Consumer and website privacy policy
Hi and welcome to the Hudson Property Group Ltd privacy notice. You are not being asked to agree to this notice nor is HPG hiding anything in it that should be elsewhere, this is just to tell you what is being done with your personal information. If anything isn’t clear or you want to know more, then you can ask a question later. There tend to be two groups of people that need to look at privacy notices, people that want to book a holiday and people that own holiday cottages via our website. HPG want people to understand this privacy notice and have tried to make it easy for you to read. There is a heading so you can find what you want more quickly, with a plain explanation as to what HPG are doing then there is the legal language because the GDPR says it is required. HPG, hope you find what you need.If you have questions after reading this, please email info@hudsonpropertygroup.co.uk who will get back to you.
Who We Are
Hudson Property Group Ltd, a company registered in England, with company number: 15060115 of Granville House, 2 Tettenhall Road, Wolverhampton, West Midlands, England, WV1 4SB, (referred to as “Hudson Property Group”, “HPG” in this privacy notice) is the primary data controller in relation to your personal data. This means that HPG are responsible for your personal data.Hudson Property Group Ltd (HPG) operate through brands and companies who together make up the Hudson Property Group Ltd.Our trading brands are Hudson Property Shropshire Ltd, Hudson Property Cheltenham Ltd, and Hudson Property Hampshire Ltd.
Our Contact Details
For privacy queries the correspondence address is PO Box 4910, Shrewsbury SY1 9RQ and the email address to contact is info@hudsonpropertygroup.co.uk
The Data We Collect from You
HPG collect personal details including your name, address, email addresses, telephone numbers, title, and country of residence. If you interact with HPG on social media, HPG may collect your social media identifiers. Sometimes this data is checked using publicly accessible sources used to verify identity.
If you are part of a group of travellers, HPG may collect personal details of members of your party. It is your responsibility as the lead booker to inform them of this privacy policy and that you have provided their data.
HPG must collect data from you to create and maintain an account for you on HPG systems. Interactions with you are managed using an account system and HPG will tell you when information is required rather than voluntary.
HPG collect financial data including transactions made with you but generally do not collect or retain payment card details as this processing is outsourced but HPG may (if you consent) retain an authorisation to charge a payment method.
HPG record some calls to or from our office. This will include the number dialled or called from as well as the recording itself. These recordings may be used for training purposes, fact verification and to meet regulatory obligations in relation to selling insurance. In a similar way HPG may retain transcripts of live chats, text messages and other social media direct messaging that is sent to you or you send to us.
If you have booked through another website such as Airbnb or Booking.com then HPG will receive data from them rather than collecting it from you directly. The data received depends on the relevant website and their own privacy policy. HPG also collect data from you about other people who are in your travelling party. You are responsible for telling them you have given us their data our use of which is governed by this privacy policy. Where you provide us with information about children you are responsible for gaining the relevant consent from them or their parents/guardians.
HPG collect data for marketing and website management purposes including details of how you have used the website, your responses to surveys and feedback requests, your marketing preferences, and your cookie consents.
HPG collect technical data including internet protocol (IP) addresses, 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 our website. Some of this data is used for website management and marketing purposes.
When things go wrong, and HPG must collect debts from you or take other legal action HPG may get information about other creditors you have and payments you make to them. This will be received from IVA, bankruptcy, or financial advisors as well as your legal representatives.
Providing Our Services to You
HPG use your personal data to fulfil the contract with you as a booking agent and to assist with fulfilling the contract between you and the property owner. This because it is necessary for the performance of the contract to which both you and the owner are a party for the rental agreement as well as the contract between you and HPG as the booking agent you have made your booking through.
HPG may use your personal data to sell you insurance from insurance partners where you want this to happen. This because it is necessary as a step for you to form a contract with the insurance partner in the future.
HPG may provide you with access via a customer website portal and you can also access your data through the app. This uses your personal data to provide you with information about your bookings and the feedback you have given and to provide you with on site offers that are personalised to you. This either because it is necessary for the performance of the contract with you or because it is in HPG legitimate interests for providing an excellent service to give you information you want in a way that enables us to be a successful business.
