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Privacy Policy

1 Introduction

Swan Holidays Ltd (trading as Welcome Family Holiday Park) respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when we collect your personal data in other circumstances, and tell you about your privacy rights and how the law protects you

2 Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how Swan Holidays Ltd collects and processes your personal data, including any data you may provide through this website when you sign up to our newsletter, book a holiday, stay at the Welcome Family Holiday Park (the Park) or take part in a competition.

This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy policy together with any other privacy policy or fair processing policy 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Swan Holidays Ltd is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy policy).

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the “Contact Us” section of our website or by using the following details:

Full name of legal entity: Swan Holidays Ltd

Email address: legal@welcomefamily.co.uk

Postal address: Welcome Family Holiday Park, Dawlish Warren, South Devon, EX7 0PH

Telephone number: 03451 65 62 65

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 8 May 2023.

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.

Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3 The data we collect about you

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).

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

Identity Data includes name, username or similar identifier, title, gender, vehicle number plate and booking reference.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address and the platform on which you access our 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 our third parties and your communication preferences.

CCTV Data includes video footage from CCTV cameras.

Promotional Filming and Photography Data includes audio and visual recordings and photographs collected when you visit the Park.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Special Categories of Personal Data

We may collect or process Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions and , information about your health) if you make us aware of any special requests for your booking including anything due to specific medical, dietary, or religious requirements which we will note so that we can do our best to accommodate your request. If you book onsite activities, we may ask for information about your health including any existing conditions relevant to the activity and details of who to contact in the event of an emergency. The information is collected for the following purposes:

• to provide the activities that you want and to ensure you can safely take part; and

• to ensure we are able to contact someone in an emergency.

We may also process the details of any “Blue Badge” issued to you for the purpose of issuing a disabled parking sign for use during your stay at the Park.

The legal basis for our use of this data is your consent. You have the right to object to us processing this data at any time.

Criminal offence data

We may collect information about criminal convictions and offences if:

• you have made a booking at the Park, and we discover that you are a convicted child sex offender, or you are subject to the notification requirements of the Sexual Offences Act 2003, or you are subject to a Risk of Sexual Harm Order or Child Abduction Notice; or

• you have committed a crime at the Park.

We will only share criminal offence data with the police (and other law enforcement bodies) in accordance with the law. We will not process this information for any other reason.

Troublesome customers or visitors

Where a customer or visitor of the Park has committed a breach of the Park Rules (as set out in our terms and conditions) or otherwise causes difficulties at the Park, we may share limited Identity and Contact information with other local holiday parks on the basis of our legitimate interests of protecting our business, staff and customers and the other local holiday parks protecting their businesses, staff and customers. We may also share information with the police on the basis of our legitimate interests of ensuring that the police have all the necessary information for a proper and fair investigation or where it is necessary for us to comply with a legal obligation. Where we share criminal offence data with the police, we will do so on the grounds of preventing or detecting unlawful acts in accordance with paragraph 10 of Schedule 1 of the Data Protection Act 2018. When sharing this information, we will ensure that the sharing is limited to that information which is strictly necessary and is on the basis of a written agreement containing suitable confidentiality and security measures to ensure that the information is not shared with any additional third parties.

We may also receive similar information from the other local holiday parks in relation to customers or visitors of their park and we reserve the right to check this information prior to accepting a booking at the Park.

Our use of CCTV Data

We have installed CCTV systems in some locations of the Park for the purpose of staff and public safety. Signs are prominently displayed notifying you that CCTV is in operation and providing you with details of who to contact for further information about them.

We will only disclose CCTV images to third parties for the purposes of public safety. CCTV images will not be released to the media for entertainment purposes or placed on the internet.

We will only retain CCTV Data for as long as reasonably necessary to fulfil the purposes we collected it for i.e. to protect our customers, premises, assets and staff from crime, and to ensure health and safety at all times. If you would like further information on the retention period for CCTV Data, please contact us.

Our use of Promotional Filming and Photography Data

We sometimes undertake promotional filming & photography. Every effort is made to ensure filming does not intrude into your privacy and make it clear to all guests in the vicinity that filming/photography is taking place. If you do not want to be included in promotional material please try to stay away from the filming area. However, if you or someone in your party does stray into a photo or video without meaning to, please let us know and we’ll do our best to remove the image or video material from our library.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a holiday rental). In this case, we may have to cancel a the holiday booking you have with us but we will notify you if this is the case at the time.

