Effective date: May 19, 2018
Holiday Swapping Limited ("us", "we", or "our") operates the website and the Holiday Swap mobile application (the "Service").
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
Service means the website and the Holiday Swap mobile application operated by Holiday Swapping Limited
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Information Collection And Use
We collect several different types of information for various purposes to provide and improve our Service to you.
Types of Data Collected
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact oridentify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device ("Usage Data").
This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
We may use and store information about your location if you give uspermission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.
You can enable or disable location services when you use our Service at any time, through your device settings.
Tracking & Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Use of Data
Holiday Swapping Limited uses the collected data for various purposes:
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Holiday Swapping Limited may process your Personal Data because:
Retention of Data
Holiday Swapping Limited will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United Kingdom and choose to provide information to us, please note that we transfer the data, including Personal Data, to United Kingdom and process it there.
Disclosure Of Data
Disclosure for Law Enforcement
Under certain circumstances, Holiday Swapping Limited may berequired to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Holiday Swapping Limited may disclose your Personal Data in the good faith belief that such action is necessary to:
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights Under GeneralData Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Holiday Swapping Limited aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/
Firebase is analytics service provided by Google Inc.
We also encourage you to review the Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245. For more information on what type of information Firebase collects, please visit please visit the Google Privacy & Terms web page:http://www.google.com/intl/en/policies/privacy/
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g.payment processors).
The payment processors we work with are:
Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 ("Children").
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Who are we?
We are Holiday Swapping Limited. You can contact us at firstname.lastname@example.org. Other contact details are on our website.
What’s the point of this policy?
It tells you what to expect when we collect your personal information. Please only use our service if you are completely happy with this policy.
Generally, the policy covers only information provided to us. If you give personal information to other people, such as payment providers or other websites, please check their privacy policies.
Might the policy change?
Yes. If so, we will notify you by SMS / email / in-app message or otherwise. We will assume you agree if you carry on using the app afterwards.
Why do we need the information?
To provide you with our services in line with our contract with you and/or for other purposes (such as marketing) if you agree.
What do we collect?
Information which you give us via forms - such as your name, photo and contact details - or when you communicate with us in some other way.
Automated information such as the internet protocol (IP) address used to connect your device to the internet, connection information such as browser type and version, information about your device including device-type and device identifier, operating system and platform, mobile network data, a unique reference number linked to the data you enter on our system, login details, clickstream data, details of your activity with date / time stamps including pages you visited and your searches / transactions.
If you log in via Facebook: Information from your public Facebook profile including your name, profile photo and date of birth.
What do we do with personal information?
Provide our service, e.g. send service messages, process payments, fulfil orders.
Send you marketing messages, if you have given permission. You can withdraw permission at any time as explained on our service or by emailing us at the above email address.
Use it to recognise you when you visit or return to our service to track anonymised traffic and usage patterns, prevent or detect fraud or abuses and help us improve our service.
If you supply us with someone else’s email address for a “Refer A Friend” or similar offer, to send a referral message to that person and we will then immediately delete it.
How long do we keep it?
Generally, for six years after your account is closed - to help deal with any disputes. That timeframe may vary if we are legally required to keep information for a particular period. We will keep your information which we use for marketing until you tell us that you no longer wish to receive marketing messages.
To whom do we send or make available your personal information?
To other people who supply us with a service, e.g. e-commerce platform providers, website hosts, content delivery networks and businesses which help us send communications or monitor our website.
To other users of our service, if you enter information into a public profile or otherwise include it in a post, comment or other public action on our service.
To the relevant authorities or complainants, if we think the personal information breaches our terms and conditions, or it is necessary to protect us or others, or that a criminal act may have been committed, or we are required to do so by law or appropriate authority.
To potential buyers so far as reasonably necessary, in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business.
What happens to your payment details?
These go direct to our payment partners. We do not receive such information. To ensure your details are not being used without consent, our payment partners may send your personal information to relevant third parties including credit reference and fraud prevention agencies, who may keep a record of that information.
Do we send your information outside the European Union?
No. Your personal information which we collect is stored on servers located within the EU and is not transferred to any third countries.
What rights do you have?
To ask us for access to your personal information, to rectify it if there are mistakes, to delete or restrict or object to its use in certain circumstances or to “data portability”. (Some of these rights may not yet have come into effect.)
If you have a complaint about how we are dealing with your personal information, please contact us via the email address above. If you are not happy with our response or think we are not handling your personal information in accordance with the law, you can complain to the Information Commissioner’s Office (ICO).
For more information about your rights, visit the ICO’s website: www.ico.org.uk.