HPG will also communicate with you by any means (including email) about changes to HPG terms and conditions, your contract or with the property owner or changes to this privacy or other policies that may affect you. This is based on compliance with a legal obligation or because it is necessary to perform the contracts with you.
Marketing and sales materials
Your personal data will be used to personalise advertising and marketing in relation to future bookings or related products including insurance. This based on your consent for text, email, and telephone calls if you are registered. You can withdraw this consent at any time through unsubscribe links, during a telephone conversation, by changing your preferences in your customer portal or by emailing info@hudsonpropertygroup.co.uk. For some postal communications and telephone calls where you are not registered HPG rely on our legitimate interests as a growing business.You may also be eligible to take part in loyalty schemes and will process your personal data to check your eligibility and to provide these services based on it being in HPG legitimate interests as a company seeking to increase repeat custom through providing a service that customers want to use.
Marketing and sales materials for customers of businesses that HPG acquire
HPG rely on our legitimate interests as the acquirer of the business to process your personal data in line with the privacy policy of the company you have a contract with.
Our Legal Obligations
HPG are subject to legal obligations under the laws of the UK, Ireland, the EU, and other countries and may need to process your personal data to comply with these legal obligations from specific reporting that may be required from time to time to more general obligations in law. This may involve co-operating with public sector organisations such as government agencies, local government, and regulators. This may include the Competition and Markets Authority, the UK Information Commissioner’s Office, HMRC and other tax authorities, the Police or local councils.
Financial Information
HPG will process your personal data to manage payments, collections, fees and charges and debt recovery. This may involve third parties particularly where debt recovery is involved. This because it is necessary for the performance of the contract with you.
General Business Purposes
HPG may process your personal data for security purposes (including cyber security) and to generally administer HPG business including for group reorganisations, system maintenance and reporting, preparation of HPG accounts, the generation of aggregated information for public disclosure, staff training, account auditing and processes, verification of compliance with laws and regulations and other internal administration. HPG do all of this based on legitimate interests as a business that wishes to grow and develop and on the basis of legal obligations to which HPG are subject.
Customer Service
Where you make a complaint or have a query, or where an owner raises issues with your behaviour during a rental period, HPG will need to process your personal data to mediate between you and them. This is because it is necessary to fulfil booking conditions which are part of the contracts between HPG and you and you and the owner. Where you make queries, HPG will also need to process your personal data to answer. Call recordings may be used for fact verification in customer service queries.
Who We Share Your Data With
Public Authorities
This may include law enforcement bodies, the courts, regulators, government and local government bodies and agencies, HMRC and other public bodies.
Payment Services ProvidersAt present HPG do not use specialist companies to process payment card details. However, this may change.
Marketing PartnersHPG use many service providers to assist in our marketing efforts or to leave reviews. These include may include trust pilot or similar.
Insurance ProvidersWhere HPG sell you insurance your details will be disclosed to the insurance provider and may need to disclose it to other organisations (such as the FOS or the FCA) that you may later complain to.
Third Party Booking PlatformsThese include but are not limited to Airbnb, Vrbo, Booking.com, TripAdvisor, Expedia and similar companies. They may pass the information on to other advertising partners.
Purchasers or Potential Purchasers of Our BusinessThird parties whom HPG may choose to sell, transfer, or merge parts of the business or assets. If a change of ownership happens to the business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.
How Long We Keep Your Data
HPG keep different categories of data for different periods of time depending on what they are used for and seek to get rid of what is not needed as early as possible. However, HPG are required to keep some information for longer periods by law and keep some because it is for legitimate interests.As a guide, you can expect enough data to be retained to identify you for six years after you last interacted with HPG or had a commercial relationship with you. This is mainly because that is when records relating to corporate taxation can be removed.Because holiday letting is a long-term proposition and can involve large periods of time between booking with a particular company marketing data promoting HPG services will contain to be sent for up to four years after your last response although the frequency of communications will decrease with time, and you can ask HPG to stop at any time.While there is a commercial relationship with you HPG retain full records, including data from more than six years ago and if HPG reasonably contemplate there may be litigation or there has been a complaint in relation to your property this information may be retained beyond the six-year standard.
