Privacy Policy

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Revised: 22nd June 2020

1. Who is responsible for managing my information?

Top Villas Limited and all other websites and offline material produced in relation to it are owned and maintained by:

Top Villas Ltd
Bramling House
Bramling
Canterbury, Kent
CT3 1NB
United Kingdom

("we" or "us")

This is our privacy policy. It explains how we use, collect, protect and share your personal data. We are responsible for the collection and proper management of any personal information you submit. We will keep your personal details secure and use the information you provide consistently with applicable privacy and data protection laws and the terms of this privacy notice.

2. What information do we collect?

If you choose to make a booking through us or make enquiries about a potential booking we will collect details that you provide in relation to that booking or enquiry. Information held is likely to include your name, contact details, payment details, information about people travelling with you, information about your booking and any additional information we may need to help meet your specific requirements.

If you choose to list your vacation home with us we will collect details such as your name, contact details and details regarding the accommodation you wish to let.

We also collect website usage information using cookies and user session tracking to optimise user experience on our site. For further information about cookies and how we use them please see our Cookie Policy.

2.1. Third-party

We partner with Microsoft Clarity and Microsoft Advertising to capture how you use and interact with our website through behavioral metrics, heatmaps, and session replay to improve and market our products/services. Website usage data is captured using first and third-party cookies and other tracking technologies to determine the popularity of products/services and online activity. Additionally, we use this information for site optimization, fraud/security purposes, and advertising. For more information about how Microsoft collects and uses your data, visit the Microsoft Privacy Statement.

3. How do we use your information?

The information you provide may be used in a number of ways, for example:

to enable us to complete your booking (if you are booking a vacation home);
to enable us to advertise your vacation home, transfer payments due to you and to provide related support services (if you are letting your accommodation through us);
for statistical purposes when we evaluate our range of services;
to personalise repeat visits to our websites;
to tell you about other products and services we think may be of interest to you (see below);
to manage customer service queries; and
to help us to provide details or information you may have requested.

4. On what legal basis will we process your information?

We will always process your personal information on lawful grounds and in particular on the grounds set out below:-

Performance of a Contract

If you make a booking through us we will use the details that you give to provide that booking to you. This information is likely to include your name, contact details, payment details, information about people travelling with you, information about your booking and any additional information we may need to help meet your specific requirements.

If you let your holiday accommodation with us we will collect details such as your name, contact details, bank account details and details regarding the accommodation you wish to let to perform our agreement(s) with you.

If you do not provide us with the information set out in this paragraph, then we may not be able to provide the booking or rental services.

Legitimate Interest

We may use your name and email contact details you have given us to tell you about our own products and services which we think may be of interest to you. You can ask us to stop doing so at any time by clicking the unsubscribe link in any of our emails.

We may use some of your personal information for statistical purposes when we evaluate our range of services.

We may share your email address with Bing, Facebook, Google or other web-based advertising platforms (“Platforms”) , who act as data processors for them to use on our behalf in connection with the creation of marketing and promotion for us. This may include the Platforms using socio-demographic information about you to identify other people like you, with similar interests to present our marketing to. This socio-demographic information is not used for any other purpose nor shared with any other party. No information about other individuals identified from these Platforms is shared with us at any time.

The Platforms may also use your personal data to serve targeted advertising/content to you via their Platform. You can control what advertisements you receive via the privacy settings on the relevant platform.

We may also share your contact details with our third party review sites(s) who may contact you to ask for your comments on the accommodation and/or services that have been provided.

The above are done on the basis that they are in the legitimate interest of our company.

Consent

We may ask your consent to use your name, SMS, phone number(s) and postal address to tell you about our own products and services which we think may be of interest to you.

We may also ask your consent to share your name and contact details with selected third parties companies so that they can tell you about their products and services.

If you agree, we may also pass on your information, in certain cases, for the purposes of conducting a credit check.

You can withdraw your consent at any time.

Legal Obligation

We may also disclose your personal data without your permission to the extent that we are required to do so by law or regulation.

5. Who will you share my information with?

We may share your information with:

other sections of Top Villas Ltd and their service providers (see also section 7 below);
owners of or agents for villas, apartments and townhouses (if you are making an accommodation booking);
individuals who may be renting accommodation from you (if you are a holiday accommodation owner or advertiser);
credit/debit card companies;
our preferred insurance provider(s) (if you purchase travel insurance); and
other third parties who we may need to work with to deliver services or fulfil travel plans on your behalf, for example, resorts, management companies, owners’ associations, car hire companies and other suppliers;
Platforms as set out in ‘4’ above;
Other third parties with your consent as set out above.

We may also disclose your personal data without your permission in connection with any legal proceedings or prospective legal proceedings, and in order to establish, exercise or defend our legal rights.

6. How do you manage my information?

We may from time to time appoint third-party service providers to help us manage efficient systems within the business. Some of these systems may for operational reasons be located in countries overseas including the USA.

We will only transfer your information to service providers who help manage our systems, or overseas, where we are satisfied that this is lawful and that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy laws.

If we transfer your personal data to the USA then we will always use a lawful method to do so which may be either the “Privacy Shield” Programme or an agreement in a form approved by the European Commission.

7. Updating Your Details?

If you would like to change any of your preferences relating to the way in which we may use your information for direct marketing, then please update your user preferences or send an email to [email protected] or contact us at Top Villas Ltd, Bramling House, Bramling, Canterbury, Kent, CT3 1NB, United Kingdom. Alternatively you can call us on: 0800 4334567.

8. How long will we hold your information for?

We have a system of retention periods in place to ensure that your information is only stored whilst it is required for the relevant purposes or to meet legal requirements. Where your information is no longer required, we will ensure it is disposed of or deleted in a secure manner.

9. Your rights

You have the right to ask us at any time:

to confirm whether we hold any of your personal data;
to send you a copy of any personal data that we hold about you;
to correct any inaccuracies in your personal data and to add relevant details where the personal data we hold is incomplete;
to delete (to the extent possible) any of your personal data, where we are required by law to do so;
to stop processing your personal data, where we are required by law to do so;
to let you have a portable copy of the personal data we hold about you, where we are required by law to do so;
to stop processing any of your personal data that we process on the basis of our legitimate interests; and
to stop sending you marketing material. However please note that we may continue to send you service related (i.e. non-marketing) communications, such as email updates

Where we have reached a decision that affects you by processing your personal data automatically then you have the right to speak to someone to discuss that decision.

Where we process your personal data on the basis that you have given us your consent to do so then you may contact us at any time to withdraw your consent

If you wish to exercise any of these rights, or wish to object to our use of your personal information, please write to us at the address given below.

Data Protection Co-ordinator, Top Villas Ltd, Bramling House, Bramling, Canterbury, Kent, CT3 1NB, United Kingdom.

Or by email to: [email protected]

10. Does the notice apply to linked websites?

Our websites may contain links to other websites. This privacy notice only applies to this website so when you click links to other websites you should read their own privacy notices.

11. When do you monitor telephone calls?

We may from time to time record telephone calls you have with our staff for training purposes and to improve the quality of our service.

12. How do we update this privacy notice?

We keep our privacy notice under regular review and we will place any updates on our webpage.

14. Who can I contact if I have queries about this privacy notice?

You can also contact us directly if you have any questions about our privacy notice or information we hold about you.

Please write to us at the address given below.