Privacy, Data Protection & Cookie Policy

Glan Clwyd Isa respects your privacy and is committed to protecting your personal information.

This policy explains what personal information we collect, why we use it, who we may share it with, how long we keep it, your rights in relation to your personal information, and how we use cookies and similar technologies on our website.

Privacy & Data Protection

Who We Are

For the purposes of UK data protection law, Glan Clwyd Isa is responsible for the personal information described in this policy.

If you have any questions about this policy or the way we use your personal information, please contact us using the contact details provided on our website.

Information We Collect

When you make an enquiry, make or manage a booking, contact us or stay at Glan Clwyd Isa, we may collect information including:

• your name;
• postal address;
• email address;
• telephone number;
• booking and accommodation details;
• arrival and departure dates;
• the number of adults and children included in your booking;
• payment and transaction information;
• correspondence and communications relating to your booking;
• information you choose to provide when contacting us; and
• records of safety acknowledgements completed in connection with facilities such as the swimming pool or hot tubs.

We do not routinely request the names of children included in a booking.

Where you choose to provide information concerning accessibility or health requirements, we will only use that information where necessary to respond to your request, assess the suitability of our accommodation or facilities, or make appropriate arrangements.

How We Collect Your Information

We may collect personal information when you:

• make a booking through our website or SuperControl;
• make an enquiry through our website;
• contact us by email, telephone or another communication method;
• use the SuperControl Guest Login or booking portal;
• make a payment;
• complete a safety or risk acknowledgement; or
• stay at Glan Clwyd Isa.

We may also collect images through CCTV operating at Glan Clwyd Isa for security, crime prevention and the protection of guests, visitors, property and the estate.

Why We Use Your Information

We use personal information where necessary to:

• respond to enquiries;
• process, administer and manage accommodation bookings;
• take and record payments;
• communicate with guests before, during and after their stay;
• provide access to our Guest Login and booking services;
• provide information necessary for your stay;
• manage safety requirements and guest acknowledgements;
• maintain appropriate financial and accounting records;
• protect our property, guests and business;
• prevent and investigate fraud, crime or misuse;
• establish, exercise or defend legal claims; and
• comply with our legal, tax, accounting and regulatory obligations.

Our Lawful Bases for Using Personal Information

Depending upon the circumstances, we process personal information because:

• it is necessary to take steps at your request before entering into a contract or to perform our accommodation contract with you;
• we are required to process the information to comply with a legal obligation;
• it is necessary for our legitimate interests, or those of another person, where those interests are not overridden by your data protection rights; or
• you have provided consent where consent is required.

Our legitimate interests may include operating and protecting our holiday accommodation business, maintaining appropriate business records, protecting our property and guests, preventing fraud and crime, and dealing with disputes or legal claims.

Where we need to process particularly sensitive personal information, such as health information voluntarily provided in connection with an accessibility requirement, we will only do so where an appropriate additional legal condition applies.

Booking and Payment Providers

We use SuperControl to administer accommodation bookings and provide our online booking and Guest Login facilities.

Card payments are currently processed using HolidayRentPayment and associated payment services.

We do not normally receive or retain complete payment-card details ourselves where those details are processed securely by our payment providers.

We may change or introduce payment providers from time to time. Where we do so, this policy will be updated where appropriate.

Accounting

We use QuickBooks for accounting and financial record keeping.

Relevant booking, customer, payment and transaction information may therefore be processed through our accounting records.

Our accountant may have access to information contained within those records where necessary to provide accounting, tax or related professional services.

Email and Website Enquiries

We use Gmail for business email communications.

If you contact us through our website, information submitted through the enquiry or contact form will be used to respond to your enquiry and may subsequently form part of your booking or correspondence record.

Safety Acknowledgements

Where guests are required to complete swimming pool, hot tub or other safety acknowledgements, these may be processed and retained through a separate electronic waiver or acknowledgement service.

The information is used to maintain a record that relevant safety information and rules have been provided and acknowledged.

CCTV

CCTV operates at Glan Clwyd Isa for security, crime prevention and the protection of guests, visitors, property and the estate.

CCTV footage may contain images of guests, visitors, vehicles or other identifiable individuals.

Access to CCTV recordings is restricted and recordings will only be used for legitimate security and safety purposes or disclosed where reasonably necessary, including to law-enforcement authorities, insurers or professional advisers where appropriate.

CCTV recordings are normally retained for up to 30 days, after which they are automatically overwritten or deleted.

Relevant footage may be retained for longer where this is reasonably necessary in connection with a particular incident, crime, investigation, insurance matter, complaint or legal claim. Any footage retained for such a purpose will be kept only for as long as reasonably necessary.

Further information about our CCTV arrangements is available on request.

