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QLodges Website Privacy Policy

QLodges respects your privacy and is committed to protecting your personal data. Our Privacy Policy will help you to understand what information we collect and process using the QLodges website, how we protect and use it, and what choices you have about your personal data.
When we refer to "QLodges" within this privacy policy, we are referring to QLodges of Wellington House, Cliffe Park, Bruntcliffe Road, Morley, Leeds, LS27 0RY, the organisation which provides this website, and any services or features which may be made available to you from this website. 


Data Protection Framework
QLodges have aligned our privacy policy with the EU General Data Protection Regulation ("GDPR"), which comes into effect on 25th May 2018, under the supervision of the ICO within the UK.
QLodges will complete the applicable Privacy Impact Assessments (also known as Data Protection Impact Assessments under GDPR) for activities related to this website if they meet the necessary criteria, and these are available upon request from QLodges.


Purpose of this Privacy Policy
This privacy notice aims to give you information on how we collect and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our deal alert newsletter, complete the enquiry or contact forms.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy notice supplements the other notices and is not intended to override them.


Data Controller
QLodges is the controller and responsible for your personal data.
We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection officer using the details set out at the end of this document.


1. Customer and Citizen Data

You may decide to send us your personal information via this website if you are seeking more information about rental accommodation or ownership at QLodges, signing up for newsletters or deal alerts, or for other similar purposes. Your decision to disclose your personal data is entirely voluntary, and by doing so, you are taking an affirmative action by providing us with specific consent to use your personal data only for the purposes for which you have disclosed it to us.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).


1.1 How data is collected
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data includes first name last name, title.
• Contact Data includes address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, 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 this website. 
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
We use different methods to collect data from and about you including through:


1.1.1 Direct interactions
You may give us your Identity and Contact by filling in online forms or by corresponding with us by phone, email, online chat or otherwise. This includes personal data you provide when you:

• Request information about holiday rentals or holiday ownership;
• Request marketing to be sent to you in the form of deal alerts or newsletters;
• Enter a competition, promotion or survey; or
• Give us some feedback.


1.1.2 Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.





1.1.3 Third parties or publicly available sources
We may receive personal data about you from various third parties and public sources as set out below:
• Technical Data from the following parties:
• Analytics providers such as Google based outside the EU;
• Search information providers based both inside and outside the EU.


1.2 How we use your personal data
QLodges will only use your personal data when the law allows us to and only for the purposes for which you have submitted it to us. Most commonly, we will use your personal data in the following circumstances: (a) provide information to you, (b) make contact with you, (c) provide contracted services to you, (d) perform the contract between us, (e) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (f) where we need to comply with legal and regulatory obligations or (g) maintain the operations and security of the website and services we provide to you.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
You will receive marketing communications from us if you have:
• Requested information from us, rented holiday accommodation with us or purchased holiday ownership products at QLodges;
• If you have provided us with your details and ticked the consent box to send you marketing communications; and
• You have not opted out of receiving that marketing


1.3 Promotional offers from us
We may use your Identity, Contact, Technical and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which marketing of products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.


1.4 Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via the details below.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis, which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


1.5 Data Storage
We will, at all times, handle and store your personal data in accordance with industry best practice aligned with ISO27001, the international standard for information security. This includes the activities and procedures undertaken by our own personnel and authorised third parties, and the technical controls which we have implemented to prevent unauthorised access, compromise or theft of information from our applications, supporting computer systems and premises.
These include removal of all personal data from the local and staging website, removal of data migration plugin, password prompts to access the staging site and two-factor authentication and email verification to access the back-end of the site. User access is limited.
We have put in place procedures to deal with any suspected data breach including disaster planning and will notify you, and any applicable regulator, of a breach where we are legally required to do so.
We limit, where possible, access to your personal data to employees and third parties including data processors, who have a business need to know such data. They will only process your data on our instructions and are subject to a processing agreement duty of confidentiality.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for including satisfying any legal, accounting or reporting requirements. By law we keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data, please see below.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


2. Sensitive Personal Data
GDPR specifies a set of personal data categories which are "sensitive", and which require special consideration by Data Controllers. This website, and any services available from this website, do not knowingly collect or process any sensitive personal data, and supporting Privacy Impact Assessments (also known as Data Protection Impact Assessments under GDPR) are available upon request from the QLodges Data Protection Officer.


3. Children's Personal Data
This website, and any services available from this website, are not directed to children under the age of 13. If you learn that a child under the age of 13 has provided us with their personal information without having parental consent, please contact the QLodges Data Protection Officer immediately so that we can take appropriate action.


4. Customer and Citizen Data Rights
As prescribed within data protection regulations, you have specific rights connected to the provision of your personal data to QLodges using this website. These include your rights to request we:
• Confirm to you what personal data we may hold about you, if any, and for what purposes;
• Change the consent which you have provided to us in relation to your personal data;
• Correct any inaccurate or incomplete personal data which we may hold about you;
• Provide you with a complete copy of your personal data for you to move elsewhere;
• Stop the processing of your personal data, whilst an objection from you is being resolved; and
• Permanently erase all your personal data promptly, and confirm to you that this has been done (there may be reasons why we may be unable to do this)
To contact QLodges, please see below.


4.1 Exercising your rights
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.


4.1.1 What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


4.1.2 Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If QLodges does not address your request within one month or fails to provide you with a valid reason why we have been unable to do so, you have the right to contact the Information Commissioner's Office to make a compliant. They can be contacted via their website (www.ico.org.uk) or by telephone 0303 123 1113.


5. Declaration of Processing and Sub-Processing
To make an informed decision on whether to provide your personal data to QLodges using this website, we need to make you aware of the following organisations who act as Data Processors for us in the provision of our services to you:
  • Durham Associates
  • Cameron House Lodges Limited
  • Merlin Timeshare Software
  • Spellman Walker
  • Mailchimp
  • Irwin Mitchell 
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield, which requires them to provide similar protection to personal data shared between the Europe and the US.


If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.
Please email us at datacontroller@qlodges.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
The activities within which each of these Data Processors participates may have been recorded within the applicable Privacy Impact Assessment records (also known as Data Protection Impact Assessments under GDPR) and these are available upon request from the QLodges Data Protection Officer.


6. Website Cookies
This QLodges website uses cookies to record log data. We use both session-based and persistent cookies, dependent upon how you use or interact with this website.
Cookies are small text files sent by us to your computer, and from your computer or mobile device to us each time you visit our website. They are unique to you or your web browser.
Session-based cookies last only while your browser is open and are automatically deleted when you close your browser session. Persistent cookies last until you or your browser deletes them, or until they expire.
We use cookies which are not specific to your account but are unique and allow us to undertake website analytics and customization, among other similar things. If you decide to disable some or all cookies, you may not be able to use some of the functions on our website. We may use third-party cookies, for example Google Analytics, and you may choose to opt-out of third party cookies by visiting their website.
We may use third-party cookies, for example Google Analytics, and you may choose to opt-out of third party cookies by visiting their website.
You can view our cookie policy here



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