Privacy Policy
www.guest-protection.redkitehosts.com (our website) is provided by Red Kite Travel Ltd, trading as Red Kite (we, our or us). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR).
Given the nature of our website, we do not expect to collect the personal data of anyone under 13 years old. If you are aware that any personal data of anyone under 13 years old has been shared with our website please let us know so that we can delete that data.
This privacy policy is divided into the following sections:
- What this policy applies to
- Personal data we collect about you
- How your personal data is collected
- Marketing
- Who we share your personal data with
- How long your personal data will be kept
- Transferring your personal data out of the UK
- Cookies and other tracking technologies
- Your rights
- Keeping your personal data secure
- How to complain
- Changes to this policy
- How to contact us
What this policy applies to
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to make additional products and services available to you. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
- your name, address and contact information, including email address and telephone number
- biometric information to check and verify your identity, manage your booking, etc.
- your billing information, transaction and payment card or other payment method information
- bank account and payment details
- details of any information, feedback or other matters you give to us by phone, email, post or via social media
- your activities on, and use of, our website
- information about the services we provide to you
- information about how you use our website and technology systems
- your responses to surveys, competitions and promotions
You must provide this personal data to use our website and the services on it unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on your use of our website or any services on it.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
How your personal data is collected
We collect personal data from you:
- directly, when you enter or send us information, such as when you contact us (including via email), send us feedback, complete a online booking for one of our properties, post material to our website and complete customer surveys via our website, and
- indirectly, such as your browsing activity while on our website; we will usually collect information indirectly using the technologies explained in the section on ‘Cookies and other tracking technologies’ below
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
- where you have given consent
- to comply with our legal and regulatory obligations
- for the performance of a contract with you or to take steps at your request before entering into a contract, or
- for our legitimate interests or those of a third party
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
| What we use your personal data for | Our reasons |
|---|---|
| Creating and managing your account with us | For our legitimate interests—to deliver the best service efficiently. |
| Providing property booking services to you | To perform our contract with you or take steps before entering one. |
| Conducting checks to verify identity and prevent fraud | To comply with legal and regulatory obligations. |
| Managing your booking, including providing further checks and rearranging or cancelling certain bookings. | Your consent to manage the booking more effectively |
| Enforcing legal rights or defend or undertake legal proceedings. | Depending on the circumstances:
|
| Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
If you have provided such a consent you may withdraw it at any time by changing the setting on the cookies tool (this will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn) |
| Communications with you not related to marketing, including about changes to our terms or policies, changes to your booking or other important notices | Depending on the circumstances:
|
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us understand our customer base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Updating and enhancing customer records | Depending on the circumstances:
|
| Marketing our services to existing and former customers | For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information |
share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | Depending on the circumstances:
|
How and why we use your data in more detail
More details about how we use your personal data and why are set out in the table below.
