Purpose of this privacy notice.
This privacy notice aims to give you information on how Invitation to Tuscany Ltd. collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone), when you make an enquiry with us, when you make a booking of a villa, when you sign up to our newsletter, etc.
There is a lot of legal information and language on this page, essentially for us it boils down to this (but do still take the time to read the notes below):
You give us various bits of personal data in order that we can help you book a villa, or a cook, or hire a car. We can use this data to do the things you ask us to, but we can't sell it to anyone or use it in any nefarious way. If you give us sensitive data, like passport numbers, we should destroy it as soon as we no longer need it. And we can only send you newsletters if you've expressly asked us to. These are the principles that guide how we treat your data - the legal position is set out below.
This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of a villa and you have children in your party.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Invitation to Tuscany Ltd is the controller and responsible for your personal data (collectively referred to as "Invitation to", "we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Invitation to Tuscany Ltd
Name or title of data privacy manager: Daniel Wrightson
Email address: DPO@invitationtotuscany.com
Postal address: Friern Park, Unit 5, London N12 9DA
Telephone number:+44 20 8444 9500
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 15/05/2018 and historic versions can be obtained by contacting us.
The data protection law in the UK will change on 25 May 2018. We have made relevant changes to our software so that we can either anonymise you or provide you with a data dump of the information we hold on you.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(A) Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, title, date of birth and gender.
(B) Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
(C) Financial Data
This includes data relating to your means and methods of payment, such as your bank account and payment card details. All card transactions are processed and stored by a third party (SagePay) so it is unusual, but possible, that we would have card details for you.
(D) Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
(E) Technical Data
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
(F) Profile Data
This includes the data that we receive when you create a profile on our website and make use of that policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(G) Usage Data
This includes information about how you use our website, products and services.
(H) Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
Special Categories of Personal Data
We might occasionally collect the following special categories of personal data about you.
Details about your:
- dietary requirements which may disclose your religious or philosophical beliefs;
- race or ethnicity.
We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so. These details are not retained.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary date, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions 13. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
(A) Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make a booking of travel services;
- making an enquiry as to any of the services we offer;
- create an account on our website;
- subscribe to our newsletter or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
(B) Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
(C) Third parties
We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties: (i) analytics providers such as Google based outside the EU.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay based inside the EU.
- Identity and Contact Data from third party social media or communication services (e.g. Google, Facebook, LiveChat). This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data to fulfil our contract with you:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- When you, as a Guest, submit a booking request, certain information about you is shared with the manager of the property you have booked, like your full name and contact details. We might also ask for the full name of all additional Guests and their nationalities again to be shared with the manager and registered by the manager with the local authorities, and any other information you agree to share to facilitate your stay at the property you have rented, i.e. extra services such as requests for babysitting, shopping and cooks with your personal preferences as allergies.
- If you are a property owner, we may need to verify your identity, your date of birth, your address, email address, phone number and other information in order to check your identity, to provide the payment services to you, and to comply with applicable laws
- When you as a property owner have a confirmed booking, certain information is shared with the guest to coordinate the booking, such as your full name and your contact details.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
- Where, after staying at a property, you write Reviews and Ratings about the property and any wider services provided.
- If you submit a review your feedback shall be visible on our web site but your details will shown only as Initials and Abode.
Generally we do not rely on “consent” as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. All newsletters have an “Unsubscribe” button clearly visible at the bottom of the page, alternatively you have the right to withdraw consent to marketing at any time by contacting us at DPO@invitationtotuscany.com
We like to keep in touch and we like to inform you of things you might like to know about. We send regular newsletters to those of you who have opted-in at the time of booking, or while making an enquiry or by direct subscription to our mailing list.
We also sometimes send you personal emails if there is an offer on a particular property we think you might be interested in.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
We never share or sell your data for marketing purposes.
Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the third parties for the purposes of fulfilling our contract with you. All third parties are informed that your data may only be used for the purposes we have requested from them. You can request a list of our third party service providers by writing to DPO@invitationtotuscany.com
We may also have to share your information with local police and local courts, where you have booked a property with us and we are therefore under a legal obligation to do disclose your data to such parties. Similarly, we may be under a legal obligation to disclose your personal data to the local authority in the area in which you have made a booking of one of our properties, in order to facilitate the collection and remittance of Tourist Taxes by the property manager.
In special cases: third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available on request by contacting us.
In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
If you book with us we will keep your information for 6 years from the completion of your booking (in the case of adults) or 6 years from the date of your 18th birthday (in the event of any children that travel on the booking) in order to enable us to defend any legal claims that you may pursue against us. In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You may:
Request access to your personal data
Request correction of your personal data
Request erasure of your personal data
Object to processing of your personal data
Request restriction of processing of your personal data
Request transfer of your personal data
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.