Privacy Policy
Time Trails in Brittany's Digital Privacy Policy
This privacy policy (“Policy”) describes the types of personal data collected by Time Trails in Brittany through your use of our contact and/or enquiry forms, (“Online Facilities”), what happens to that personal data and your rights.
‘Personal data’ is essentially information from which an individual person can be identified.
The Policy is set out in sections so you can easily find the
specific areas you want to know.
Who are we?
Time Trails in Brittany is operated by Philip Dunn, of La Ville Mainguy, La Croix Hellean, Josselin, 56120, France. So when this policy refers to the “Time Trails in Brittany” that’s what we mean. Time Trails in Brittany may use your data on the basis set out in this Policy.
References to “we”, “us” and “our” in this Policy are all references to Time Trails in Brittany.
What does this policy cover?
This Policy applies to personal data collected by Time Trails in Brittany through your use of the Online Facilities.
Where personal data is collected and used for the purposes set out in this Policy, Time Traisl in Brittany are ‘data controllers’ under data protection law applicable in the EU (“Data Protection Law”).
You should read this Policy together with any other privacy information which may be provided on specific occasions when personal data about you is collected on the Online Facilities. That will ensure you are fully aware of how and why we are using your data. This Policy supplements any other notices and is not intended to override them.
What does this policy NOT cover?
Offline
This Policy does NOT apply in relation to any data you provide to Time Trails in Brittany through offline scenarios separate from the Online Facilities, such as written correspondence, unrelated telephone enquiries or in person.
Links to Third Party Websites and Services
We are not responsible or liable for the content, privacy notices or services offered by websites or apps other than the Online Facilities. We encourage you to read those notices.
This includes websites and apps which link from any of the Online
Facilities.
What information do we collect?
We may collect, use, store and transfer different kinds of personal data about you. For the purpose of this Policy we have grouped these together as follows:
- Identity Data such as your name(s) and title, date of birth and gender (where
relevant).
- Contact Data such as your address, billing address (where different), email address, preferred language and telephone numbers.
- Transaction Data such as details about
payments to and from you and other details of products or services you
have purchased from us.
- Technical Data such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types versions and statuses, operating system and platform and other technology on the devices you use to access the Online Facilities.
This site is hosted by Blogger.com who are responsible for the functionality of our Online Facilities. The Online Facilities may use cookies,
which are small files with a code that is stored on your device, with
your consent, and is retrieved when you next visit the
Online Facilities. This allows limited information about your use and browsing
to be recognised and utilised in an anonymised format by Time Trails in Brittany for information purposes only.
- Usage Data such as information about how
you use the Online Facilities and services provided through them. This may include information about page views, length
of visit or use and exit route, timing, frequency and patterns of your
use, along with navigation paths when using the Online Facilities – this
information does not directly identify you.
- Communications Data includes information
you provide when communicating with us, your preferences in receiving information from us and our third parties and (where relevant) any other
communication preferences.
- Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be generated from your personal data but does not directly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
If you fail to provide personal data
Use of services accessed through the Online Facilities may
require you to provide specific types of information. Where you fail, or are unable to
provide that information, we may not be able to perform the
contract we have or are trying to enter into with you. For example, we
may not be able to provide you with further details relating to your booking enquiry.
Children’s Data
We understand that children and young people, including those under 13 years of age (“minors”), may visit the Online Facilities or otherwise interact with us. Minors may need their parent or guardian’s permission to use or access certain facilities or receive certain information through the Online Facilities. Minors may also be asked to confirm they have that permission, and we reserve the right to verify parental or guardian consent, where required.
We try not to make a minor's participation in activities with us contingent on the minor disclosing any more personal information than is reasonably necessary in order to do so. We do not actively market to minors or use (or pass to any third party) personal information on persons known to be minors for any commercial purposes, without proper consent.
How do we collect your personal data?
We use different methods to collect data about you, including through:
- Direct interactions. You
may give us your Identity, Contact, Financial, Communication and
certain Profile Data by filling in forms or by corresponding with us
using contact details we provide on the Online Facilities. This
includes, amongst other things, personal data you provide when you:
request an iFollow or newsletter subscription); participate in
interactive features, including any competition, promotion or survey; or
give us feedback.
