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Vaboo Privacy Policy

Last Updated 24 October 2018

We respect the privacy of every person who:

1. visits vaboo.co.uk;

2. administers a Vaboo “Parent Account”; or

3. registers for the Vaboo services via a Vaboo “Child Account” i.e. via a sub account which is associated with the relevant Parent Account,

(the “Sites”) and who uses the services that we make available from the Sites (our “Services”) and we are committed to ensuring a safe online experience.

1. Purpose of this Policy

This privacy policy (“Privacy Policy”) explains our approach to any personal information that we might collect from you or which we have obtained about you from a third party and the purposes for which we process your personal information. This Privacy Policy also sets out your rights in respect of our processing of your personal information.

This Privacy Policy will inform you of the nature of the personal information about you that is processed by us and how you can request that we delete, update, transfer it and/or provide you with access to it.

This Privacy Policy is intended to assist you in making informed decisions when using the Sites and our Services. Please take a moment to read and understand it. Please note that it should be read in conjunction with our Website Terms of Use.

Please also note that this Privacy Policy only applies to the use of your personal information obtained by us, it does not apply to your personal information collected during your communications with third parties.

2. Who are we and what do we do?

The Sites and our Services are operated by Vaboo Limited, (“we”, “us” or “our”).

Vaboo Limited is the data controller responsible for your personal information.

Vaboo Limited is an English company with registered company number 09521467 and whose registered office is at Avaland House, London Road, Hemel Hempstead, Hertfordshire, United Kingdom, HP3 9SD.

3. How to contact us?

If you have any questions about this Privacy Policy or want to exercise your rights set out in this Privacy Policy, please contact us by:

• sending an e-mail to info@vaboo.co.uk; or

• calling us on: +44 3450 523 957

4. What personal information do we collect and how do we use it?

Our primary goal in collecting personal information from you is to: (i) verify your identity; (ii) help us improve our products and services and develop and market new products and services; (iii) carry out requests made by you on the Sites; (iv) investigate or settle inquiries or disputes; (v) comply with any applicable law, court order, other judicial process, or the requirements of a regulator; (vi) enforce our agreements with you; (vii) protect the rights, property or safety of us or third parties, including our other customers and users of the Sites and at our stores; (viii) provide support for the provision of our Services; and (ix) use as otherwise required or permitted by law.

In particular, we use your personal information for the following purposes:

• Providing you with the Services via the Sites.

In order to enable us to set up your account on our Website and provide our Services to you via our Website, we have been provided with certain personal data by either your letting agent [or the partner organisation which has offered you access to our Services and Rewards (the “Rewards Partner”) has provided us with certain personal data including your name & email address based on your legitimate interest. We also collect certain other personal information about you and explain our legal basis to do so, as described further in this privacy policy.

We collect and maintain personal information that you voluntarily submit to us when completing your account registration online and during your use of the Sites and/or our Services. We use the contact and payment details you have provided to us so that we can provide you with the relevant services that you have chosen to subscribe to (for example ‘Reward Gateway’).

Who do we share your personal information with for this purpose?

We will share your personal information with the following categories of third parties:

• Online card payments - credit card companies and other payment providers.

What is our legal basis?

It is necessary for us to use your personal information to perform our obligations in accordance with any contract that we may have with you.

• Customer services.

Contact information will be requested if you make customer service enquiries together with details of other personal information that is relevant to your customer service enquiry. This information is used in order to enable us to respond to your requests, enquiries and complaints if you have any.

Who do we share your personal information with for this purpose?

We do not share your personal information for this purpose.

What is our legal basis?

It is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best customer service we can to you.

• Customer insight, analysis and surveys.

We analyse your contact details with other personal information that we observe about you from your interactions with our Sites, such as the discount offers you avail of from time to time.

We also circulate surveys via email from time to time, principally to our tenant users who have registered with our Sites. We use any personal information to compile feedback reports which we provide to the relevant accommodation provider. However these reports do not contain any personal data as they only provide the accommodation provider with aggregated and anonymised insights.

Where you have given your consent (where lawfully required), we use cookies, log files and other technologies to collect personal information from the computer hardware and software you use to access the Sites, or from your mobile. This information is used to create profiles and insights about which offers you are most interested in.

Please see our cookie policy for further information.

We also use this information to help us with the selection of discount offers and service lines.

Who do we share your personal information with for these purposes?

We share your personal information with a variety of third party service providers to assist us with customer insight analytics. We may also from time to time, share with our clients who gave you access to our platform.

What is our legal basis?

Where your personal information is completely anonymised, we do not require a legal basis to use it as the information will no longer constitute personal information that is regulated under data protection laws. However, our collection and use of such anonymised personal information may be subject to other laws where your consent is required. Please see our Cookie Policy for further details.

Where your personal information is not in an anonymous form, it is in our legitimate interest to use your personal information in such a way to ensure that we provide the very best products and services to you and our other customers or the relevant accommodation provider.

• Marketing communications from third party discount providers.

The very nature of our Site means that we make available third party discount offers to many of our customers. We never share your personal information with these third parties. However we often send details of discount offers to our users via email – which could be categorised as a marketing communication.

We use information that we observe about you from your interactions with our Sites, and/or with our Services (see the Customer Insight and Analysis section above for more details of the information collected and how it is collected) to provide you with personalised discount offers.

Who do we share your personal information with for these purposes?

We do not share your personal information for this purpose.

