Hotel Booking Agents Association (HBAA) has appointed a Data Protection Controller (DPC) who will endeavour to ensure that all personal data is processed in compliance with this Policy and the Principles of the Data Protection Act 1998. The Freedom of Information Act 2000 and the Protection of Freedoms Act 2012 are also relevant to parts of this policy.
Hotel Booking Agents Association (HBAA) recognises The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) adopted 27 April 2016, the two-year transition period and the application date of 25 May 2018 and is actively working towards compliance with that directive.
- we do not collect more information than is necessary;
- we do not use your data for purposes other than those specified;
- we do not keep your data if it is no longer needed;
- we do not farm your data out to third parties.
1. Information collection and tracking:
1.1. When you visit a website:
You can visit our website without giving away your personal information. The HBAA uses Google Analytic Services, ‘DoubleClick’ by Google and Cookies in order to improve our service, user experience and analyse how the website is used. Aside from the approximate location (IP address), the information collected by Google Analytics is mostly anonymous traffic data including browser information, device information, language; it may also help us to improve our service to you.
We do not collect additional information, such as your age, gender, interests, bank details or clickstream.
The collected information is used to provide an overview of how people are accessing and using the HBAA website. It is not used for any additional purpose, such as to profile those who access our website.
The website is hosted, managed and maintained within the UK by Moore-Wilson New Media Ltd, under the brand name of “Port Eighty Hosting” and is the ‘Data Processor’. As a UK company they are bound by the EU’s GDPR rules on data management.
Moore-Wilson New Media Ltd, 19 Garrick Street, Covent Garden, London, WC2E 9AX
PortEighty Hosting, Portway Centre, Spitfire Road, Old Sarum, Salisbury. Wiltshire. SP4 6EB
2. When you contact us:
While you can use our website without giving out your personal information, once you contact us via the HBAA website, the HBAA collects information about you.
The information you provide (personal information such as your name, email address, contact number and message) will be sent SSL encrypted and processed and stored so that it is possible for us to contact and respond to your request, and/or allow you access to our services.
2.1. Phone Calls:
All our calls are recorded for training and compliance purposes, we do not use the data from these calls for marketing purposes but to help us fulfill the role you ask of us at that time. Call data is ‘your data’ and as such is subject to the same rights as all other data covered under this policy.-->
If you apply for a job with the HBAA, we will collect, process and store the information you have sent us for recruitment-related purposes, such as contacting you. Additionally, The HBAA may keep your data for a period of time for the purpose of considering you for a different opportunity.-->
3. Email Marketing
Our site features email marketing in the form of a ‘Newsletter Signup’ managed by Mailchimp. We do not share this information with any other third parties without your explicit consent and you can unsubscribe from our newsletter at any time by either clicking the link in our.
Mailchimp is a trading name of The Rocket Science Group, registered at 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308 USA.
4. Social media and Social Media plug-ins:
Our website features three plug-ins for easy sharing and following our social media pages: Facebook, operated by Facebook Inc; LinkedIn and Twitter.
Being on our website does not automatically result in sharing data on these social media networks. These plugins remain inactive (idle) until clicked upon. Once clicked upon, you will be taken to the said social media networks with their own specific privacy policies which we recommend your view.
Our Social Media is managed by Capella Marketing, 3rd Floor, Fitzhardinge Street, London, W1H 3EF.
5. Information Security:
The HBAA cares to ensure the security of personal data. When the HBAA collects information about you, we also make sure that your information is protected from unauthorised access, loss, manipulation, falsification, destruction or unauthorised disclosure. This is done through appropriate technical measures.
In the event of a data breech or data loss we will notify you within 72 hours of the breech and have the necessary processes in place to respond to such events.
6. Access to information:
You have the right to request access to the information we have on you without charge. You can do this by contacting Catherine Mount at firstname.lastname@example.org.
We will provide you with a copy of all the data we have about you. In order to comply with your request, we may ask you to verify your identity.
We will fulfill your request by sending your copy electronically, unless the request expressly specifies a different method. For any subsequent access request outside what is either deemed reasonable or outside of what we are required by law to comply with, we may charge you with an administrative fee.
7. Information Correction & Deletion:
If you believe that the information we have about you is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for the purposes specified in Information Collection and Use will be deleted.
If at any point you wish for the HBAA to delete information about you, you can simply contact us.
The HBAA will not reduce your rights stated in this Policy without asking for explicit prior consent to the changes.
10. To sum up:
In accordance with applicable law, we only collect a limited amount of information about you that is necessary for improving our service.
We do not use profiling, we do not sell or in any other way spread your data to third parties, we do not use your data for purposes other than those we have specified.
We also make sure that your data is stored securely. We delete all information deemed no longer necessary.
11. You can contact us at any time to:
· Request access to information that the HBAA has about you
· Correct any information that the HBAA has about you
· Delete information that the HBAA has about you
If you have any additional questions about the HBAA’s collection and storage of data, please contact Catherine Mount:
Catherine Mount – Data Controller
MSS - Portland House
1 Coventry Road
Tel: 0845 5050 150
Company No. 03442834
11.1. The Right to complain:
As a consumer you have the right to complain or address any concerns about your data use. If you feel we have not addressed your concerns you can contact the ICO (Information Commissioners Office) to raise your concerns in confidence, we would request that in the first instance you contact us.
Glossary of terms
Cookies are small files or other pieces of data which are downloaded or stored on your computer or other device, that can be tied to information about your use of our website (including certain third party services and features offered as part of our website).
A device is what you use to reach our website, such as a smartphone, tablet or computer.
Internet Protocol (IP) address is a number that is connected to your device. An IP address can be used to determine the location of your device typically within a 40km radius, thus not being an exact determination of your location. IP addresses are basically how the Internet functions.
Personal information is information that can identify you. This can be your name, email, contact information or other type of information that can be traced back to you.