4 How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact and Financial Data and any Special Categories of Personal Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• make a booking;

• participate in activities as part of your booking;

• subscribe to our newsletter;

• request marketing to be sent to you;

• enter a competition, promotion or survey; or

• give us feedback or contact us.

• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, and other similar technologies.

• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources including analytics providers such as Google based outside the UK, social media platforms based outside the UK and other holiday parks.

5 How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Performance of a contract: where we need to perform the contract, we are about to enter into or have entered into with you.

• Legitimate interests: 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. Legitimate interests means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

• Legal obligation: where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you or where we process Special Categories of Personal Data. You have the right to withdraw consent at any time by contacting us.

6 Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/ActivityType of dataLawful basis for processing including basis of legitimate interest
To administer your booking and deliver our services, including:

a) responding to requests for information;

b) confirming your booking or otherwise communicating with you about your booking;

c) providing you with other products and services you request (for example where you have purchased an activity pass at the Park); and

d) providing you with suitable accommodation and facilities and making reasonable adjustments to accommodate your stay, including the issuing of disabled parking signs.
a) Identity

b) Contact

c) Special Categories of Personal Data
a)Performance of a contract with you.

b) Condition for processing Special Categories of Personal Data: explicit consent (Article 9(2)(a) UK GDPR).
To process and deliver your order including:

a) to manage payments, fees and charges;

b) and to collect and recover money owed to us.
a) Identity

b) Contact

c) Financial

d) Transaction

e) Marketing and Communications
a) Performance of a contract with you. 

b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:

c) notifying you about changes to our terms or privacy policy;

d) and asking you to leave a review or take a survey.
a) Identity

b) Contact

c) Profile

d) Marketing and Communications
a) Performance of a contract with you.

b) Necessary to comply with a legal obligation.

c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services).
The use of CCTV equipment throughout the Park.a) Identity

b) CCTV
a) Necessary for our legitimate interests (to protect our customers, premises, assets and staff from crime, and to ensure health and safety at all times).
Promotional filming and photography.a) Identity

b) Promotional Filming and Photography
a) Necessary for our legitimate interests (to develop our products/services and grow our business).
To share details of customers or visitors who have caused issues at the Park with the police.a) Identity

b) Contact

c) CCTV
a) Necessary for our legitimate interests (to protect our business, staff and customers and the business, staff and customers of other local holiday parks).
To share details of customers or visitors who have caused issues at the Park with other local holiday parks.a) Identity

b) Contact
a) Necessary for our legitimate interests (to protect our business, staff and customers and the business, staff and customers of other local holiday parks).
To enable you to partake in a prize draw, competition or complete a survey and to share the prize winner’s details on social media.a) Identity

b) Contact

c) Profile

d) Usage

e) Marketing and Communications
a) Performance of a contract with you.

b) Necessary for our legitimate interests (to study how customers book holidays with us and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). a) Identity

b) Contact

c) Technical
a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).

b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.a) Identity

b) Contact

c) Profile

d) Usage

e) Marketing and Communications

f) Technical
a) Necessary for our legitimate interests (to study how customers book our holidays, to grow our business and to inform our marketing strategy).
To use data analytics to improve our website, services, marketing, customer relationships and experiences.a) Technical

b) Usage
a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you.a) Identity

b) Contact

c) Technical

d) Usage

e) Profile

f) Marketing and Communications
a) Necessary for our legitimate interests (to grow our business)

7 Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile 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 products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from our third party processor, Mailchimp if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

You can find out more about how MailChimp collects and stores your information here.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

8 Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive. We use the following cookies:

• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

• Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9 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.

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.

10 Disclosures of your personal data

We may share your personal data with the parties set out below:

• Service providers acting as processors who provide IT and system administration services.

• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

• Law enforcement agencies.

• Other local holiday parks for the purpose of protecting our business, staff and customers and the business, staff and customers of other local holiday parks.

• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

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.

11 International transfers

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.

• Where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

12 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.

13 How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period if required by law or a regulatory authority (such as HMRC), in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

If you would like further information on the retention period for your personal data, please contact us.

14 Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, including the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data This enables you to ask us to suspend the processing of your personal data in the following scenarios:

o If you want us to establish the data’s accuracy.
o Where our use of the data is unlawful, but you do not want us to erase it.
o Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
o You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
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 could refuse to comply with your request in these circumstances.

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.

Time limit to respond
We try to respond to all legitimate requests within one month of receipt of your request. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. we will notify you and keep you updated.