Who We Share Information With

Where necessary, personal information may be shared with organisations which provide services to us, including:

• SuperControl;
• payment-processing providers;
• QuickBooks and accounting service providers;
• our accountant and other professional advisers;
• our email and website service providers;
• our electronic safety-acknowledgement provider;
• IT, website and technical service providers;
• insurers; and
• law-enforcement authorities, courts, regulators or other authorities where required or permitted by law.

Our cleaners do not routinely receive guest names, addresses, telephone numbers or other personal contact information.

We do not sell guest personal information.

Marketing

We do not currently operate a regular promotional email or newsletter mailing list for previous guests.

If we introduce email marketing in the future, we will ensure that personal information is used for that purpose in accordance with applicable data protection and electronic marketing requirements and that appropriate unsubscribe options are provided.

Wi-Fi

Wi-Fi is provided to guests as part of their stay.

Glan Clwyd Isa does not routinely maintain its own records identifying individual guests or devices from their use of the guest Wi-Fi.

The operation of the network or equipment may nevertheless involve technical information being processed automatically by the relevant equipment or service providers.

How Long We Keep Your Information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected and to meet our legal, accounting, tax, contractual and regulatory obligations.

Different types of information may therefore be retained for different periods.

Booking and financial records may need to be retained after a stay has ended for accounting, tax, legal and record-keeping purposes.

Enquiry information which does not result in a booking will not be retained indefinitely where there is no continuing business or legal reason to keep it.

CCTV recordings are normally retained for up to 30 days and are then automatically overwritten or deleted. Relevant footage may be retained for longer where reasonably necessary in connection with an incident, investigation, insurance matter, complaint or legal claim.

We periodically review the personal information we hold and delete or anonymise information which we no longer reasonably require.

Keeping Your Information Secure

We take reasonable technical and organisational measures to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

Access to personal information is limited to people who reasonably require it for the operation, administration or professional support of the business.

Your Data Protection Rights

Depending upon the circumstances, data protection law may give you rights including the right to:

• request access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to erase personal information in certain circumstances;
• ask us to restrict the use of your information in certain circumstances;
• object to certain uses of your personal information;
• receive certain information in a portable format where applicable; and
• withdraw consent where we rely upon consent to process your information.

These rights are not absolute and some information may need to be retained where we have a legal or legitimate reason to do so.

If you wish to exercise a data protection right, please contact Glan Clwyd Isa using the contact details provided on our website.

Complaints

If you have concerns about how we use your personal information, please contact us first so that we can investigate and respond.

You also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK’s independent data protection regulator.

Cookie Policy

Our website uses cookies and similar technologies to help the website operate, provide online booking functionality, understand how the website is used and, where applicable, remember visitor preferences.

A cookie is a small file or piece of information stored on or accessed from your device when you visit a website.

Types of Cookies and Similar Technologies We May Use

• Strictly necessary cookies. These are required for the website or a service you have requested to function correctly. They may include cookies used for security, booking functionality, remembering cookie choices or accessing secure areas of the website. Where the law permits, these technologies may be used without consent because they are necessary to provide the requested service.
• Analytics and statistical technologies. These help us understand how visitors use our website, such as which pages are visited and how visitors navigate the site. This information helps us monitor and improve the performance of the website. These technologies will only be used in accordance with applicable consent requirements or legal exceptions.
• Functionality technologies. These may allow the website to remember choices or preferences and provide additional functionality. We will use these technologies in accordance with applicable consent requirements or legal exceptions.
• Advertising and targeting cookies. Where these are used, they may help measure advertising or make advertising more relevant. Cookies or similar technologies used for advertising or tracking purposes will not be set unless the required consent has been obtained.

SuperControl

We use SuperControl to provide online availability, booking and Guest Login functionality. SuperControl may use cookies or similar technologies where necessary to provide these services.

Google Analytics

We may use Google Analytics to help us understand how visitors use the Glan Clwyd Isa website. This can include information about visits to the website, pages viewed and how visitors navigate the site.

Google Analytics and any associated technologies will be used in accordance with applicable privacy and cookie requirements and the choices available through our cookie controls.

Other Third-Party Services

Some features of our website may be provided by third parties and may use cookies or similar technologies.

Where consent is legally required for these technologies, they should not be activated until the appropriate consent has been obtained.

Your Cookie Choices

Where consent is required, you can choose whether to allow non-essential cookies through the cookie controls provided on our website.

Rejecting non-essential cookies will not prevent you from accessing the main content of our website, although some optional features may not function in the same way.

You can also control or delete cookies using your browser settings. Blocking all cookies, including cookies which are necessary for website or booking functionality, may affect the operation of parts of the website.

You can change or withdraw your cookie choices using the cookie settings available on our website.

Changes to This Policy

We may update this Privacy, Data Protection & Cookie Policy from time to time to reflect changes in our business, service providers, technology or legal requirements.

The latest version will be published on our website.