Brightwater Holidays Limited (“we”) are committed to protecting and respecting your privacy.

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. By visiting https://www.brightwaterholidays.com you are accepting and consenting to the practices described in this policy.

For the purpose of the Data Protection Act 1998 and all applicable laws and regulations relating to the processing of personal data and privacy, including the General Data Protection Regulation ((EU) 2016/679) (the “Data Protection Legislation”), the data controller is Brightwater Holidays Limited Eden Park House Cupar KY15 4HS

The Data Protection Principles

We comply with the principles of data protection law. This says that the personal information we hold about you must be:

1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date, and you can inform us at anytime of inaccuracies.
5. Kept only as long as necessary for the purposes we have told you about.
6. Processed in a manner that ensures appropriate security of the personal data, using appropriate technical or organisational measures.

Information we collect from you

We will collect and process the following data about you:

Information you give us

This is information about you that you give us by filling in booking forms on our site www.brightwaterholidays.com or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our site, subscribe to our service, search for a product or service, make a booking on our site, enter a competition, promotion or survey, request a brochure on our site, sign-up to our email newsletter and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information.

Information we collect about you

With regard to each of your visits to our site we will automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

Information we receive from other sources

This is information we receive about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on this site. We will also have told you for what purpose we will share and combine your data. 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). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Special category personal data

We may ask you to provide certain information relating to your health, including any medical conditions, in order to determine whether such health issues may affect the product or service you are interested in. We will only process such data where you have provided your explicit consent to us doing so.

Uses made of the information

We use information held about you in the following ways:

Information you give to us. We will use this information:

• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• 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;
• Interrupted or incomplete online booking process (abandoned cart)
  When you are booking online but for some reason are not able to complete the booking process, we may process your Personal Data for the purpose of enabling you to easily continue the online booking process, for example if you experienced technical difficulties. We may do this by contacting you via phone or email.
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer
• to enable trusted external partners (including digital marketing agencies and social media platform operators) to identify relevant audiences for our marketing activities. Our trusted external partners may have access to the personal information needed to perform their functions, but may not use it for other purposes.

If we intend to use this information for any other purpose, we will let you know what we intend to do with such data and the legal basis we are relying on for processing such data. This may include obtaining your express consent.

Information we collect about you. We will use this information:

• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of our service, when you choose to do so;
• as part of our efforts to keep our site 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 our site about goods or services that may interest you or them;
• to enable trusted external partners (including digital marketing agencies and social media platform operators) to identify relevant audiences for our marketing activities. Our trusted external partners may have access to the personal information needed to perform their functions, but may not use it for other purposes;
• we may share non-personal aggregate statistics about visitors to this site and traffic patterns with other parties.

Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

Disclosure of your information

You agree that we have the right to share your personal information with:

• 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.
• Selected third parties including:

1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with you;
2. analytics and search engine providers that assist us in the improvement and optimisation of our site;
3. credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you;
4. trusted external partners (including digital marketing agencies and social media platform operators including Facebook, Twitter, ResponseIQ, Live Chat Inc, MailChimp) to identify relevant audiences for our marketing activities. Our trusted external partners may have access to the personal information needed to perform their functions, but may not use it for other purposes.

We may disclose your personal information to third parties if we are under a duty to do so in order to comply with any legal obligation, or to protect the rights, property, or safety of Brightwater Holidays Limited, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction. We will inform you if we need to disclose your personal data for such purpose.

Where we store your personal data

The data that we collect from you will be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). It will also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order, 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.

All information you provide to us is stored on our secure servers. Any payment transactions will be securely encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

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 to our 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.

How Long We Keep Your Data For

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

In addition to the above, by law we have to keep basic information about our guests (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being guests for tax purposes.

In some circumstances you can ask us to delete your data: see “Your rights” below for further information.

In some circumstances we will 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.

Your rights

Under the Data Protection Legislation:

• Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at info@brightwaterholidays.com [or by clicking the unsubscribe link at the bottom of any marketing email that we send to you];
• You can ask us to rectify any inaccuracies in the personal information that we hold about you.
• You may have the right to request the erasure of personal information that we hold about you.
• You may have the right to object to our processing of your personal data for certain purposes, including for direct marketing purposes, for scientific or historical research purposes or statistical purposes.
• You may have the right to restrict our processing of your personal data in certain circumstances.
• You may have the right to request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller,
• You may have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
• You can exercise any of the above rights at any time by contacting us at Eden Park House Cupar KY15 4HS or info@brightwaterholidays.com.

Links to and from our site

Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Access to information

The Data Protection Legislation gives you the right to access information held about you. Your right of access can be exercised in accordance with the Data Protection Legislation. You may request details or a copy of the personal data that we hold about you by writing to us at Eden Park House Cupar KY15 4HS.

Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.

Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests.

We may also use or allow third parties to serve cookies on our site that fall into one or more of the four categories above. For example, like many companies, we use Google Analytics and Google Tag Manager to help us monitor our website traffic. We may also use third party cookies to help us with market research, revenue tracking, and to help us to improve site functionality.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Brightwater Holidays utilises Force24’s marketing automation platform.

Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:

• F24_autoID
  • F24_personID

They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.

f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months. Non-essential, first party, 10 years, persistent.

f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.The information stored by Force24 cookies remains anonymous until:

• Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
  • A user of the website completes a form containing email address from either our website or our Force24 landing pages.

The Force24 cookies will remain on a device for 10 years unless they are deleted.

How to manage your cookie settings
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. The links below explain how you can control cookies via your internet browser.

Chrome
Firefox
Safari

For more information about deleting cookies using alternative browsers, and comprehensive information on cookies, we recommend visiting allaboutcookies.org.

Other Tracking
We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities

Device & browser type and open statistics
All emails have a tracking pixel (a tiny invisible image) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.

Link Tracking
All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Eden Park House Cupar KY15 4HS or info@brightwaterholidays.com.

If you have any complaints relating to our privacy policy or our use of your personal data, please contact us at Eden Park House Cupar KY15 4HS or info@brightwaterholidays.com. You also have the right to make a complaint to the Information Commissioner’s Office. Further information can be found at https://ico.org.uk/.