY & COOKIE POLICY
VERSION 1.2 – APPLICABLE from 24/12/2022 onwards
BACKGROUND:
This Privacy &
Cookie Policy relates to the website, www.albacampers.com,
which is owned and operated by Halley & McKenzie Ltd (hereafter, ‘Alba
Campers’).
ALBA CAMPERS understands that your
privacy is important to you and that you care about how your personal data is
used. We respect and value the
privacy of everyone who visits this website, www.albacampers.com (“Our Site”) and will only collect and use
personal data in ways that are described here, and in a www.albacampers.com that is consistent
with our obligations and your rights
under the law.
Please read this
Privacy & Cookie Policy carefully and ensure that you understand it.
1.
Definitions and
Interpretation
In this Policy the following terms shall have the following
meanings:
|
“Account” |
means an account required to access and/or use certain areas |
|
“Cookie” |
means a small text file placed on your computer or device by |
|
“Cookie Law” |
means the relevant parts of the Privacy and Electronic |
2.
Information About Us
Our Site is owned
and operated by HALLEY & MCKENZIE LTD, a company registered in Scotland
under Company Registration Number SC597843, of registered office 113 St.
Johns Road, Edinburgh, Scotland, EH12 7SB, and
we can be contacted using the details below:
Email address: info@albacampers.com
Telephone number: 0131 210
0038
3.
What Does This Policy Cover?
This Privacy & Cookie Policy applies only to your use of
Our Site. Our Site may contain links to other websites. Please note that we have no control over how your data is
collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites
before providing any data to them.
4.
What Is Personal Data?
Personal data is defined by the General Data Protection
Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act
2018 (collectively, “the Data Protection Legislation”) as ‘any information
relating to an identifiable person who can be directly or indirectly identified
in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about
you that enables you to be identified. Personal data covers obvious information
such as your name and contact details, but it also covers less obvious
information such as identification numbers, electronic location data, and other
online identifiers.
5.
What Are My Rights?
Under the Data Protection Legislation, you have the
following rights, which we will always work to uphold:
(a).
The right to be informed about our collection and use of your personal
data. This Privacy Policy should tell you everything you need to know, but you
can always contact us to find out
more or to ask any questions using the details in Part 15.
(b).
The right to access the personal data
we hold about you. Part 13 will tell
you how to do this.
(c).
The right to have your personal data
rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
(d).
The right to be forgotten, i.e. the
right to ask us to delete or
otherwise dispose of any of your personal data that we hold. Please contact us using
the details in Part 15 to find out more.
(e).
The right to restrict (i.e. prevent)
the processing of your personal data.
(f).
The right to object to us using your personal data for a
particular purpose or purposes.
(g).
The right to withdraw consent. This
means that, if we are relying on
your consent as the legal basis for using your personal data, you are free to
withdraw that consent at any time.
(h).
The right to data portability. This
means that, if you have provided personal data to us directly, we are using
it with your consent or for the performance of a contract, and that data is
processed using automated means, you can ask us for a copy of that personal data to re-use with another service or
business in many cases.
(i).
Rights relating to automated
decision-making and profiling. We do
not use your personal data in this way.
For more information about our use of your personal data or exercising your rights as outlined
above, please contact us using the
details provided in Part 15.
It is important that your personal data is kept accurate and
up-to-date. If any of the personal data we
hold about you changes, please keep us
informed as long as we have that
data.
Further information about your rights can also be obtained
from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have
the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to
resolve your concerns ourselves, however, so please contact us first, using the details in Part 15.
6.
What Data Do You Collect and
How?
Depending upon your use of Our Site, we may collect
and hold some or all of the personal and non-personal data set out in the table
below, using the methods also set out in the table. Please also see Part 14 for
more information about our use of
Cookies and similar technologies. We do
not collect payment information or other financial information, our payment
processor does this instead. We do not
collect any ‘special category’ or ‘sensitive’ personal data AND/OR personal data relating to children AND/OR data relating to criminal convictions
and/or offences.
|
Data Collected |
How We Collect the Data |
|
Identity |
Via our Site |
|
Contact information |
Via our Site |
|
Client |
Via our Site and |
7.
How Do You Use My Personal
Data?
