This Privacy Notice explains types of personal information we may collect about you when you interact with us. It also explains how we will store and handle that information, as well as keep it safe and secure.
We will keep our privacy notice under regular review and will advise you of any updates on our website.
This Notice was last reviewed in May 2018.
- Who we are
Ski Verbier Exclusive Limited and Ski Verbier Ltd are subsidiaries of Verbier Exclusive Limited, which is incorporated in England (company registration number 7018564). Our registered offices are Fairfax House, Cromwell Park, Chipping Norton, Oxfordshire, OX7 5SR. For the purposes of Data Protection legislation Ski Verbier Exclusive Limited is the Data Controller.
As Data Controller we must:
- use your personal information fairly and lawfully
- only use your personal information for the purposes it has been provided for, unless required to by law
- only collect as much personal information as needed for the services you require
- keep your personal information accurate and up to date
- only keep your information for as long as necessary
- use your personal information in accordance with your rights
- keep your personal information safe and secure
- not transfer your personal information outside the European Economic Area unless adequate levels of protection are in place
- What is personal information?
Personal information is defined as any information which relates to a living individual who can be identified either:
- from the information we hold, or
- from the information combined with any other information which is already in the possession of, or likely to come into the possession of, the person or organisation holding the information
Personal information also includes any expression of opinions about an individual, and any indication of the intentions of the data controller (i.e. the Company) or any other person in respect of the individual.
- What type of personal information do we collect?
We collect a range of personal information depending upon whether you are booking a holiday, or are, for example, a prospective candidate for a job. Set out below are some examples of the types of personal information that we may collect:
- Personal details such as names, addresses, telephone numbers, date of birth, height, weight and shoe size
- Bank and credit card details
- Dietary information
- Information about people travelling with you
- Personality and character references
- Education and training details
- Employment details
- Financial details
- Pension details
- Racial or ethnic origin
- Physical health or mental condition
- Information relating to health and safety
- Medical information
- Complaints, accidents, incident details
- Sounds and visual images (such as CCTV images)
If we need to collect personal information not covered in this list you will be informed by us.
- How do we collect personal information?
We may collect your personal information in a number of ways, for example:
- Forms you have completed and given to us
- Contact you have made with us through our website, telephone, emails or letters you have sent to us, as well as contact made through social media sites operated by the Company
- CCTV images
- When you apply for a job vacancy
- When you enter a competition
- Referrals made to us from outside organisations
- We may also take photographs at our events, our properties and in our communities to use for general marketing and publicity. However, photographs of individuals will only be used for these purposes with consent.
- Why do we collect your personal information?
We hold and use personal information for the following purposes:
- To fulfil your travel arrangements and deliver the services that you have asked for
- To provide services tailored to your requirements and to treat you in a more personal way
- Advertising, marketing and public relations
- Staff administration
- Accounts and records
- Property management
- Other commercial activities
- Information and administration
- Pensions administration
- Who might we share your personal information with?
We obtain and share personal information with a wide variety of sources, which include but are not limited to:
- Third party suppliers in resort and elsewhere in order for us to organise the logistics of your holiday as efficiently as possible
- Individuals themselves or professionals appointed by the individual to act on their behalf
- Data processors that work on behalf of the Company
- Advertisers, ad servers and ad networks (but this will not include any information that directly identifies you)
Individual services may share your personal information with other organisations which are relevant in order to provide the service they are carrying out on your behalf. In these instances, the service area should inform you who they intend to share your personal information with.
- How long will we keep your personal information?
We will only keep your personal information for as long as necessary. At the end of the retention period, or the life of a particular record, it will be reviewed and deleted, unless there is any special reason for keeping it.
- What is our legal basis for using your personal information?
To use your personal information there must be a lawful basis to do this. These are, consent, contract, legal obligation, vital interest, public tasks and legitimate interest. In most cases the processing must also be necessary.
The legal bases upon which we hold your information include consent, contract and legitimate interest. The specific legal basis will depend upon the reason or reasons why we collected and need to use your information.
The GDPR sets a high standard for consent to use people’s information. Consent requires a positive opt-in. Pre-ticked boxes or any other consent method by default is no longer allowed. We will not generally rely on consent as a basis for processing personal data. In the limited circumstances where we may rely upon consent, we will specifically obtain this in the course of collecting the data.
If consent is the only legal basis used to process your personal information, you can withdraw your consent at any time. Consent can be withdrawn online, by email, telephone or face-to-face. Our email address is firstname.lastname@example.org. Our telephone number is +44 (0) 1608 674 011. Our address is set out above. Alternatively, you can follow the opt out or unsubscribe instructions in the relevant communication.
This is when we need to process your personal data to fulfil a contractual obligation to you, for example, to process your holiday booking, fulfil your travel arrangements and otherwise perform the contract we have with you.
