Privacy Policy

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.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

 

Definitions

Service – Service means the website and the Holiday Swap mobile application operated by Holiday Swapping Limited

Personal Data – 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 – 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 – Cookies are small pieces of data stored on your device (computer or mobile device).

Data Controller – 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. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers) – 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 (or User) – 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

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • First name and last name
  • Phone number
  • Address, State, Province, ZIP/Postal code, City
  • Cookies and Usage Data

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.

Usage Data

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.

Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customise our Service.

You can enable or disable location services when you use our Service at any time, through your device settings.

 

Use of Data

Holiday Swapping Limited uses the collected data for various purposes:

  • To provide and maintain our Service
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or valuable information so that we can improve our Service
  • To monitor the usage of our Service
  • To detect, prevent and address technical issues
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

 

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Holiday Swapping Limited legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Holiday Swapping Limited may process your Personal Data because:

  • We need to perform a contract with you
  • You have given us permission to do so
  • The processing is in our legitimate interests and it’s not overridden by your rights
  • For payment processing purposes
  • To comply with the law

 

Retention of Data

Holiday Swapping Limited will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

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.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Holiday Swapping Limited will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

 

Disclosure Of Data

Disclosure for Law Enforcement

Under certain circumstances, Holiday Swapping Limited may be required 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).

Legal Requirements

Holiday Swapping Limited may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Holiday Swapping Limited
  • To prevent or investigate possible wrongdoing in connection with the Service
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

 

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{7f9a97d6b4d21eb819e72ecc2f40976d17ee585ed5314a6eca7285c24650def5} 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:

  • The right to access, update or to delete the information we have on you.Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
  • The right of rectification.You have the right to have your information rectified if that information is inaccurate or incomplete.
  • The right to object.You have the right to object to our processing of your Personal Data.
  • The right of restriction.You have the right to request that we restrict the processing of your personal information.
  • The right to data portability.You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent.You also have the right to withdraw your consent at any time where Holiday Swapping Limited relied on your consent to process your personal information.

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).

 

Service Providers

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 analysing 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.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

  • Google Analytics – 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 contextualise and personalise 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 – Firebase is analytics service provided by Google Inc.You may opt-out of certain Firebase features through your mobile device settings, such as your device advertising settings or by following the instructions provided by Google in their Privacy Policy: http://www.google.com/intl/en/policies/privacy/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/
Payments

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).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

 

Links To Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

 

Children’s Privacy

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.

 

Changes To This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this Privacy Policy, please contact us:

 

Who are we?

We are Holiday Swapping Limited. You can contact us at info@holidayswap.com. 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.