Under the Data Protection Legislation, we must always have a lawful basis for
using personal data. The following table describes how we will use your personal
data, and our lawful bases for doing
so:
|
What We Do |
What Data We Use |
Our Lawful Basis |
|
Administering our business. |
Contact information |
Provision of services |
|
Supplying our services to you. |
Identify information/documents and contact information and |
Provision of services |
|
Personalising and tailoring our services for you. |
Client requirements and travel itinerary |
Provision of services by us and by third party contractors |
|
Communicating with you. |
Contact information |
Provision of services; promotion and marketing of services |
|
Supplying you with information by email AND/OR post that you have opted-in-to (you |
Contact information |
Provision of services; promotion and marketing of services |
With your permission and/or where permitted by law, we may
also use your personal data for marketing purposes, which may include contacting
you by email AND/OR telephone AND/OR text message AND/OR post with information, news, and offers on our products AND/OR services. You will not be sent any unlawful
marketing or spam.
We will always work to fully protect your rights and comply
with our obligations under the Data
Protection Legislation and the Privacy and Electronic Communications (EC
Directive) Regulations 2003, and you will always have the opportunity to
opt-out. We will always obtain your express opt-in consent before sharing your
personal data with third parties for marketing purposes and you will be able to
opt-out at any time.
Third Parties (including) whose content appears on Our Site may use third-party Cookies, as
detailed below in Part 14. Please refer to Part 14 for more information on
controlling cookies. Please note that we
do not control the activities of such third parties, nor the data that they
collect and use themselves, and we advise
you to check the privacy policies of any such third parties.
We will only use
your personal data for the purpose(s) for which it was originally collected
unless we reasonably believe that
another purpose is compatible with that or those original purpose(s) and need
to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is
compatible with the original, please contact us using the details in Part 15.
If we need to use your personal data for a purpose that is
unrelated to, or incompatible with, the purpose(s) for which it was originally
collected, we will inform you and
explain the legal basis which allows us to
do so.
In some circumstances, where permitted or required by law,
we may process your personal data
without your knowledge or consent. This will only be done within the bounds of
the Data Protection Legislation and your legal rights.
8.
How Long Will You Keep My
Personal Data?
We will not keep your personal data for any longer than is
necessary in light of the reason(s) for which it was first collected. Your
personal data will therefore be kept for up to six (6) years after the
completion of our services to you.
9.
How and Where Do You Store or
Transfer My Personal Data?
We may store or transfer some or all of your
personal data in countries that are not part of the European Economic Area (the
“EEA” consists of all EU member states, plus Norway, Iceland, and
Liechtenstein) or EEA. These are
known as “third countries” and may not have data protection laws that are as
strong as those in the UK and/or the EEA. This means that we will take
additional steps in order to ensure that your personal data is treated just as
safely and securely as it would be within the UK and under the Data Protection
Legislation as follows.
We share your
data within the group of companies of which we are a part. Where this involves the transfer of personal data outside
the EEA, our group ensures that
personal data is protected by requiring all companies within the group to
follow the same rules with respect to personal data usage. These are known as
“binding corporate rules”. More information on binding corporate rules is
available from the European Commission.
In addition, where we share your data with external third
parties, as detailed below in Part 10, that are based outside of the EEA, the
following safeguards are applied to such transfers:
We will only
transfer your personal data to third countries whose levels of data protection
are deemed ‘adequate’ by the European Commission. More information is available
from the European Commission.
Please contact us using
the details below in Part 15 for further information about the particular data
protection mechanisms used by us when
transferring your personal data to a third country.
The security of your personal data is essential to us, and
to protect your data, we take a
number of important measures, including the following:
●
limiting access to your personal data to those employees, agents,
contractors, and other third parties with a legitimate need to know and
ensuring that they are subject to duties of confidentiality; and,
●
procedures for dealing with data breaches (the accidental or
unlawful destruction, loss, alteration, unauthorised disclosure of, or access
to, your personal data) including notifying you and/or the Information
Commissioner’s Office where we are legally
required to do so.
10.
Do You Share My Personal Data?
We will not share
any of your personal data with any third parties for any purposes, subject to
the following exceptions.
We will pass your contact information and requirements to
third party contractors and service providers if and when you instruct us to do
so, whether tacitly or expressly – for instance, if a roadside assistance
service is required.
If we sell,
transfer, or merge parts of our business
or assets, your personal data may be transferred to a third party. Any new
owner of our business may continue
to use your personal data in the same way(s) that we have used it, as specified in this Privacy & Cookie Policy.
In some limited circumstances, we may be legally required to share certain personal data, which
might include yours, if we are involved in legal proceedings or complying with
legal obligations, a court order, or the instructions of a government
authority.
If any of your personal data is shared with a third party,
as described above, we will take
steps to ensure that your personal data is handled safely, securely, and in
accordance with your rights, our obligations,
and the third party’s obligations under the law, as described above in Part 9.
