1. CONTACT DETAILS
- By contacting our general customer services team at: firstname.lastname@example.org
- Or by contacting us via telephone at: +31 (0)20 261 64 33
2. HOW WE COLLECT YOUR INFORMATION
We collect your personal information when you interact with us or use our services, such as when you use our site to make a booking. We also look at how visitors use our Sites, to help us improve our services and optimise customer experience.
We collect information:
- when you place an order with us and during the booking process (including for payment and booking contact);
- when you contact us directly via email, phone, post and message and;
- when you browse and use our Sites (before and after you make a booking with us).
We also collect information from third party sites, such as analytics and advertising platforms and our fraud detection provider.
3. INFORMATION THAT WE COLLECT FROM YOU
When you visit the Sites or make a booking at Sherlocked, you are asked to provide information about yourself including your name, contact details and payment information.
We also collect information about your usage of the Sites and information about you from any messages you post to the Sites or when you contact us or provide us with feedback, including via e-mail, letter, phone or facebook.
We collect technical information from your mobile device or computer, such as its operating system, the device and connection type and the IP address from which you are accessing our Sites.
4. USE OF YOUR INFORMATION
We will only process the data we collect about you if there is a reason for doing so, and if that reason is permitted under data protection law. We will have a lawful basis for processing your information: if we need to process your information in order to provide you with the service you have requested or to enter into a contract; we have your consent; we have a justifiable reason for processing your data; or we are under a legal obligation to do so.
Where we need to in order to provide you with the service you have requested or to enter into a contract, we use your information:
- to supply the services you have requested;
- to enable us to collect payment from you; and
- to contact you where necessary concerning our services, such as to resolve issues you may have with your booking.
6. DIRECT MARKETING
Where you have given your consent and where we are permitted to do so by law, we will use your information to let you know about our other products and services that may be of interest to you. At any moment you can unsubscribe by either emailing us directly at email@example.com or by clicking the unsubscribe button in the newsletter.
7. RETENTION OF YOUR INFORMATION
We will not retain your information for any longer than we deem necessary.
Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the ‘Use of your information’ section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes.
When determining the relevant retention periods, we will take into account factors including:
our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on ‘How we use your personal information’ above);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, we securely erase your information where we no longer require your information for the purposes collected.
8. DISCLOSURE OF YOUR INFORMATION
The information we collect about you will be transferred to and stored on our servers located within the EU. We are very careful and transparent about who else your information is shared with.
We share your information with third party service providers. The types of third party service providers whom we share your information with includes:
- Payment providers (including online payment providers and fraud detection providers): for the purposes of providing services to us, for example when they process information such as credit card payments for us, provide support services to you or carry out fraud checks for us;
- IT service providers (including cloud providers): for the purposes of data storage and analysis;
- Marketing and advertising partners: so that they can ensure that you see advertising which is more relevant to you and send you email marketing on our behalf.
If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
We may also share your information:
- if we are under a duty to disclose or share your information in order to comply with (and/or where we believe we are under a duty to comply with) any legal obligation or regulatory requirement. This includes exchanging information with other companies and other organisations for the purposes of fraud protection and prevention;
- in order to enforce our contractual terms with you and any other agreement;
- to protect the rights of Sherlocked, our guests and our employees or others, including to prevent fraud; and
- with such third parties as we reasonably consider necessary in order to prevent crime, e.g. the police.
We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected.
We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
10. YOUR RIGHTS
Under data protection law, you may have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our customer service using the contact details set out above. For additional information on your rights please contact your data protection authority and see below.
The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this policy.
The right of access. You have the right to obtain access to your information (if we’re processing it). This will enable you, for example, to check that we’re using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).
The right to erasure. This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details).
The right to restrict processing. You have rights to ‘block’ or ‘suppress’ further use of your information. When processing is restricted, we can still store your information, but will not use it further.
The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.
The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by unsubscribing from our newsletter or by disabling cookies as set out in sections 5 and 6 above.
If you have any questions or complaints, please contact us via firstname.lastname@example.org and we’ll do our best to resolve any issues swiftly.
If you’re not satisfied with our response to any complaint, you can also make a complaint to the Autoriteit Persoonsgegevens (AP) using the following details:
Either by mail to: Autoriteit Persoonsgegevens, Postbus 93374, 2509 AJ in Den Haag
Or by phone: 088 – 1805 250