Privacy Policy

  1. Introduction and important information

Tanya Frisby owner of Darwin Cottage, Jevington (“We” or “us”) is committed to protecting and respecting your personal data and privacy.

This privacy policy relates to how we use and collect personal data from you when you book with us as a guest in our self-catering accommodation, use our services or access our website. It also relates to our use of any personal information you provide to us by telephone (including SMS), in written correspondence (including letter and email) and in person. Bookings made via the Awaze group will be subject to their Privacy Policy.

Please note that:

  • our website is not intended for children under the age of 18 and we do not collect data relating to children; and
  • our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

Whenever you provide personal data, we are legally obliged to use your information in line with all applicable laws concerning the protection of such information; including but not limited to the Data Protection Act 2018 and the General Data Protection Regulation 2016 (GDPR), described in this policy as the “Data Protection Laws”.

This privacy policy also forms part of our terms of business and is not intended to override them. This policy may be amended or updated from time to time and any revisions will be posted to this page, so please check back regularly.

    • For the purpose of the Data Protection Laws, the data controller for Darwin Cottage is [Tanya Frisby]. If you want to request more information about our privacy policy or information regarding data protection you should contact us using the details provided below:

FAO: Tanya Frisby

[Newton House, Jevington, Polegate, East Sussex, BN26 5QB]

United Kingdom

Email:              [tanya@thefrisbys.co.uk]

Telephone:      07739 233705 and ask to speak to the Privacy Officer.  [A1] 

  • www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
    • We collect and process personal data. Typically the personal data we collect and process will include identity, contract, transactional, technical, profile, usage and marketing and communications data such as:
      • Identity Data includes first name, last name, title or other identifier (such as job title), marital status, date of birth, gender and images.
      • Contact Data includes billing address, email addresses and telephone numbers.
      • Transaction Data includes details about services you have purchased from us or your visits to our premises.
      • Financial Data includes bank account and payment card details.
      • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
      • Profile Dataincludes your username and password, purchases or orders made by you, your interests, preferences (including details about your personal likes and dislikes as identified during your visits to our premises), feedback and survey responses.
      • Usage Data includes information about how you use our website, products and services.
      • Marketing and Communications dataincludes your preferences in receiving marketing from us and our third parties and your communication preferences.

Please note that we may collect and/or process other personal data from time to time. If we ask you to provide any other personal information not described above, the personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point that you are asked to provide your personal information.

    • We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
    • We only collect data from you directly or via third parties (see the section Third Parties below).
    • It is important that the Personal Data we hold about you is accurate and current. We cannot be held responsible for any inaccurate or incomplete data on our system arising out of your default in this regard. Please keep us informed if your Personal Data changes during your relationship with us.
      • As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy [LINK] for further details.
      • We will receive personal data about you from various third parties and public sources as set out below:

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel all or part of a service you have with us but we will notify you if this is the case at the time.

    • We use information held about you to:
      • carry out our obligations arising from any contracts entered into between you and us and provide our services, including any third party services we make available to you;
      • carry out feedback and research on our services; and
      • notify you about changes to our services.
    • We never sell your data to third parties or allow third parties to contact you without your permission.
    • We share your data with third parties where there is a legal obligation for us to do so or we have identified a valid lawful basis as set out in the table below (please also see clause 7 below). We may process your personal data without your knowledge or consent where this is required or permitted by law.
    • We have set out below in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity[A3] Type of dataLawful basis for processing including basis of legitimate interest
To register you as a guest.Identity ContactPerformance of a contract with you
To provide our self-catering accommodation and service(s) to you and to process related transactions, including: Manage payments, fees and charges Collect and recover money owed to usIdentity Contact Transaction Usage Marketing and CommunicationsPerformance of a contract with you Necessary for our legitimate interests [A4] (to recover debts due to us)
To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a surveyIdentity Contact Profile Marketing and CommunicationsPerformance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a competition or complete a surveyIdentity Contact Profile Usage Marketing and CommunicationsPerformance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).Identity Contact TechnicalNecessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation
To measure or understand the effectiveness of the advertising we serve to youIdentity Contact Profile Usage Marketing and Communications TechnicalNecessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, services, marketing, customer relationships and experiencesTechnical Usage ProfileNecessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about services that may be of interest to youIdentity Contact Technical Usage Profile Marketing and CommunicationsNecessary for our legitimate interests (to develop our products/services and grow our business)      
    • We only process your data (which may include providing it to a third party) where we have identified a valid lawful basis to do so. These are as follows:
      • Contractual obligation – means processing that is necessary to comply with our obligations arising out of a contract, for example, where you have bought services from us we will use the personal data you provide to fulfil our contractual obligations .
      • [A5] means in the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process you personal data for our legitimate interests. Where we use legitimate interests we will record our decision on making this decision. We rely on legitimate interest where processing of the data we hold on you does not, in our opinion, affect your rights or freedoms and is proportionate to our interests e.g. keeping you up to date with our latest services or obtaining your feedback on our service. 
      • Consent – We will seek to obtain your consent to process:
        • your data outside our contractual obligations (see above) unless we have identified a Legitimate Interest (see above); and
        • any special category data.
      • Legal obligation – We may process your data where we it is necessary for us to do so to comply with the law.
    • We will keep your information within the organisation except where disclosure is required or permitted by law or when we use third party service providers (data processors) to supply and support our services to you.  We have contracts in place with our data processors. This means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
  • Please see below the list which sets out the categories of recipients of personal data.
SERVICE PROVIDERS WHO MAY RECEIVE YOUR PERSONAL DATA[A6] LOCATION (e.g within the UK, EEA or outside of the UK/EEA)
IT Support ServicesUK/EEA
Email ProviderUK/EEA
Website ProviderUK/EEA
Secure document disposal serviceUK/EEA
BanksUK/EEA
Online payment providersUK/EEA
AccountantsUK/EEA
InsurersUK/EEA
SolicitorsUK/EEA
Software ProvidersUK/EEA
Feedback aggregators and collectorsUK/EEA
Couriers UK/EEA
Marketing AgenciesUK/EEA
    • 2.1.
  1. 11.          International transfers[A7] 
    1. 11.1       Your data is stored by us and our processors in the UK or the European Economic Area (EEA). However, several of our external third parties are based outside EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented. We will either:
      1. transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
      1. 11.1.2         ensure that standard contractual clauses (SCCs) are in place and we have received assurances that an adequate level of protection of the personal data is achieved (based on a case by case assessment of the circumstances of the transfer), including adequate technical and operational measures in place to protect the personal data.
    1. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
  2. 12.          Data security
    1. 3.2.
  1. APPLICATIONS to work for us

If you apply to work for us (directly or indirectly) in any role we may receive data about you from third parties. In addition, we will keep the details of your application and any additional information provided to us by you or others during your application so that we can keep you informed of future opportunities that you may be interested in. If you do not wish for us to keep your details for this reason, please let us know by contacting us using the details provided in this policy.

CHANGES TO THE PRIVACY POLICY We keep our privacy policy under regular review. This version was last updated on 02/02/2022.

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