| Purpose | Processing operation | Lawful basis relied on under UK GDPR | Relevant categories of personal data |
|---|---|---|---|
| Creating and managing your account with us | Processing your personal information in the creation and management of the account | Our legitimate interests (Article 6(1)(f)), which is to be as efficient as we can so we can deliver the best service to you | Your username, legal name, address and contact information, including email address and telephone number |
| Providing property booking services to you | Taking your details in order to secure the booking and provide information to the owners of the relevant property. | The necessity of taking this information to enable the performance of the contract that you are entering into regarding the booking (Article 6 (1)(b)). | Your biometric data, legal name, address and contact information, including email address and telephone number |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | Taking the details that you have provided upon making your booking and cross-referencing them against provided identification documentation | To comply with our legal and regulatory obligations to maintain security and prevent fraud (Article 6 (1)(c)). | Your legal name, address and identification documentation. |
| Enforcing legal rights or defend or undertake legal proceedings | Utilising your personal information in situations where we are required to bring legal action against any individuals or organisations. | To comply with our legal and regulatory obligations (Article 6 (1)(c)), or our legitimate interests (Article 6(1)(f)) in protecting our legal position. | Your username and account information, booking history, legal name, address and contact information, including email address and telephone number |
| Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | The use of cookies and other tracking technologies to tailor the features and settings on the website for the individual user experience. | Depending on the circumstances, your consent (Article 6(1)(a)), or our legitimate interests (Article 6(1)(f)) in improving the functionality of the website. | Your IP and access details, your account details and your preferences and use of the website. |
| Retaining and evaluating information on your recent visits to our website and how you move around different sections of our website for analytics purposes to understand how people use our website so that we can make it more intuitive or to check our website is working as intended | The use of cookies and other tracking technologies to alter the design or features of the website in response to your use of it. | Depending on the circumstances, your consent (Article 6(1)(a)), or our legitimate interests (Article 6(1)(f)) in improving the functionality of the website. | Your IP and access details, your account details and your preferences and use of the website. |
| Communications with you not related to marketing, including about changes to our terms or policies, changes to your booking or other important notices | The use of your email address to inform you of information that you may require in relation to your use of the website or the booking you make through the website. | To comply with our legal and regulatory obligations (Article 6 (1)(c)) regarding updates to terms, or our legitimate interests (Article 6(1)(f)) in informing the customer of relevant details. | Your email address and account details. |
| Protecting the security of systems and data used to provide the services | Utilising the provided personal information to ensure that information is secure and that no information or data has been compromised. | To comply with our legal and regulatory obligations (Article 6 (1)(c)). We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests (Article 6(1)(f)). | Your username and account information, booking history, legal name, address and contact information, including email address and telephone number |
| Statistical analysis to help us understand our customer base | Using your information in order to carry out analysis of the profile of our customers and to tailor our services accordingly. | For our legitimate interests (Article 6(1)(f))., ie to be as efficient as we can so we can deliver the best service to you at the best price | Your username and account information, booking history, legal name, address and contact information, including email address and telephone number |
| Updating and enhancing customer records | Keeping thorough and updated records of our customers to ensure that we can provide them with a quality service, that we can keep up-to-date records of their upcoming bookings, and keep them informed about the latest information about the Company. | Depending on the circumstances, to perform our contract with you or to take steps at your request before entering into a contract (Article 6 (1)(b)), to comply with our legal and regulatory obligations (Article 6 (1)(c)), or, where neither of the above apply, for our legitimate interests (Article 6 (1)(f)), eg making sure that we can keep in touch with our customers about existing orders and new products | Your username and account information, booking history, legal name, address and contact information, including email address and telephone number |
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant | Utilising existing personal information that we hold about our customers to demonstrate that we are complying with the legal and regulatory requirements placed upon the Company. | To comply with our legal and regulatory obligations (Article 6 (1)(c)). | Your username and account information, booking history, legal name, address and contact information, including email address and telephone number |
| Marketing our services to existing and former customers | Providing useful information for customers who have previously utilised our services. | For our legitimate interests (Article 6(1)(f)), ie to promote our business to existing and former customers | Your username and account information |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency | In a scenario where the Company is being sold or restructured, this will enable us to share your details with any other interested parties. | To comply with our legal and regulatory obligations (Article 6 (1)(c)), or our legitimate interests (Article 6(1)(f)) ie to protect, realise or grow the value in our business and assets | Your username and account information, booking history, legal name, address and contact information, including email address and telephone number |
How and why we use your personal data—Special category personal data
Certain personal data we collect is treated as a special category to which additional protections apply under data protection law:
- Biometric data, produced by a third party from photographic identifiers provided by you.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new booking opportunities.
You have the right to opt out of receiving marketing communications at any time by contacting us at hello@redkitehosts.com.
We may ask you to confirm or update your marketing preferences if you book with us again in the future, or if there are changes in the law, regulation, or the structure of our business.
We will always treat your personal data with the utmost respect and never share it with other organisations for marketing purposes.
For more information on your right to object at any time to your personal data being used for marketing purposes, see ‘Your rights’ below.