What is our legal basis?

We rely on your consent to send you information on discount offers that may be of interest to you via email.

• Business administration and legal compliance.

We use your personal information for the following business administration and legal compliance purposes:

• to comply with our legal obligations;

• to enforce our legal rights;

• protect rights of third parties; and

• in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.

Who do we share your personal information with for these purposes?

We will share your personal information with professional advisers such as lawyers and accountants and/or governmental or regulatory authorities.

What is our legal basis?

Where we use your personal information in connection with a business transition, enforce our legal rights, or to protect the rights of third parties it is in our legitimate interest to do so. For all other purposes described in this section, it is our legal obligation to use your personal information to comply with any legal obligations imposed upon us such as a court order.

Where we share your sensitive personal information, we shall obtain your consent to do so.

Any other purposes for which we wish to use your personal information that are not listed above, or any other changes we propose to make to the existing purposes will be notified to you using your contact details.

5. How do we obtain your consent?

Where our use of your personal information requires your consent, you can provide such consent at the time we collect your personal information following the instructions provided.

6. Our use of cookies and similar technologies

Our Sites use certain cookies, pixels, beacons, log files and other technologies of which you should be aware. Please see our Cookie Policy to find out more about the cookies we use and how to manage and delete cookies.

7. Third Party Links and Services

Our Sites contains links to third party websites and services. Please remember that when you use a link to go from our Sites to another website or you request a service from a third party, this Privacy Policy no longer applies.

Your browsing and interaction on any other websites, or your dealings with any other third party service provider, is subject to that website’s or third party service provider’s own rules and policies.

We do not monitor, control, or endorse the privacy practices of any third parties.

We encourage you to become familiar with the privacy practices of every website you visit or third party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.

This Privacy Policy applies solely to personal information collected by us through our Service and does not apply to these third party websites and third party service providers.

8. How long do we keep your personal information for?

We keep your personal information for a period of 3 years from the date of our last interaction with you.

If your information is only useful for a short period e.g. for specific marketing campaigns we may delete it.

9. Confidentiality and security of your personal information

We are committed to keeping the personal information you provide to us secure and we will take reasonable precautions to protect your personal information from loss, misuse or alteration.

We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:

• unauthorised access;
• improper use or disclosure;
• unauthorised modification; and
• unlawful destruction or accidental loss.

All of our employees and data processors (i.e. those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of our Services.

10. How to access your information and your other rights?

You have the following rights in relation to the personal information we hold about you:

• Your right of access.

If you ask us, we’ll confirm whether we’re processing your personal information and, if so, provide you with a copy of that personal information (along with certain other details). If you require additional copies, we may need to charge a reasonable fee.

• Your right to rectification.

If the personal information we hold about you is inaccurate or incomplete, you’re entitled to have it rectified. If we’ve shared your personal information with others, we’ll let them know about the rectification where possible. If you ask us, where possible and lawful to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to erasure.

You can ask us to delete or remove your personal information in some circumstances such as where we no longer need it or if you withdraw your consent (where applicable). If we’ve shared your personal information with others, we’ll let them know about the erasure where possible. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to restrict processing.

You can ask us to ‘block’ or suppress the processing of your personal information in certain circumstances such as where you contest the accuracy of that personal information or you object to us processing it. It won’t stop us from storing your personal information though. We’ll tell you before we lift any restriction. If we’ve shared your personal information with others, we’ll let them know about the restriction where it is possible for us to do so. If you ask us, where it is possible and lawful for us to do so, we’ll also tell you who we’ve shared your personal information with so that you can contact them directly.

• Your right to data portability.

With effect from 25 May 2018, you have the right, in certain circumstances, to obtain personal information you’ve provided us with (in a structured, commonly used and machine readable format) and to reuse it elsewhere or to ask us to transfer this to a third party of your choice.

• Your right to object.

You can ask us to stop processing your personal information, and we will do so, if we are:

• relying on our own or someone else’s legitimate interests to process your personal information, except if we can demonstrate compelling legal grounds for the processing; or

• processing your personal information for direct marketing.

• Your rights in relation to automated decision-making and profiling.

You have the right not to be subject to a decision when it’s based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of, a contract between you and us.

• Your right to withdraw consent.

If we rely on your consent (or explicit consent) as our legal basis for processing your personal information, you have the right to withdraw that consent at any time.

• Your right to lodge a complaint with the supervisory authority.

If you have a concern about any aspect of our privacy practices, including the way we’ve handled your personal information, you can report it to the UK Information Commissioner’s Office (ICO). You can find details about how to do this on the ICO website at https://ico.org.uk/concerns/ or by calling their helpline on 0303 123 1113.

11. Credit and debit card details

Please note that we do not collect or process your credit or debit card details. These are however collected and processed by our payment processing service provider Stripe Payments Europe, Ltd (“Stripe”). The collection and processing by these providers of your credit or debit card details and other personal data are governed by their respective terms and conditions. See https://stripe.com/gb/privacy for more information. Stripe may from time to time provide us with information regarding the credits and debits made to your card in order to enable us to reconcile our accounts.

12. Changes to this Privacy Policy

We may make changes to this Privacy Policy from time to time.

To ensure that you are always aware of how we use your personal information we will update this Privacy Policy from time to time to reflect any changes to our use of your personal information. We may also make changes as required to comply with changes in applicable law or regulatory requirements. We will notify you by e-mail of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal information.