When you make an enquiry about holiday accommodation with Ultimate Luxury Villa Rentals or stay in one of our accommodations, we collect and process personal data about you. This document helps you understand what personal information we collect about you, how we collect it, what we use it for, and what rights you have regarding your personal data.
1 Personal data - what we collect and what we use it for
We collect and store:
- Your name
- Your address (where we have it)
- Your contact details
- Your passport details (if staying at one of our Marbella villas, as is required by law in Andalucia, Spain)
- Your date of birth (if staying at one of our accommodations)
Passport information is required by law if staying overnight at a villa rental or hotel, therefore we have to log this information for every visitor.
For what purposes do we use your personal information?
We will use the information you provide to us to:
- Provide our services to you.
- Invite you to leave reviews.
- Respond to your questions and provide related customer service.
- Send you our newsletters and special offer notifications.
- Comply with legal requirements and legal process, requests from public and governmental authorities, relevant industry standards and our internal policies.
- Protect our operations or those of any of our affiliates.
- Protect our rights, privacy, safety or property and/or that of our affiliates, you or others.
- Allow us to pursue available remedies or limit any damages that we sustain.
On what legal basis do we process your personal data?
We need to process your personal information in order to:
- Perform our contract with you (see Article 6.1.b of the GDPR)
- For the establishment, exercise or defence of legal claims, where necessary (see Article 9.2.f of the GDPR)
- In order to supply the authorities with your passport information when you stay overnight in a villa rental or hotel, as dictated by law.
You are free to revoke your consent for us to hold this information at any time. However, please be aware that we may have the right to continue to process your information if it can be justified on one of the other legal bases mentioned above.
2 Disclosure of personal information
We disclose your personal information to the following parties and in the following circumstances:
- To third parties only if you are staying in one of our accommodations and would like us to arrange further services e.g airport transfers, private chefs...
- To allow third party vendors, consultants and other service providers to perform services on our behalf.
- To comply with laws or to respond to claims, legal process (including but not limited to subpoenas and court orders) and requests from public and government authorities
- To cooperate with regulatory bodies and government authorities.
- To third parties in order for us to pursue available remedies, or limit damages that we may sustain.
- To a third party in the event of any reorganisation, merger, acquisition, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business or assets (including in connection with any bankruptcy or similar proceedings).
3 Data retention
We keep the passport information for 3 years as required by law, or whilst it is required to provide a service you have requested, or if required to confirm your identity for any bookings you have asked us to provide, and other Master Data until you request otherwise. We will delete this information upon your request and we will only save a log with the following information: your name, contact details and the date of the deletion of your Account. We will keep the log for 3 years. All other information will be deleted.
4 Security measures
We use SSL 256-bit encryption for the collection, storage and protection of all data. In addition we use reasonable organisational, technical and administrative measures to protect your personal information within our organisation.
5 Access and insights into the personal data we have about you
6 Correction and deletion of your personal data
If any of the Master Data or other personal information that we have about you in our capacity as a data controller is incorrect or misleading, you are welcome to ask us to assist with correcting your information.
7 Other rights
In addition to the rights set out above concerning your personal data, you also have the following rights:
- You also have the right to object to the processing of your personal data and have the processing of your personal data restricted unless this prevents us complying with the law.
- In particular, you have an unconditional right to object to the processing of your personal data for direct marketing purposes.
8 Changes to this Policy
We reserve the right to make changes to this Policy. The date shown at the start of this Policy indicates when it was last revised. If we make material changes to it, we will provide notice to give you the opportunity to review the changes before they come into effect. If you object to our changes, you can request that your data be deleted from our records.
9 Contact information and where to send questions or complaints
If contacting us does not resolve your complaint, you have further options, for example you may always lodge a complaint with a data protection supervisory authority