Effective Date: 1st March 2017
HSB truly respects the privacy of its users, and is fully committed to protect their personal information and use it properly. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
1. Your Consent
This policy describes our privacy practices – what information we collect on our visitors and users, how we collect it, what we do with it, how we protect it, and your rights regarding your information.
Please note: you are not obligated by law to provide us with any information. You hereby acknowledge, warrant and agree that any information you do provide us is provided of your own free will and consent, for the purposes and uses described herein.
There are two main methods we use:
- 1. We collect information through your use of the Services. In other words, when you are visiting or using our Services, including when you browse the Website or any Owner Website, register an Owner Account, edit your Owner Website and upload information and content, and/or download and use any HSB Apps and/or Mobile Apps, we are aware of it any may gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services, including through the use of “cookies” and other tracking technologies, as further detailed below.
- 2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services;
We collect two types of information: Personal Information (which could be used to uniquely identify an individual) and Non-personal Information (which is non-identifying).
2. What Information Do We Collect?
When you visit or use our services – you may also provide us with certain information (either automatically through your uses, or by manually submitting it).
3. How Do We Collect Such Information?
We collect such Non-personal and Personal Information for the following purposes:
- 1. To provide and operate the Services;
- 2. To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
- 3. To provide our Users with ongoing customer assistance and technical support;
- 4. To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages;
- 5. To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
- 6. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
- 7. To enhance our data security and fraud prevention capabilities;
- 8. To comply with any applicable laws and regulations.
4. Why Do We Collect Such Information?
We collect and use information in order to provide our services and make them better and safer.
We also collect and use information in order to contact our visitors, users and job applicants, and in order to comply with the laws applicable to us.
5. Where Do We Store Your Information?
We store and process Personal Information subject to this policy in the UK, USA, Europe, or other jurisdictions, whether by ourselves or with the help of our affiliates and service providers.
HSB’s data storage providers are committed to protect and secure your data.
HSB may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with HSB, on the User’s behalf.
For such purposes, HSB serves and shall be considered as a “Data Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Data Protection Directive) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining any consents and permissions required for the collection and usage of such information.
HSB cannot provide legal advice to Owners or Holidaymakers, however we do recommend that all Owners publish and maintain clear and comprehensive privacy policies on their own Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
If you are a Holidaymaker, please read the following: HSB has no direct relationship with the individual Holidaymakers whose Personal Information it processes. If you are a visitor, user or customer of any of our Owners, and would like to make any requests or queries regarding your Personal Information, please contact such Owner(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by HSB on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Holidaymakers’ Personal Information, we will respond to such request within thirty (30) days.
8. Sharing Personal Information with Third Parties
We may share the information of our Owners or Holidaymakers with various third parties, including certain service providers, law enforcement officials and application developers.
The information may be shared solely in accordance with this policy.
HSB, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Users and their Users-of-Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Users preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by HSB, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called clear gifs (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however unlike cookies these are not stored on your device, but are instead embedded within our Services.
By subscribing to any Services (including to any of our newsletters, blogs, social media accounts or public events) and providing HSB with your e-mail address or any other contact information (such as your phone number or social media handle), you expressly agree to receive promotional content, messages or calls from HSB or our partners (acting on HSB’s behalf) through such means.
Accordingly, HSB and its partners shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages and similar forms of communication. If you wish not to receive such promotional messages, you may notify HSB at any time or follow the “unsubscribe” or STOP instructions contained in the promotional communications you receive.
10. Communications from HSB
You agree that we or our partners may send you promotional messages and content.You can easily opt-out of receiving promotional messages by contacting us or using the “unsubscribe” options provided by us.
If you wish to access and/or request us to make corrections to the Personal Information that you have stored with us (either Owners or your Holidaymakers’), or wish to request a list of what Personal Information (if any) pertaining to you we disclosed to third parties for direct marketing purposes, please send us an e-mail to email@example.com and we will respond within a reasonable timeframe and in accordance with any applicable law.
Note that you may also correct, update or remove certain parts of such Personal Information by yourself, or completely deactivate your User Account, through your Account settings.