If any personal data is transferred outside of the EEA, we will take suitable steps in order to
ensure that your personal data is treated just as safely and securely as it
would be within the UK and under the Data Protection Legislation, as explained
above in Part 9.
If we sell,
transfer, or merge parts of our business
or assets, your personal data may be transferred to a third party. Any new
owner of our business may continue
to use your personal data in the same way(s) that we have used it, as specified in this Privacy & Cookie Policy.
In some limited circumstances, we may be legally required to share certain personal data, which
might include yours, if we are involved in legal proceedings or complying with
legal obligations, a court order, or the instructions of a government
authority.
11.
How Can I Control My Personal
Data?
11.1
In addition to your rights under the Data Protection Legislation,
set out in Part 5, when you submit
personal data via Our Site, you may
be given options to restrict our use
of your personal data. In particular, we
aim to give you strong controls on our
use of your data for direct marketing purposes (including the ability to
opt-out of receiving emails from us which
you may do by unsubscribing using the links provided in our emails and at the point of providing your details
and by managing your Account).
11.2
You may also wish to sign up to one or more of the preference
services operating in the UK: The Telephone Preference Service (“the TPS”), the
Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference
Service (“the MPS”). These may help to prevent you receiving unsolicited marketing.
Please note, however, that these services will not prevent you from receiving
marketing communications that you have consented to receiving.
12.
Can I Withhold Information?
You may access certain areas of Our Site without
providing any personal data at all. However, to use all features and functions
available on Our Site you may be
required to submit or allow for the collection of certain data.
13.
How Can I Access My Personal
Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and
for a copy of it (where any such personal data is held). This is known as a
“subject access request”.
All subject access requests should be made in writing and
sent to the email or postal addresses shown in Part 15.
There is not normally any charge for a subject access
request. If your request is ‘manifestly unfounded or excessive’ (for example,
if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond
to your subject access request within thirty (30) days. Normally, we aim to provide a complete response,
including a copy of your personal data within that time. In some cases,
however, particularly if your request is more complex, more time may be required
up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14.
How Do You Use Cookies?
Our Site may
place and access certain first-party Cookies on your computer or device.
First-party Cookies are those placed directly by us and are used only by us. We
use Cookies to facilitate and improve your experience of Our Site and to provide and improve our products AND/OR services. We have carefully chosen these Cookies
and have taken steps to ensure that your privacy and personal data is protected
and respected at all times.
By using Our Site,
you may also receive certain third-party Cookies on your computer or device.
Third-party Cookies are those placed by websites, services, and/or parties
other than us. Third-party Cookies may be used on Our Site. For more details, please refer to the table below. These
Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
All Cookies used by and on Our Site are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you
may be shown a prompt or pop-up requesting your consent to set those Cookies.
By giving your consent to the placing of Cookies you are enabling us to provide the best possible
experience and service to you. You may, if you wish, deny consent to the
placing of Cookies; however certain features of Our Site may not function fully or as intended. You will be given the
opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our
Site depend on Cookies to function. Cookie Law deems these Cookies to be
“strictly necessary”. These Cookies are shown in the table below. Your consent
will not be sought to place these Cookies, but it is still important that you
are aware of them. You may still block these Cookies by changing your internet
browser’s settings as detailed below, but please be aware that Our Site may not work properly if you do so.
We have taken great care to ensure
that your privacy is not at risk by allowing them.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your
internet browser. Most internet browsers also enable you to choose whether you
wish to disable all Cookies or only third-party Cookies. By default, most
internet browsers accept Cookies, but this can be changed. For further details,
please consult the help menu in your internet browser or the documentation that
came with your device.
You can choose to delete Cookies on your computer or device
at any time, however you may lose any information that enables you to access
Our Site more quickly and efficiently including, but not limited to, login and
personalisation settings.
It is recommended that you keep your internet browser and
operating system up-to-date and that you consult the help and guidance provided
by the developer of your internet browser and manufacturer of your computer or
device if you are unsure about adjusting your privacy settings.
15.
How Do I Contact You?
To contact us about
anything to do with your personal data and data protection, including to make a
subject access request, please use the following details:
Email address: info@albacampers.co.uk
16.
Changes to this Privacy
Policy
We may change
this Privacy Notice from time to time. This may be necessary, for example, if
the law changes, or if we change our business in a way that affects
personal data protection.
Any changes will be immediately posted on Our Site and you will be deemed to have
accepted the terms of the Privacy & Cookie Policy on your first use of Our Site following the alterations. We recommend that you check this page
regularly to keep up-to-date. This Privacy & Cookie Policy was last updated
on 17/12/2022.
