privacy policy

CUG Travel Ltd T/a unlockedhotels.com

Our contact details.

Address: 15 Bexhill Road, Eastbourne, East Sussex, BN22 7JH

Phone Number: 0330 880 0540

E-mail: info@unlockedhotels.com

The type of personal information we collect.

We currently collect and process the following information:

• Personal identifiers, contacts, and characteristics (for example, name and telephone number, contact details, email address, (postal address when booking)
• We do not collect any financial or payment information, this is covered under PCI compliance and payments are handled by our payment gateway and totally separate from the unlocked hotels web site.

Thank you for your interest in our services. Protecting your privacy and data is very important to us. We only collect and use data in accordance with applicable provisions regarding data protection. In the following, we as a Controller, will explain to you what data we collect and how we process this data.

1. PERSONAL DATA

Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to a unique identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. Personal data will only be saved if it is necessary for providing the booked services, adhering to legal requirements or for purposes

explained in the following paragraphs.

2. ANONYMISED DATA / LOG FILES / IP ADDRESS

You can visit and browse our website only by registering and providing certain personal data, SUCH AS Full name, email address, Phone number. However, certain anonymous data may be saved each time our website is visited, e.g. which page or which offer was called up. This data is not personal, however, and thus is not subject to the legal guidelines regarding data protection.

3. PURPOSE OF COLLECTING PERSONAL DATA

Personal data must however be provided if you make a reservation via our website, contact us, subscribe to our newsletter or use other services on our website that require personal data to be given. This includes the management of your data in an account with membership, login function, amending existing bookings or orders.

In accordance with legal requirements, we will normally only collect data necessary for the service you require. If you provide any further information, this is always voluntary.

If a reservation is made or another service is booked, the data collected will be used to process this booking and for statistical purposes, all within the scope of legal requirements.

If you subscribe to our newsletter, we also store and use the data you provided about yourself and your reservations when booking or registering in order to give you optimum service as a newsletter subscriber.

4. LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

For the processing of personal data required for the performance of a contract to which the data subject is a party, the legal basis is our obligation to perform that contract. This also applies to processing that is required to perform any pre-contractual measures.

If the processing is necessary for the purposes of the legitimate interests pursued by us or by a third

party, except where such interests are overridden by the interests or fundamental rights and

freedoms of the data subject, the legal basis shall be our legitimate interest.

5. TRANSFER OF PERSONAL DATA TO THIRD PARTIES

We will only transfer your personal data in accordance with the applicable data protection regulations

Your data will be transferred to our sub-contractors or other suppliers related to your booking (e.g. payment processors, IT service providers, support staff) if this is necessary for us to fulfil our contractual obligations and to provide you with the services you have booked.

Data will also be transferred to persons or companies to process your reservation or booking, particularly for bookings made via third-party service provider such as bed banks. The privacy provisions in the domicile of these persons and companies may differ from those at our location, but we will take reasonable steps to ensure the data we pass to them remains secure.

Your data will also be disclosed and sent to third parties if we are obliged to do this by law or on orders of a competent authority.

You have the right to receive a copy of your personal data which you have provided to us in a structured, commonly used and machine-readable format. You also have the right to transmit this data to another controller if you so wish.

6. STORAGE AND ERASURE OF DATA

Your personal data will be stored in accordance with the purposes listed under “Purpose of collecting personal data”. The data will be erased or blocked once the purpose ceases to apply. Data may be stored according to the laws or other regulations to which the controller is subject.

7. RIGHT OF ACCESS / REVOCATION; OTHER RIGHTS OF DATA SUBJECTS

You have the right:

• to obtain from us confirmation as to whether personal data concerning you are being processed. In particular, you can obtain information on the purposes of the processing, the categories of personal data, categories of recipients to whom your data has been or will be disclosed, the planned duration of storage, the existence of a right to rectification, erasure, restriction of processing or to object, the existence of a right to lodge a complaint, the origin of the data, if this has not been collected by us, and on the existence of automated decision- making including profiling and any meaningful information on the details.
• to obtain the erasure of personal data concerning you stored by us unless the processing is necessary to fulfil a legal obligation, for reasons of public interest or for the establishment, exercise or defence of legal claims;
• to obtain the restriction of processing of your personal data, where the accuracy of the personal data is contested by you, the processing is unlawful but you oppose the erasure of the personal data, or we no longer need the data, but you require them or the establishment, exercise or defence of legal claims or you have objected
• to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format or request the transmission to another controller;
• to withdraw the consent you once provided to us at any time. This will mean that we will no longer be able to continue the data processing relating to this consent in the future, and
• to lodge a complaint with a supervisory authority. Generally, you may contact the supervisory authority at your usual place of residence or workplace or at our registered office.

In order to withdraw your consent to data usage, to exercise your right of access, or request the rectification, blocking or erasure or to exercise your other rights as a data subject, please contact:

Address: CUG Travel Ltd T/a www.unlockedhotels.com 15 Bexhill Road, Eastbourne, East Sussex, BN22 7JH

Email: info@cugtravel.co.uk

These rights are available to you free of charge.

8. SECURITY, QUESTIONS AND REMARKS, CONTROLLER

Security also depends ultimately on your system. You should always treat your access information as confidential, never allow your browser to save passwords unless it is secure and close the browser window when you leave our website. This makes it more difficult for third parties to access your personal data.

Use an operating system that can manage user rights. Always set up different user profiles, including amongst users, and never use the internet under administrator rights. Use security software such as virus scanners and firewalls and always keep your system up to date.

The controller for this online presence as defined by the General Data Protection Regulations and other national data protection laws is:

Address: CUG Travel Ltd 15 Bexhill Road, Eastbourne, East Sussex, BN22 7JH

Email: info@cugtravel.co.uk

9. NEWSLETTER – UNSUBSCRIBING

If you no longer wish to receive our newsletter or our advertising emails, click on the link: “Unsubscribe from newsletter ” which appears at the bottom of every email from us.

How we get the personal information and why we have it

Most of the personal information we process is provided to us directly by you for one of the following reasons:

• For records of who will stay in an accommodation we must record the names of all guests who will stay / reside in the booked rooms / accommodation by the provider and or in line with local laws.

We use the information that you have given us in order to provide names only to the booking partner and accommodation, or to contact you with order information and  updates.

Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:

(a) Your consent. You can remove your consent at any time. You can do this by contacting info@cugtravel.co.uk

(b) We have a contractual obligation.

(c) We have a legal obligation.

(d) We have a vital interest.

(e) We need it to perform a public task.

(f) We have a legitimate interest.

How we store your personal information

Your information is securely stored.

We keep Name, Address, Email, Telephone number for 24 Months We will then dispose your information by deletion from our servers / data base. If your membership remains in place we will keep your membership information for the duration of your membership.

Your data protection rights

Under data protection law, you have rights including:

Your right of access - You have the right to ask us for copies of your personal information.

Your right to rectification - You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Your right to erasure - You have the right to ask us to erase your personal information in certain circumstances.

Your right to restriction of processing - You have the right to ask us to restrict the processing of your personal information in certain circumstances.

Your right to object to processing - You have the the right to object to the processing of your personal information in certain circumstances.

Your right to data portability - You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.

Please contact us at info@cugtravel.co.uk 15 Bexhill Road, Eastbourne, East Sussex if you wish to make a request.

How to complain

If you have any concerns about our use of your personal information, you can make a complaint to us at info@cugtravel.co.uk

You can also complain to the ICO if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Helpline number: 0303 123 1113

ICO website: https://www.ico.org.uk