We work with a range of hoteliers to enable them to grow and optimise their sales channels, both direct and through third parties. As part of this collaboration, certain personal data of guests and prospective guests will be collected by or uploaded onto our booking system through the actions of the hotels and other third parties with whom we work or directly by the guests or prospective guests. As a result, we, C-Breez Limited, may be the data controller of that personal data. This privacy policy refers to the personal data which is collected in this way and what happens to this.
What is the purpose of this privacy policy?
This privacy policy sets out the personal data which is collected from or about a living, identified or identifiable individual by the hotels and other third parties with whom we work or our own systems. These individuals are referred to as “data subject(s)”, “you” and “your” in this policy. The hotels and other third parties are referred to as “partners”. Data subjects may be nationals or residents of any country and may have legal rights regarding their personal data. This policy also sets out why we collect personal data and what we will do with it. In addition, it tells you about some of the key rights which you have under UK data protection laws which include (but are not limited to) the UK Data Protection Act 2018. These laws are referred to as “data protection laws”.
We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are otherwise permitted to do in accordance with data protection laws.
We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are otherwise permitted to do in accordance with data protection laws.
What personal data will we collect from or about you and why?
In order for our partners to respond to an enquiry, process and fulfil your booking or send you any information or promotional material, they need to collect personal data from you most of which will be uploaded to our booking system. Depending on what’s required, the personal data which is collected and stored on our booking system is likely to include names and contact details (such as your mobile / landline telephone number, postal and e-mail addresses) and dates of birth of party members. We may also collect and store special category personal data (see below) although our systems may not recognise it as such. We do not store credit/debit card or other payment details or passport information. We may also access your personal data when assisting our partners with support queries and technical issues.
Information relating to your racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation and biometric or genetic data is treated as special category personal data and is referred to as such in this policy. All references in this privacy policy to personal data include special category personal data unless otherwise stated. Special category personal data provided to us will be passed on to the hotel where relevant to the services which have been booked.
Information relating to your racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation and biometric or genetic data is treated as special category personal data and is referred to as such in this policy. All references in this privacy policy to personal data include special category personal data unless otherwise stated. Special category personal data provided to us will be passed on to the hotel where relevant to the services which have been booked.
Who may we provide your personal data to?
Where you make a booking, appropriate personal data will be collected by the hotel who will share this with any third party (such as banks and/or credit card companies) who need this information so that your hotel stay can be provided. With your consent, the hotel may use appropriate personal data to market their services to you. The appropriate information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law. Certain information may also be passed on to security or credit checking companies. Depending on the travel arrangements concerned, certain personal data may also be accessible by other suppliers from our booking systems.
We will only allow partners and other third parties to have access to the personal data of guests that they require in order to deliver the services that are contracted through our booking system. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps intended to ensure that anyone permitted access to your personal data through our booking system for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services. If we cannot permit access to necessary personal data to the relevant suppliers or any other third party as applicable, whether in the EEA or not, it will not be possible to fulfil your booking. In making your booking, you consent to your personal data being made available to the hotel and, if applicable, any other necessary third party.
We will only allow partners and other third parties to have access to the personal data of guests that they require in order to deliver the services that are contracted through our booking system. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps intended to ensure that anyone permitted access to your personal data through our booking system for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services. If we cannot permit access to necessary personal data to the relevant suppliers or any other third party as applicable, whether in the EEA or not, it will not be possible to fulfil your booking. In making your booking, you consent to your personal data being made available to the hotel and, if applicable, any other necessary third party.
Where will we process your personal data?
Your personal data may be stored, used and otherwise processed within the UK, any other country(ies) of the European Economic Area (EEA), the USA, the country(ies) of the Caribbean where your hotel(s) is located and any other country(ies) where any data centre we use is situated.
EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein. The UK is no longer a member of the EEA.
