Elegant Resorts Limited ("we") are committed to protecting and respecting your privacy.
SCOPE OF POLICY
This policy (together with the application terms and conditions as set out at https://www.elegantresorts.co.uk/information/travel-app-terms-and-conditions ("App T&Cs") and any additional terms of use incorporated by reference into the App T&Cs, together our Terms of Use) applies to your use of:
- Elegant Resorts Travel App mobile application software ("App") hosted on eUKhost Web Services ("App Site"), once you have downloaded or streamed a copy of the App onto your mobile telephone or handheld device ("Device").
- Any of the services accessible through the App ("Services") that are available on the App Site.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the Data Protection Act 1998, the data controller is Elegant Resorts Limited of Elegant House Sandpiper Way, Chester Business Park, Chester, CH4 9QE.
Please note that we have separate privacy policies that apply to your use of any of our websites. This particular policy applies only to your use of the App and the Services.
INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following data about you:
- Information you give us (Submitted information): You may give us information about you by filling in forms on the App Site or in the App itself. This includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service and when you report a problem with an App or our Services. The information you give us may include your name, address, e-mail address and phone number, the Device's phone number, age, username, password and other registration information and personal description.
- Information we collect about you and your device: Each time you visit or use our App we may automatically collect the following information:
- technical information, including the type of mobile device you use, a unique device identifier (for example, your Device's IMEI number, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use or time zone setting ("Device Information");
- information stored on your Device, including login information or other digital content ("Content Information");
- details of your use of any of our Apps and the resources that you access ("Log Information").
- details of your use of any of our Apps and the resources that you access ("Log Information").
- Location information: We may also use GPS technology to collect location data to display the personalized assistance notification features, even when the app is closed and not in use. . This option can be changed later by going into the device settings. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by emailing [email protected].
- Information we receive from other sources (Third Party Information): We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
- If you contact us, We may keep a record of that correspondence.
- Unique application numbers: when you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
Information you give us:
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you, in the resort where you have booked your holiday.
- to notify you about changes to our Services
- to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about.
Information we collect about you and your device:
- to ensure that content from the App is presented in the most effective manner for you and for your device;
- to administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to allow you to participate in interactive features of the App and the Services, when you choose to do so;
- as part of our efforts to keep the App safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of the App about goods or services that may interest you or them.
Location information:
- to allow you to participate in interactive features of the App and the Services, when you choose to do so;
- to make suggestions and recommendations to you and other users of the App about goods or services that may interest you or them.
Information we receive from other sources:
- We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
Unique application numbers:
- to administer the App and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to maintain, protect and improve the App and the Services.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymous aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers' wishes by displaying their advertisement to that target audience.
DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006.
We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
- If Elegant Resorts Limited or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
In order to:
- enforce or apply the App T&Cs, Our Booking Terms and Conditions https://www.elegantresorts.co.uk/information/booking-conditions and other agreements or to investigate potential breaches; or
- protect the rights, property or safety of Elegant Resorts Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you will be stored at, a destination within the European Economic Area (EEA). It will also be processed by staff operating inside the EEA who work for us or for one of our suppliers. In addition, your data is accessible by support personnel at mTrip, our data processor, who are the authors of our Travel App. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
Unfortunately, the transmission of information via the internet is not completely secure. Although We will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via the App or App Site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML 5) and other technology.
OUR DATA PROCESSOR
Our Data Processor and authors of the Travel App software are mTrip based in Canada. Your data is held within the European Economic Area (EAA) but can be accessed by support personnel at mTrip for the purposes solely of providing support as and when necessary.
YOUR RIGHTS
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at Elegant House Sandpiper Way, Chester Business Park, Chester, CH4 9QE or [email protected].
The App may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which the App or the Services are advertised). If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. Please check these policies before you submit any personal data to these websites or use these services.
ACCESS TO INFORMATION
The Data Protection Act 1998 gives you the right to access information held about you. Your right of access can be exercised in accordance with that Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information We hold about you.
CHANGES TO PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you when you next start the App. The new terms may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Services.
CONTACT
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Elegant House Sandpiper Way, Chester Business Park, Chester, CH4 9QE or [email protected].