11. Accessing Your Personal Information
You may request to access or correct the personal information you have stored with us, by sending us an e-mail or letter. You may also correct, update or remove certain information, or deactivate your account, through your account or website settings.
We may retain your Personal Information (as well as your Users-of-Users Information) for as long as your User Account is active or as otherwise needed to provide you with our Services.
We may continue to retain such Personal Information even after you deactivate your User Account and/or cease to use any particular Services, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our Owners or their Holidaymakers’, prevent fraud and abuse, enforce our agreements and/or protect our legitimate interests.
12. Data Retention
We may keep your information for as long as your account is active, and longer as needed (for example, if we are legally obligated to keep it further, or need it to protect our interests).
HSB has implemented security measures designed to protect the Personal Information you share with us, including physical, electronic and procedural measures. We regularly monitor our systems for possible vulnerabilities and attacks, and regularly seek new ways and Third Party Services for further enhancing the security of our Services and protection of our Visitors’ and Users’ privacy.
However – regardless of the measures and efforts taken by HSB, we cannot and do not guarantee the absolute protection and security of Owners Personal Information, your Holidaymakers’ Information or any other User Content you upload, publish or otherwise share with HSB or anyone else.
We therefore encourage you to set strong passwords for your Account and Website, and avoid providing us with any sensitive information which you believe its disclosure could cause you substantial or irreparable harm.
If you have any questions regarding the security of our Services, you are more than welcome to contact us at firstname.lastname@example.org.
We collect two types of information regarding our Owners and Holidaymakers:
- 1. Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
- 2. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third-party accounts (such as the e-mail or username for a connected PayPal, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
13.1 Holidaymakers’ Information
We may also collect similar information pertaining to visitors and users of our Owner’s Websites (“Holidaymakers”), solely for and on our Owners’ behalf
13.2 Third Party Services:
HSB has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement and data optimization services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Owners’ and Holidaymakers’ Personal Information – depending on each of their particular roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes.
13.3 Law Enforcement, Legal Requests and Duties:
HSB may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have a good faith belief that the law requires us to do so, with or without notice to you.
13.4 Protecting Rights and Safety:
HSB may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of HSB, any of our Owners’ and Holidaymakers’, with or without notice to you.
Our Services include certain Social Media features and widgets, such as the “Facebook Connect” or “Google Sign-in” features, “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”). These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
13.5 Service and Billing Messages:
HSB may also contact you with important information regarding our Services, or your use thereof.
For example, we may send you a notice (through any of the means available to us) if a certain Service is temporarily suspended for maintenance; reply to your support ticket or e-mail; send you reminders or warnings regarding upcoming or late payments for your current or upcoming subscriptions; forward abuse complaints regarding your Website; or notify you of material changes in our Services.
You will not be able to opt-out of receiving such Service and Billing Messages.
14. Public Forums and User Content
Our Services offer publicly accessible blogs, communities and support forums. Be aware that any information you provide in any such areas may be read, collected, and used by others who access them. To request removal of your Personal Information from our blogs, communities or forums, feel free to contact us at: privacy@Holidaysitebuilder.com. In some cases, we may not be able to remove your Personal Information from such areas. For example, if you use a third party application to post a comment (e.g., the Facebook social plugin application) while logged in to your related profile with such third party, you will need to login into such application or contact its provider if you want to have the Personal Information you posted through it removed.
In any event, we recommend that you do not post any information (or use any posting means to post information) you would not want to be made public on these areas.
If you upload any User Content to your User Account or post it on your User Website, you do so at your own risk.
We cannot control the actions of other Users or members of the public who may access your User Content, and are not responsible for the circumvention of any privacy settings or security measures you or us may have placed on your User Website (including, for instance, password-protected areas on your User Website). You understand and acknowledge that, even after its removal by you or us, copies of User Content may remain viewable in cached and archived pages or if any third parties (including any of your Users-of-Users) have copied or stored such User Content. Again, we recommend that you do not upload or post any information you would not want to be publicly available.