Data Protection Framework
The Lakelands Owners Club 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 will be available upon request from The Lakelands Owners Club (see Section 12).
This privacy notice aims to give you information on how The Lakelands Owners Club collects 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 or the Holiday Planner.
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.
The Lakelands Owners Club is the controller and responsible for your personal data (collectively referred to as “The Lakelands Owners Club”, “The Lakelands”, “we”, “us” or “our” in this privacy notice). We have appointed a data protection administrator at Resort Solutions, our management company, 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 administrator 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, to make a provisional booking for rental accommodation, contacting the Club or Resort Solutions Ltd., asking about exchanges at The Lakelands Owners Club, 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;
- Purchase Data includes information about your holiday ownership/timeshare ownership and holiday rental purchases; and
- Marketing and Communications Data includes your preferences in receiving marketing from us.
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, or otherwise. This includes personal data you provide when you:
- Request information about holiday rentals or holiday ownership
- Complete the provisional booking forms;
- Complete the contacts forms;
- Purchase holiday ownership
- Renting a holiday apartment; or
- Give us some feedback.
Should you send us questions via the contact and enquiry forms, we will collect the data entered on the form, including the contact details you provide, to answer your question and any follow-up questions. We do not share this information without your permission.
We will, therefore, process any data you enter onto the contact form only with your consent. You may revoke your consent at any time. An informal email making this request is sufficient. The data processed before we receive your request may still be legally processed.
We will retain the data you provide on the contact form until you request its deletion, revoke your consent for its storage, or the purpose for its storage no longer pertains (e.g. after fulfilling your request). Any mandatory statutory provisions, especially those regarding mandatory data retention periods, remain unaffected by this provision.
1.1.2 Automated technologies or interactions
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:
- 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
The Lakelands Owners Club 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.
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 The Lakelands;
- If you have provided us with your details and confirmed you want to receive marketing communications;
We have a lawful basis for processing existing data on the grounds of legitimate interest as users have engaged with us before and we will only send specific communications for relevant products and services.
You have the right to withdraw consent to marketing at any time by contacting us (at email@example.com) or by clicking the un-subscribe link (opt-out) in our emails.
Whatever preference you may affirm or change from time to time, GDPR permits us to send communications where a legal requirement arises or legitimate interest prevails.
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 specific interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
1.4 Data Storage
We will, at all times, handle and store your personal data in accordance with industry best practice for information security. This includes the activities and procedures undertaken by our own personnel and authorised third parties (see Section 5), 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.
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.
In some circumstances you can ask us to delete your data, please see Section 4 below.
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.
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 Lakelands Owners Club Data Protection Officer (see Section 9) 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 The Lakelands Owners Club 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 The Lakelands Owners Club, please see Section 12 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 The Lakelands Owners Club 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 complaint. 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 The Lakelands Owners Club 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:
Resort Solutions Ltd (Processor), based in the United Kingdom, who undertakes lawful data processing for marketing and the provision of management services on behalf of The Lakelands. Resort Solutions Ltd is registered with the Information Commissioner’s Office for the UK Data Protection Act with registration number Z8935499.
SharpSpring (Sub Processor), based in the United States, a marketing platform that deals with marketing automation and email distribution. SharpSpring complies with their requirements under the GDPR. Access to SharpSpring is limited and password protected.
Pinpoint Booking System PRO, developed by Dot On Paper and based in the United States, a plugin which creates an online booking/reservation system on The Lakelands website. It provides availability calendars with pricing and the opportunity for visitors to enquire about availability through a form. No live bookings or payments are taken through this plugin.
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 firstname.lastname@example.org 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 will be recorded within the applicable The Lakelands Owners Club Privacy Impact Assessment records (also known as Data Protection Impact Assessments under GDPR) if required and these will be available upon request from the The Lakelands Protection Officer (see Section 12).
6 Website Cookies
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.
7 External Links
The Lakelands Owners Club website may include relevant hyperlinks to external websites not controlled by us.
Whilst all reasonable care has been exercised in selecting and providing any such links, you are advised to exercise caution before clicking any external links. We cannot guarantee the on-going suitability of external links, nor do we continually verify the safety or security of the contents which may be subsequently provided to you.
You are advised, therefore, that your use of external links is at your own risk and we cannot be responsible for any damages or consequences from your use of them.
8 International Transfers
The Lakelands Owners Club does not transfer your personal data outside the European Economic Area (EEA).
9 Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
10 Data Retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we keep basic information about our customers for seven years for tax purposes.
We will retain personal information about members for seven (7) years from the point at which they cease to be a member or owner of a timeshare interest, after which time it will be purged or otherwise removed from our systems.
For non-members and for other individuals who do not own a timeshare interest at the resort, we will destroy any personal data we have collected about you three (3) years after you last transacted with us.
Details of retention periods for different aspects of your personal data are available from request from us by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
12 Contacting The Lakelands Owners Club
The Data Protection Officer
The Lakelands Owners Club
C/O Resort Solutions Ltd.
St Mary’s House
St Mary’s Road