1. Introduction
Searching the Clouds LLP is a limited liability partnership established to manage and operate a “wildcation” holiday accommodation business at Little Menherion, Cornwall.
We take your privacy very seriously and we are committed to protecting the privacy and security of your Personal Information. Please read this Privacy Statement carefully as it contains important information on who we are and how and why we collect, store, use and share your Personal Information. It also explains your rights in relation to your Personal Information and how to contact us or the supervisory authorities should you wish to make a complaint.
Searching the Clouds LLP is a “data controller” and is registered with the UK Information Commissioner’s Office (ICO) for data protection purposes (registration number C1048036). This means that we are responsible for deciding how we hold and use Personal Information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
Our use of your Personal Information is subject to Data Protection Law. Data Protection Law says that the Personal Information we hold about you must be:
- Used lawfully, fairly and in a transparent way;
- Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
- Relevant to the purposes we have told you about and limited only to those purposes.
- Accurate and kept up to date;
- Kept only as long as necessary for the purposes we have told you about;
- Kept securely.
2. Key terms
| We, us, our | Searching the Clouds LLP, registered in England and Wales (No. OC430623) with its registered office at Little Menherion, Menherion, Redruth, TR16 6NW, United Kingdom |
| Personal Information | Any information relating to an identified or identifiable individual |
| Special category Personal Information | Personal Information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership; genetic and biometric data; data concerning health, sex life or sexual orientation |
| Data Protection Law | The EU General Data Protection Regulation 2016/679 (the “GDPR”), the Data Protection Act 2018 (the “DPA”) and other relevant EU and UK legislation |
3. Personal Information processed by us
3.1 What Personal Information is collected about you
The Personal Information we collect about you depends on our relationship with you but it commonly includes:
- Contact details, such as your full name, title, address(es), telephone number(s) and personal email address(es);
- Other personal details, such as date of birth, gender, nationality, reasons for your stay, special occasions taking place during your stay;
- Financial and payment information;
- Dates on which you make contact with us;
- For those using our website (https://littlemenherion.com/):
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile device 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); pages 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), and methods used to browse away from the page and any phone number used to call our customer service number;
- real time location data from your mobile device.
We may also collect, store and use the following “special categories” of more sensitive Personal Information (which will only be collected when you have provided your express consent):
- information about your physical or mental health, including any disability, medical condition or allergies.
3.2 How your Personal Information is collected
We have a range of roles so we may or will collect Personal Information about you at different times and in different ways, depending on our relationship with you, including when:
- You contract or correspond with us;
- You arrange to stay in one of our cabins;
- You buy any products or services from us;
- You supply products or services to us;
- You use our website (https://littlemenherion.com/), for example to submit an enquiry; or
- You subscribe for email newsletters and updates.
3.3 From whom your Personal Information is collected
Primarily, we collect Personal Information about you directly from you. We may also collect your Personal Information from third parties, including:
- people who introduce you to us;
- any person making a booking on your behalf;
- organisations we engage to carry out customer satisfaction surveys;
- sub-contractors in technical, payment and delivery services;
- market researchers, advertising networks and analytics providers;
- search information providers;
- social networks; or
- agents working on our behalf (e.g. Sawday’s Canopy & Stars Ltd).
3.4 How and why your Personal Information is used
Under Data Protection Law, we can only use your Personal Information if we have a proper reason for doing so, e.g.:
- for the performance of our contract with you or to take steps at your request before entering into a contract;
- for our legitimate interests or those of a third party;
- to comply with our legal and regulatory obligations; or
- you have given consent.
A legitimate interest is when we have a justifiable reason to use your information, whether for our own purposes or for those of third party, so long as this is not overridden by your own rights and interests.
We may also use your Personal Information in the following situations, which are likely to be rare:
- where we need to protect your vital interests (or the vital interests of someone else). Vital interests are normally interests that are essential for someone’s life.
The table below explains what we use your Personal Information for and our reasons for doing so. The list set out below is not exhaustive:
| What we use your Personal Information for | Our reasons |
| To keep our central records up to date | For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party |
| To respond to your enquiry | For the performance of our contract with you or to take steps at your request before entering into a contract For our legitimate interests or those of a third party |
| To provide you with any products and services that you request from us, including: processing your booking and managing your experience of staying with us | For the performance of our contract with you or to take steps at your request before entering into a contract |
| To conduct market research and statistical analysis to help us manage our operations | For our legitimate interests or those of a third party |
| To develop our operations, such as improving efficiency and quality control | For our legitimate interests or those of a third party |
| To ensure the confidentiality of commercially sensitive information | For our legitimate interests or those of a third party |
| To prevent unauthorised access and modifications to our systems | For our legitimate interests or those of a third party To comply with our legal and regulatory obligations |
| To support internal audits and quality checks | For our legitimate interests or a those of a third party To comply with our legal and regulatory obligations |
| To establish, exercise or defend legal rights or claims and responding to court orders or other legal obligations | For our legitimate interests or a those of a third party To comply with our legal and regulatory obligations |
| To comply with any legal and regulatory obligations that apply to our operations, e.g. under health and safety legislation or rules issued by relevant regulatory bodies | To comply with our legal and regulatory obligations |
| To gather and provide information required by or relating to statutory returns, external audits, enquiries or investigations by regulatory bodies | To comply with our legal and regulatory obligations |
| To send you email newsletters and other marketing materials, to keep you up-to-date with developments and notify you of offers | When you have given your consent |
- “Special categories” of particularly sensitive Personal Information require higher levels of protection. We need to have further justification for collecting, storing and using this type of Personal Information. We may process special categories of personal information in the following circumstances:
- in limited circumstances, with your explicit written consent;
- where we need to carry out our legal obligations.
Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public.
We will use your particularly sensitive Personal Information in the following ways:
- we will use information about your physical or mental health in order to manage your health and safety and/or that of others in connection with your stay with us.
We do not envisage that we will hold information about criminal convictions. We will, however, notify you in writing if this position changes.
We do not envisage that any decisions will be taken about you using automated means (i.e. where an electronic system uses Personal Information to make a decision without human intervention). We will, however, notify you in writing if this position changes.
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us (see ‘How to contact us’). Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
3.5 With whom your Personal Information is shared
We will share your Personal Information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.
We will always treat your Personal Information with the utmost respect and we will not sell or rent it to third parties. We will not share your Personal Information with third parties for marketing purposes.
We may share your Personal Information with certain third parties, including:
- business partners, suppliers and sub-contractors for the performance of any contract we enter into with you, or for any service provided to us;
- other third parties who provide services which you have requested;
- our cloud storage providers;
- our insurers and brokers;
- external auditors;
- our banks;
- external service suppliers, representatives and agents that we use to make our operations more efficient, e.g.marketing agencies or analysis suppliers;
We may also disclose your Personal Information to such third parties as may be necessary to enforce or apply any contract in force between you and us or to protect the rights, property or safety of Searching the Clouds LLP, our Members or others. This includes exchanging information with other organisations for the purposes of security, law enforcement, fraud protection and credit risk reduction.
We will only disclose to a third party as much of your Personal Information as is required for the third party to fulfil the particular function and where required to do so we will have a contract in place with that third party requiring it to keep your information secure and not to use if for its own purposes.
3.6 Where your Personal Information is held
Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your Personal Information with’).
Some of these third parties may be based outside the European Economic Area (“EEA”). For more information, including on how we safeguard your Personal Information when this occurs, see below: ‘Transferring your Personal Information out of the EEA’.
3.7 For how long is your Personal Information kept
We will keep and process your Personal Information for as long as is necessary to fulfil the purposes for which we collected it, or for as long as it is necessary to do so for legal reasons. Different retention periods may apply for different types of Personal Information.
To determine the appropriate retention period, we will consider the amount, nature and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure, and whether we can achieve the purposes for which we process that Personal Information through other means.
When it is no longer necessary to retain your Personal Information, we will delete or anonymise it.
3.8 Transferring your Personal Information out of the EEA
It is sometimes necessary for us to share your Personal Information outside the United Kingdom (“UK”) and/or EEA, e.g.:
- if any of our servers is from time to time located in a country outside of the UK and/or the EEA;
- if our service providers are located outside the EEA; or
- if you are based outside the EEA.
These non-EEA countries may or may not have the same data protection laws as the UK and EEA. If we transfer your personal information outside of the UK and/or the EEA in this way, we will take steps to ensure that it is protected in the same way as if it were being used in the UK and/or the EEA, as the case may be, by using one of these safeguards:
- Transfer it to a non-UK and non-EEA country with privacy laws that give the same protection as in the UK and the EEA;
- Put in place a contract with the recipient that means they must protect it to the same standards as in the UK and the EEA.
More information is available on the UK Information Commissioner’s website and the European Commission Justice website.
If you would like further information please contact us (see ‘How to contact us’).
4. Your rights
You have the following rights in relation to the Personal Information which we hold, which you can exercise free of charge:
| Access | The right to be provided with a copy of your Personal Information (the right of access) |
| Rectification | The right to require us to correct any mistakes in your Personal Information, including to complete information you think is incomplete |
| To be forgotten | The right to require us to delete your Personal Information — in certain situations |
| Restriction of processing | The right to require us to restrict processing of your Personal Information — in certain circumstances, e.g. if you contest the accuracy of the data |
| Data portability | The right to receive the Personal Information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party — in certain situations |
| To object | The right to object:— at any time to your Personal Information being processed for direct marketing (including profiling);— in certain other situations to our continued processing of your Personal Information, e.g. processing carried out for the purpose of our legitimate interests |
| Not to be subject to automated individual decision-making | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you |
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation. If you would like to exercise any of those rights, please, email, call or write to us – see below: ‘How to contact us’.
5. Keeping your Personal Information secure
We have appropriate security measures to prevent Personal Information from being accidentally lost or used or accessed unlawfully. We limit access to your Personal Information to those who have a genuine business need to access it. Those processing your Personal Information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
6. How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of Data Protection Laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
7. Changes to this Privacy Statement
This Privacy Statement was published in October 2021.
We reserve the right to amend this Privacy Statement from time to time without prior notice. You are advised to check this website regularly for any amendments (but N.B. amendments will not be made retrospectively).
8. How to contact us
Please contact us by post or email if you have any questions about this Privacy Statement or the information we hold about you.
Our contact details are shown below:
Searching the Clouds LLP
Little Menherion
Menherion
Redruth
TR16 6NW
United Kingdom
littlem@littlemenherion.com
+44 (0)7766 775851