Who we share your personal data with
We routinely share personal data with:
- owners of any property that you may book through the website;
- third parties we use to help deliver our services to you, eg payment service providers;
- other third parties we use to help us run our business, eg website hosts and website analytics providers.
We only allow those organisations to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on them to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
- our external auditors, eg in relation to the audit of our accounts, in which case the recipient of the information will be bound by confidentiality obligations
- our and their professional advisors (such as lawyers and other advisors), in which case the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal and regulatory obligations
- other parties that have or may acquire control or ownership of our business (and our or their professional advisers) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised but this may not always be possible. The recipient of any of your personal data will be bound by confidentiality obligations.
Who we share your personal data with—in more detail
More details about who we share your personal data with and why are set out in the table below.
| Recipient | Processing operation (use) | Relevant categories of personal data |
|---|---|---|
| Stripe, Inc. | Processing booking payments. | Names, bank account details |
| Retool, Inc. | Administrative data management | Names, account details, booking details, contact information |
| Supabase, Inc. | Data and application storage | Names, account details, booking details, contact information |
| Amazon Web Services (AWS) | Data and application storage | Names, account details, booking details, contact information |
| Google LLC | File storage, analytics and reporting | Details of Bookings |
Who we share your personal data with—further information
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you stop using your account we will delete or anonymise your account data after seven years.
Following the end of the relevant retention period, we will delete or anonymise your personal data.
Transferring your personal data out of the UK
Countries outside the UK have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside the UK. In those cases we will comply with applicable UK laws designed to ensure the privacy of your personal data.
Under data protection laws, we can only transfer your personal data to a country outside the UK where:
- the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is available here.
- there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you, or
- a specific exception applies under relevant data protection law
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) legally-approved standard data protection clauses recognised or issued further to Article 46(2) of UK GDPR. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
Transferring your personal data out of the UK—in more detail
More details about the countries outside the UK to which your personal data is transferred are set out in the table below.
| Recipient country | Recipient | Processing operation (use) | Lawful safeguard |
|---|---|---|---|
| United States | Stripe, Inc. | Processing booking payments. | Adequacy regulation further to the Data Protection (Adequacy) (United States of America) Regulations 2023 |
| United States | Retool, Inc. | Administrative data management. | Adequacy regulation further to the Data Protection (Adequacy) (United States of America) Regulations 2023 |
| United States | Amazon Web Services LLC | Data and application storage. | Adequacy regulation further to the Data Protection (Adequacy) (United States of America) Regulations 2023 |
| United States | Supabase, Inc. | Database and authentication management. | Adequacy regulation further to the Data Protection (Adequacy) (United States of America) Regulations 2023 |
| United States | Google LLC. | File storage, analytics and reporting. | Adequacy regulation further to the Data Protection (Adequacy) (United States of America) Regulations 2023 |
Transferring your personal data out of the UK—further information
If you would like further information about data transferred outside the UK, please contact us (see ‘How to contact us’ below).
Your Rights
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data A more detailed explanation of this right under UK law is available here |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data A more detailed explanation of this right under UK law is available here |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations A more detailed explanation of this right under UK law is available here |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data A more detailed explanation of this right under UK law is available here |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations A more detailed explanation of this right under UK law is available here |
| To object to use | The right to object:
A more detailed explanation of this right under UK law is available here |
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website A more detailed explanation of this right under UK law is available here |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by emailing us at hello@redkitehosts.com Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under UK GDPR.
If you would like to exercise any of those rights, please email, call or write to us—see below: ‘How to contact us’. When contacting us please:
- provide enough information to identify yourself eg your full name, address and booking reference number) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your personal data and other information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner. They may be contacted using the details at https://ico.org.uk/make-a-complaint or by telephone: 0303 123 1113.
Changes to this privacy policy
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via including a prominent link to a description of those changes on our website for a reasonable period or by other means, such as email.
How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Our contact details
Arquen House, 4-6 Spicer Street, St. Albans, England, AL3 4PQ
hello@redkitehosts.com
01608 310076