We may store, use or otherwise process personal data outside the UK and EEA. Data protection laws may not be as strong outside the UK / EEA as they are in the UK / EEA. Personal data will not be transferred to a country outside the UK / EEA unless (1) the country to which it is transferred is one which the European Commission considers provides an adequate level of data protection or (2) the personal data is transferred to a United States company which has signed up to the Safe Harbour scheme or (3) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (4) the personal data must be provided to a government / public authority for your holiday to be provided.
EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein. The UK is no longer a member of the EEA.
We may store, use or otherwise process personal data outside the UK and EEA. Data protection laws may not be as strong outside the UK / EEA as they are in the UK / EEA. Personal data will not be transferred to a country outside the UK / EEA unless (1) the country to which it is transferred is one which the European Commission considers provides an adequate level of data protection or (2) the personal data is transferred to a United States company which has signed up to the Safe Harbour scheme or (3) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (4) the personal data must be provided to a government / public authority for your holiday to be provided.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Can we use your personal data to send you information about the hotel services we can arrange in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so. You may provide your consent by opting to receive marketing material by e-mail, on-line or by telephone. We and/or the hotel may e-mail you in relation to our respective services where the soft opt-in applies. This requires the contact details used for the e-mail to have been provided during the course of a sale or negotiation for the sale of a product or service where the individual providing the information is given the opportunity to refuse or opt out of future marketing at the time and on every subsequent occasion a communication is sent or interaction takes place.
Can you withdraw your consent to our processing your personal data?
Yes, you can withdraw your consent to receiving marketing material or other communications from us, either generally or in any particular way, at any time by e-mailing us at support@c-breez.com.
How can you find out what information we are holding about you?
You are entitled to ask us (by e-mail to support@c-breez.com) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within 1 month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.
What should you do if the personal data we are holding is inaccurate, out of date or incomplete?
If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within 3 months if the rectification request is complex.
How long can we retain and process your personal data?
We will not keep and use your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective. The same position applies if you have consented to receiving marketing communications from the hotel.
Where you have provided your personal data so as to enable the provision of the holiday arrangements or other services you have contracted, we and the hotel are entitled to retain this information for a period of 6 years after the end of those arrangements. In certain limited circumstances, we and the hotel may be able to retain it for a longer period.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective. The same position applies if you have consented to receiving marketing communications from the hotel.
Where you have provided your personal data so as to enable the provision of the holiday arrangements or other services you have contracted, we and the hotel are entitled to retain this information for a period of 6 years after the end of those arrangements. In certain limited circumstances, we and the hotel may be able to retain it for a longer period.
Can you ask us to delete your personal data?
Yes, you can ask us to remove your personal data in certain circumstances for example where you have withdrawn your consent to our further using this for marketing purposes. However, this is not always the case. Please see the previous paragraph for further information on the period we may retain personal data.
Does your website use cookies?
Yes, as is common practice, our website uses cookies. A ‘cookie’ is a small data file that our website server stores on your computer in order to collect information about your visit and to remember you when you visit again at a later date. The main purpose of a cookie is to identify users and to personalise their visit by customising web pages for their use. You will receive a warning that cookies are to be placed on your computer at the beginning of your visit and given the opportunity to object. You may customise the cookies placed on your computer so that only essential ones are uploaded.
We may also use third parties who will collect data which is not personally identifiable to analyse site visits and carry out other similar activities. In the course of doing so, they may place their own cookies on your computer so that they can collect information about your visit. You may if you wish disable or delete such cookies through your internet browser. However, doing so may mean you will be unable to access our website or parts of it, your experience of our website may be adversely affected and/or you may not receive information which is relevant to your personal interests.
We may also use third parties who will collect data which is not personally identifiable to analyse site visits and carry out other similar activities. In the course of doing so, they may place their own cookies on your computer so that they can collect information about your visit. You may if you wish disable or delete such cookies through your internet browser. However, doing so may mean you will be unable to access our website or parts of it, your experience of our website may be adversely affected and/or you may not receive information which is relevant to your personal interests.
What should I do if I have a complaint about the processing of my personal data?
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to support(at)c-breez.com. We will investigate and respond to you as soon as we reasonably can. If you remain dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see www.ico.org.uk
