GlobeTribe Limited - Privacy Notice
General Information Protection Regulation (“GDPR”)
We are concerned about protecting and respecting your privacy.
The purpose of this Notice is to:
Reassure you that GlobeTribe Limited (“GlobeTribe”) fully respect your privacy and the information relating to you, otherwise known as your Personal Data, which is provided to us
Describe the personal data that we collect about you, how it is used and shared, and your rights in relation to it
Who we are ?
GlodeTribe is a company that operates a website which:
(a) Enables owners of property available for short term holiday lettings to list and advertise their property to potential clients; and
(b) Enables persons seeking a property for short term holiday rental to locate a suitable property and rent it by dealing directly with the owner;
(c) Provides information to those who register their properties with us or who complete our online enquiry and/or booking forms including commercial and promotional information.
GlobeTribe is registered with the Information Commissioner’s Office (ICO) as a Data Controller for the Personal Data that it holds and processes and its registration number is [ insert number ].
What information does GlobeTribe collect about you?
GlobeTribe collects, uses and is responsible for personal information about you. When Globetribe does this it is the ‘controller’ of this information for the purposes of the GDPR and the Data Protection Act 2018.
If you need to contact Globetribe about your information or the processing carried out you can use the contact details at the end of this document.
We may collect your personal data in one of the following ways.
Through you registering with us in order to advertise your property on our website. You register by completing the registration form and providing directly to this site your personal data. The Personal Data collected may include: ZIP code, city, surname, relative data to the company, email, image, profile picture, address, billing address, language, country, name, phone number, business sector, website and username.
Through you, as a potential customer, completing our online enquiry and/or booking forms. The personal data collected may include surname, first name, email address, other contact details, details of your holiday party and any requests for further information, quotes etc
GlobeTribe does not use automated decision-making in the processing of your personal data.
Please bear in mind that if you choose not to provide personal data requested by us, or if you object to our processing your personal data, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the personal data.
How GlobeTribe uses your personal information
GlobeTribe may use your personal information for the following purposes:
(a) to promote and advertise owners’ property to potential clients;
(b) to provide details of potential clients who are interesting in renting a property to owners;
(c) to facilitate communication between owners and clients;
(d) to keep you informed about relevant promotional information, offers etc by email and/or through our mailing list and/or newsletter. You may be contacted by email, telephone or by post for marketing purposes relating to our services and/or to research opinion on proposed legal or business developments where legally permitted to do so, unless you let us know that you do not want to receive this type of marketing. You have the right to object to this processing if you wish and if you wish to do so, please see section entitled Marketing Opt-Out below;
(e) on an aggregated but anonymised basis to analyse how to improve the service that staff and members provide to clients including with Google Analytics (Google Inc.);
Google Analytics is a web analytics service provided by Google Inc. ("Google"). Google uses Personal Information collected for the purpose of track and examine the use of this Application, fill out report and share them with other services developed by Google. Google may use Personal Data to contextualize and customize the ads of your advertising network;
(f) to protect our rights as a company including, for instance, our intellectual property;
(g) to try and resolve any disputes between owners and clients;
(h) prevent potentially prohibited or illegal activities;
(i) to enforce our Terms and Conditions; and
(j) as otherwise described to you at the point of collection.
Marketing and promotion
In relation to personal information collected for marketing purposes, the personal information consists of your name, name of your organisation and contact details including your email address.
This will be processed so that you can be provided with information about promotional information, offers etc.
You may contact GlobeTribe using the contact details at the end of this document if you no longer wish to receive such invitations or information.
The legal basis for processing your personal information
GlobeTribe relies on the following as the lawful bases to collect and use your personal information:
If you have consented to the processing of your personal information, then GlobeTribe may process your information for the purposes set out above to the extent to which you have consented to us doing so
performance of a contract with the data subject or to take steps to enter into a contract.
Compliance with a legal obligation.
In addition we may collect and use your personal information for the purposes of the following legitimate interests of ourselves or a third party (except where such interests are overridden by the interests, rights or freedoms of the data subject):
For research purposes
To make, investigate, respond to or address complaints or concerns, including any legal or regulatory action.
To ensure network and information security, including preventing unauthorised access to personal data.
To assess and improve our services.
For marketing purposes.
To report possible criminal acts or threats to public security.
Who will GlobeTribe share your personal information with ?
It may be necessary to share your information with the following:
Potential clients who have enquired about and who may wish to rent an owner’s property
other regulatory authorities
Where such sharing takes place, GlobeTribe will take all reasonable steps to ensure that your personal data is processed in compliance with the GDPR. A list of third-party and sub-processors may be requested from GlobeTribe at any time.
GlobeTribe may be required to provide your information to regulators, such as the Financial Conduct Authority or the Information Commissioner’s Office. In the case of the Information Commissioner’s Office, there is a risk that your information may lawfully be disclosed by them for the purpose of any other civil or criminal proceedings, without GlobeTribe’s consent or your consent, which includes privileged information.
