Privacy and Cookies Policy
Privacy and Cookies Policy
1. Introduction
1. We are committed to safeguarding the privacy of our website visitors and service users.
2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
3. By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.
4. Our website/email marketing system incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via https://www.luxuryscotland.co.uk/home/disclaimer-privacy.html.
5. In this policy, "we", "us" and "our" refer to Luxury Scotland’s Registered Data Controller (Dorothy Welsh). For more information about us, see Section 13.
2. How we use your personal data
1. In this Section we have set out:
2. the general categories of personal data that we may process;
3. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
4. the purposes for which we may process personal data; and
5. the legal bases of the processing.
6. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
7. We may process information that you post for publication on our website or through our services ("publication data"). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is consent.
8. We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is the proper administration of our website and business – and our ability to respond to email enquiries made to our offices, member hotels and properties.
9. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
10. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include [the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
11. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
12. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
13. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
14. Please do not supply any other person's personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
1. We may disclose your personal data to any member of our Luxury Scotland collection (this means our members and partners) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
2. We may disclose your enquiry data to one or more of our members for the purpose for fulfilling your request. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party's use of your personal data.
3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain your personal data as follows:
4. Your name, and personal contact details will be retained for a minimum period of 1 month following [the date of enquiry form submission, and for a maximum period of 18 months following the date of enquiry form submission.
5. In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:
6. the period of retention of Your name, and personal contact details will be determined based on the length of time it may take to fulfil your enquiry.
7. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Security of personal data
1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems if used.
3. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
4. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
6. Amendments
1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
3. We may notify you of changes to this policy by email, unless you have explicitly requested that we do not do so.
7. Your rights
1. In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2. Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10. To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
(c) and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format.
11. However, this right does not apply where it would adversely affect the rights and freedoms of others.
12. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
13. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
14. You may exercise any of your rights in relation to your personal data by written notice to us.
8. Third party websites
1. Our website may include hyperlinks to, and details of, third party websites.
2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
3. Personal data of children
4. Our website and services are targeted at persons over the age of 18 in the UK and EU.
9. Updating information
1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
10. Cookie Policy: How and why Luxury Scotland uses ‘Cookies’ and other similar technologies
Luxury Scotland does make use of Cookies, which are small text files that are placed on your computer by websites that you visit, or certain emails you open and other similar technologies such as Flash Cookies and web beacons. Such technologies are widely used in order to make websites work, or work more efficiently, as well as to provide business and marketing information to the owners of the site, to gather such personal data as browser type and operating system, referring page, path through site, domain of ISP etc. for the purpose of understanding how visitors use this website. Cookie and similar technologies help us tailor this website to your personal needs.
This type of information obtained through cookies will not be disclosed outside Luxury Scotland or our authorised Third-Party Data Processors. It will not be used for unsolicited communications.
Cookies located on your computer do not contain your name but an IP address. In many cases, after the user's session is cancelled the information contained in the cookies is no longer available to Luxury Scotland.
Please ensure that your computer setting reflects whether you are happy to accept cookies or not. You can set your browser to warn you before accepting cookies, or you can simply set it to refuse them, although you may not have access to all the features of the website if you do so. See your browser "Help" button for how you can do this. Some Flash Cookies may not be affected by such settings. You do not need to have cookies on to use or navigate through many parts of this website. Remember that if you use different computers in different locations you will need to ensure that each browser is adjusted to suit your cookie preferences.
|
Cookie Name |
Cookie Purpose |
Lifespan |
|
_ga |
Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
2 years |
|
_gat |
Used by Google Analytics to throttle request rate |
1 day |
|
__cfduid |
Used by the content network, Cloudflare, to identify trusted web traffic. |
30 days |
|
_gd# |
Used by Google Analytics to distinguish users. |
Session |
|
_gid |
Registers a unique ID that is used to generate statistical data on how the visitor uses the website. |
1 day |
|
lo_session |
Collects data on the user’s navigation and behaviour on the website. This is used to compile statistical reports and heatmaps for the website owner. |
Persistent |
|
ads/ga-audiences |
Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. |
Session |
|
_fbp |
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
3 months |
|
fr |
Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. |
3 months |
For further information about Cookies including how to refuse them, please visit www.allaboutcookies.org
1. This website is owned by Luxury Scotland (Connoisseurs Scotland Ltd) and operated on their behalf by Dorothy Welsh.
2. Luxury Scotland (Connoisseurs Scotland) is registered in Scotland under registration number SC152243 and our registered office is at 1 George Square, Castle Brae, Dunfermline, Fife KY11 8QF.
3. Our principal place of business is at Iona, Perth Road, Dunblane, FK15 0HD.
4. You can contact us:
(a) by post, to the postal address given above; using our website contact form; by telephone, on the contact number published on our website.
11. Data protection registration
1. Dorothy Welsh is registered as a data controller for Luxury Scotland (Connoisseurs Scotland) with the UK Information Commissioner's Office.
2. Our data protection registration number is ZB058358
12. Representative within the European Union
1. Our representative within the European Union with respect to our obligations under data protection law is Dorothy Welsh and you can contact our representative by telephone on 01786 821860.
13. Data protection officer
1. Our data protection officer's contact details are: Dorothy Welsh / Luxury Scotland, Iona, Perth Road, Dunblane, Scotland FK15 0HD