This is the most flexible lawful basis and it can be our interests or interests of third parties. It can include commercial interests, which is what we rely on in our case. We need to process your personal data in order to effectively run our business and we have a legitimate interest as a travel company to use your personal information to operate and improve our business.
- Direct Marketing
The Company may occasionally want to use your name and contact details to inform you of holidays, offers and services. If the Company wishes to use your personal information for these purposes we will always ask for your explicit consent before doing so.
Unless you are told otherwise, this information will not be shared with third parties and you can unsubscribe at any time by phoning +44 (0) 1608 674 011 or emailing email@example.com or by clicking the ‘unsubscribe’ button on our marketing emails.
You will always be asked to opt-in to direct marketing and this should always be a clear, affirmative action, such as ticking an opt-in box.
Any information you provide us for marketing purposes will be kept with us until you notify us that you no longer wish to receive this information.
- Visitors to our website
- How do we keep your personal information secure?
We recognise the professional responsibility we have to safeguard the information of individuals. The security of your personal information is important to us and we follow a range of security policies and procedures to ensure that access to and use of your information is controlled and appropriate.
Some examples of our security measures include:
- Controlling access to Company systems and networks preventing any unauthorised access to your personal information
- Using encryption methods such as passwords so that only people with specific access rights can view it
- Pseudonymisation, meaning that we will change some personal details such as name, date of birth etc. so that someone with access to the data will not know whose personal information it belongs to
- Our staff are regularly trained in data protection to make them aware of their responsibilities when using personal information and how and when to report if something goes wrong
- We regularly test our technology and working practices to keep up to date on the latest security update
- Is your personal information used overseas?
The Company will process your personal information outside of the European Economic Area (EEA) because it operates in Switzerland which is outside of the EEA. In such instances where your personal information needs to be transferred to a country or territory outside the EEA that country or country or territory must ensure an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.
- What are your rights?
Your individual rights are set out in law. Subject to some legal exemptions, you have the following rights:
Right to be informed
You have the right to know about the collection and use of your personal information, including:
- Why it is collected
- How it is used
- Who it is shared with
- How long it is kept for
Right of access
You have the right to obtain a copy of your personal information and supplementary information to understand how and why we are your information and that we are using it lawfully. This is commonly known as a Subject Access Request (SAR). This should be made in writing to the Data Protection Officer (DPO) whose contact details are set out in section 15. You should give details of your name and postal address and details of your request and any details which would help us to locate the information, for example, booking reference. In addition you will need to provide us with proof of identity, e.g. copy of your birth certificate, passport or driving licence.
Right to rectification
You have the right to have inaccurate personal information rectified. You also have the right to have incomplete personal information completed – although this may depend on the reasons for using your personal information.
Right to erasure
In certain circumstances you have the right to have your personal information erased. This is also known as the ‘right to be forgotten’. The right to erasure does not apply to all cases such as complying with a legal obligation, performing a task set out in the public interest or for the establishment, exercise or defence of legal rights.
Right to restrict processing
You have the right to request the Company to restrict using your personal information in some circumstances. This may be because you are challenging the accuracy of the information and we are verifying the accuracy of the data. In most cases we will not need to restrict using your personal information indefinitely but will need to have the restriction in place for a certain period of time.
Right to data portability
You have the right to receive personal data you have provided to us in a structured, commonly used and machine-readable format. Individuals also have the right to request that a controller transmits this data directly to another controller – this is commonly used for banking and insurance purposes when wanting to switch providers.
Right to object
You have the right to object to the Company using your personal information. The right to object only applies in certain circumstances and requests to object to our using personal information will be considered on an individual basis. The Company will be unable to stop using personal information if it is needed to carry out a statutory function.
Rights in relation to automated decision making and profiling
Automated individual decision-making is a decision made by automated means without any human involvement. An example of this would be an online decision to award a loan. Profiling can be used to find out about individuals’ preferences, predict behaviour or make decisions about people. The Company will not make any solely automated decisions on you that have any legal or similarly significant event on you.
- Contact us
If you would like to exercise your rights in relation to your personal information, or you feel that something has gone wrong with your personal information, you can contact our Data Protection Officer (DPO) in either of the following ways:
By email: firstname.lastname@example.org
By telephone: +44 (0) 1608 674 011
In writing: Fairfax House, Cromwell Park, Chipping Norton, Oxfordshire, OX7 5SR.
If you feel that the Company has not handled your information correctly you can contact the Data Protection Officer at the above contact details or the Information Commissioner’s Office (ICO). The ICO is the Government’s Independent Body responsible for overseeing data protection. In most cases the ICO will only review cases that have exhausted the Company’s internal procedures.
The ICO’s contact details are as follows: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF. More information can be found on the ICO’s website at www.ico.org.uk