Your Statutory Rights
Right of Access (Subject Access Requests)
You have the right to ask HPG for a copy of the data held about you or any part of that data along with some further information about how it is processed and kept safe. HPG are allowed to ask you for more information about your identity and to ask you to narrow down your request to help find your data. This right always applies but there are exemptions that mean you may not always receive all the information processed and if you are a corporate owner (a company owns your property) the corporate owner cannot make an access request. You cannot make an access request for someone else’s data without their written authorisation.
Right of Erasure (Right to Be Forgotten)
This is not a simple right and does not always apply. HPG must erase your data if it is no longer needed for the purposes collected for or if you withdraw your consent where the processing is based on consent.For people who have booked a rental directly, HPG will not erase your data at all while the contract is still valid or if money is owed. HPG will also not erase your data for six years because of the rules around corporate financial records. HPG will also not delete your data if there is an ongoing complaint, if there has been a complaint in the last year, or if there is reason to believe there may be legal action taken in relation to the contract by HPG, you or a third party. In general, your data will not be erased if you have booked a rental through us in the last 12 months.Your data will be erased if it has been processed unlawfully if you have successfully objected to the processing of your data or if HPG have a legal obligation to do so.If your main concern is about marketing communications, you can opt to tell us to stop sending you marketing communications instead and where this seems to be the reason for an erasure request HPG will always cease marketing while this is discussed with you.
Right to Rectification
You always have the right to require HPG to make sure that the data held about you is accurate. Please let HPG know if it is not, and it will be fixed. Where HPG disagree that it is incorrect HPG will tell you why and give you the opportunity to provide evidence that HPG have made a mistake.
Right to Restriction
Where you have objected to HPG data processing, and HPG are still in discussions or there is a dispute over the accuracy of the data or HPG have agreed the processing is unlawful, but you wish to preserve evidence or you require the data for a legal claim you can ask HPG to restrict processing such that HPG can only continue to store it.
Right to Data Portability
Where the basis for processing your data is for the performance of a contract or based on your consent you can ask HPG to provide your data in a machine-readable format.
General Right to Object
Where the basis for processing your data is based on legitimate interests you can object at any time and HPG will consider whether there is an overriding legitimate interest that would mean HPG would continue to process your data or whether HPG should stop. You should note that legal claims would generally be regarded as an overriding interest.
Right to Object to Direct Marketing
This is an absolute right, and you can exercise it at any time by getting in touch with HPG.
Right To Appeal an Automated Decision
If HPG make a decision purely by automated means, generally meaning a computer made the decision, you can ask to have that decision reviewed by a human. HPG will tell you when a decision has been made by purely automated means.
Right To Withdraw Consent
Where HPG processing is based on your consent then that consent can be withdrawn at any time. HPG will let you know when processing is based on your consent.
Exercising Your Rights
You can ask the customer services team on the phone to exercise your rights, send an email to info@hudsonpropertygroup.co.uk or drop us a letter to our postal address at PO Box 4910, Shrewsbury SY1 9RQ.Your request will be dealt within one calendar month, but particularly complex requests may take longer. HPG will keep you informed when that happens.
Making a Complaint
Any complaint about data processing should be sent to the Information Commissioner’s Office whose details can be found at www.ico.org.uk.The Information Commissioner’s Office will expect you to have complained to HPG first and to have given HPG an opportunity to respond. HPG appreciates the opportunity to try and resolve your complaint first to resolve matters amicably.
Automated Profiling
For marketing and recommendations purposes your data may be processed in ways that tell HPG what you are likely to want to see from HPG and products that may interest you. HPG may also make certain offers available to you on this basis.
Changes to this Privacy Policy
HPG always record the data on which the privacy policy has been changed at the top of this page. You can ask HPG for copies of previous privacy policies and when they were effective from at any time. When purposes for processing your data change HPG will let you know either through this privacy policy or by sending you a direct communication if HPG think it has a large impact on you. Regular communications may indicate when this policy has been updated and ask you to look at it.
Links to Other Websites or social media
HPG website may include links to and from third-party websites, social media, plug-ins, and applications. By clicking on these links or enabling connections you may be allowing third parties to collect or share your personal data. HPG have no control over these third-party websites, plug-ins or applications and are not responsible for their privacy policies, therefore you should also read their privacy policies to understand what personal data they collect about you and how they use it.