GlobeTribe may also be required to disclose your information to the police or intelligence services, where required or permitted by law.
Special Categories of Personal Information
Certain types of personal information, such as some government-issued identification numbers, religion, health or sexuality, are considered sensitive and require additional protection under applicable laws. We limit the circumstances under which we may collect sensitive personal information; examples of this information include the following:
Health-related information may be needed for you to arrange or book appropriate travel accommodation and accessibility or facility requirements;
Government-issued identification numbers like passport or driver’s license number may be required for vehicle rental or other travel reservation
Other information that you can specify at your option and which may imply or suggest information like religion, health or other information, such as dietary needs.
Transfer of your information outside the European Economic Area (EEA)
This privacy notice is of general application and as such it is not possible to state whether it will be necessary to transfer your information out of the EEA in any particular instance. However, if you reside outside the EEA then it may be necessary to transfer some of your information to a country outside of the EEA for the purposes of marketing your property or facilitating an enquiry about your property or request to rent it by a potential client. If this applies to you and you wish additional precautions to be taken in respect of your information please contact us to discuss and, if possible facilitate this.
Some countries and organisations outside the EEA have been assessed by the European Commission and their information protection laws and procedures found to show adequate protection. Most do not. If your information has to be transferred outside the EEA, then it may not have the same protections and you may not have the same rights as you would within the EEA.
GlobeTribe stores personal data on a secure data management system. The personal data is processed through our website and at our offices.
Your personal data is stored on secure servers in the European Economic Area (EEA).
GlobeTribe will take reasonable technical and organisational precautions to prevent unauthorised access, disclosure, modification, or unauthorised destruction of your personal data.
How long will GlobeTribe store your personal information?
GlobeTribe will not keep personal data longer than required for our legitimate business purposes and those of the owners and clients who use our website.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise the data or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
We will anonymise or aggregate your data if we intend to use it for analytical purposes or trend analysis over longer periods.
Names and contact details held for marketing purposes will be stored indefinitely or until GlobeTribe becomes aware or is informed that the individual has ceased to be a potential client.
As explained above, GlobeTribe may rely on your explicit consent to process your information including special category personal information.
You have the right to withdraw this consent at any time, but this will not affect the lawfulness of any processing activity carried out prior to you withdrawing your consent. However, where GlobeTribe also relies on other bases for processing your information, you may not be able to prevent processing of your information.
If there is an issue with the processing of your information, please contact GlobeTribe using the contact details below.
Under the GDPR, you have a number of rights that you can exercise in certain circumstances. These are free of charge. In summary, you may have the right to:
Ask for access to your personal information and other supplementary information;
Ask for correction of mistakes in your information or to complete missing information GlobeTribe holds on you;
Ask for your personal information to be erased, in certain circumstances;
Receive a copy of the personal information you have provided to me or have this information sent to a third party. This will be provided to you or the third party in a structured, commonly used and machine-readable format, e.g. a Word file;
Object at any time to processing of your personal information for direct marketing;
Object in certain other situations to the continued processing of your personal information;
Restrict the processing of your personal information in certain circumstances;
If you want more information about your rights under the GDPR please see the Guidance from the Information Commissioners Office on Individual's rights under the GDPR.
If you want to exercise any of these rights, please:
Use the contact details at the end of this document;
GlobeTribe may need to ask you to provide other information so that you can be identified;
Please provide a contact address so that you can be contacted to request further information to verify your identity;
Provide proof of your identity and address;
State the right or rights that you wish to exercise.
GlobeTribe will respond to you within one month from when it receives your request.
Please note if you wish to unsubscribe from any marketing emails that you have signed up for, you can do so by contacting GlobeTribe as below. It may take 14 days for this to become effective.
How to make a complaint ?
The GDPR also gives you the right to lodge a complaint with the Information Commissioners’ Office if you are in the UK, or with the supervisory authority of the Member State where you work, normally live or where the alleged infringement of information protection laws occurred. The Information Commissioner’s Office can be contacted at http://ico.org.uk/concerns/.
GlobeTribe does not intend to process your personal information except for the reasons stated within this privacy notice. If this changes, this privacy notice will be amended and the amended notice placed on GlobeTribe’s website.
Changes to this privacy notice
This privacy notice was published on 1st August 2018 and last updated on the 1st August 2018.
GlobeTribe continually reviews its privacy practices and may change this policy from time to time. When it does an amended privacy notice will be placed on the GlobeTribe website.
If you have any questions about this privacy notice or the information GlobeTribe holds about you, please contact GlobeTribe by [ insert details ]
Cookies and usage analytics
Traffic log cookies are used to identify which pages are being used. This helps those responsible for the upkeep and maintenance of this website to analyse personal data about webpage traffic and improve the website in order to tailor it to user needs. This information is only used for statistical analysis purposes and is then removed from the system.