- Automated technologies or interactions. As
you interact with the Online Facilities, Technical & Usage Data
about your equipment, browsing actions and patterns may also be
collected or generated, along with Profile and Communications Data. Blogger.com, as the host of this site,
collects this personal data by using cookies, server logs and other
similar technologies. We do not receive data from other websites you
visit. Other websites may use cookies which activate beyond
their websites, including when you use the Online Facilities (you should
check the cookies policy of those websites in those instances).
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Technical & Usage Data from parties such as our analytics providers (including Google), and advertising networks (see below);
- Identity, Contact, Profile, Usage and/or Technical Data from social media platforms which are publicly available or through which you may log in or interact with the Online Facilities;
- Information from lawfully available sources where relevant to our bringing, defending or assisting in legal action (such as the police, regulators, investigators or publicly available sources).
We may, when necessary, also supplement the information collected with other information that we obtain from our dealings with you .
What do we use your personal data for?
We use information about you for the following purposes:
- Services, Products & Opportunities- to allow you to register your interest in our products and services and fulfil any of our obligations for delivery of those.
Processing your data for this purpose will usually be necessary (i) to perform any contract with you for the relevant service where applicable (ii) to comply with legal obligations where applicable or (iii) otherwise for our legitimate interests in complying with third party requirements which enable us to provide the service(s).
- Payments and Finance- to collect payments from you for any paid for products or services, and/or administer any payments which may become due to you. This will usually be necessary (i) to perform any contract with you for the paid for service or (ii) to comply with legal obligations where applicable or (iii) for our legitimate interests in recovering debts due to us.
- Publications– to include you in relevant publications, such as details of future product and service offerings. We will usually ask you for permission in these circumstances.
- Manage and Improve- to manage and improve the Online Facilities, notify you of applicable changes where required and allow you to use the features offered by the Online Facilities. This will usually be necessary (i) to perform any contract with you where relevant for applicable services (ii) to comply with legal obligations where applicable or (iii) otherwise for our legitimate interests in managing our relationship with you as a customer, improving our service, and/or record keeping.
- Communications- to communicate with you where necessary for purposes other than marketing. This will usually be necessary (i) to perform any contract with you for applicable services where relevant (ii) to comply with legal obligations where applicable or (iii) otherwise for our legitimate interests in managing our relationship with you as a customer, improving our service, and/or record keeping.
- Administer and Protect- to administer and protect our business, the Online Facilities, and rights of ourselves or other associated third parties (including those of other users and partners). This may include routine tasks such as troubleshooting, data analysis, testing, system maintenance and support as well as more formal matters such as bringing, defending or assisting in legal action where necessary. This will usually be necessary (i) for our legitimate interests in running our business and systems in a secure manner, business restructuring, protecting our rights and property (including intellectual property) and preventing or tackling illegal activity or (b) to comply with a legal obligation where applicable.
- Marketing & Associated Profiling- to
alert you to information about events, surveys, competitions, offers,
products, services and other exciting updates relating to us, and/or
commercial partners.
We only do this through email, phone calls where you have agreed, so this is on the basis of your consent. However, if you are an existing customer we may contact you about our products or services similar to those you have previously received or enquired about (unless you have chosen not to receive such communications).
How do we store your information and for how long?
Location
We are committed to protecting the security of your personal data, which we generally hold on secure hard drives in the European Economic Area (EEA).
We will not disclose your personal information to any other organsiations without your express consent. Whenever we transfer your personal data out of the EEA, we take reasonable steps to ensure that your information is still properly protected. This may include safeguards such as checking the relevant countries have been deemed to provide an adequate level of protection for personal data by the European Commission, or using contractual provisions to ensure your information is properly protected (certain contracts are approved by the European Commission).
In the unlikely event that any personal data sent to the US, we will check whether the ‘Privacy Shield’ applies – that ensures a similar level of protection to personal data shared within the EEA. See https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en, for further details.
Duration
We will keep the personal data you have provided only for as long as we reasonably require to fulfil the purposes we collected it for, including for the purposes of satisfying any contractual, legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. This is in addition to any applicable legal requirements.
For legal reasons we may have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for up to seven years after they cease being customers– this is particularly for any paid for products or services.
In some circumstances you can ask us to delete your data: see the “What are your rights?” section below for further information.
We may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Security
We have put in place appropriate operational, technical and security measures to reduce the risk of your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. This includes use of encryption where relevant, for example in relation to any financial information you provide which is encrypted for additional security. In addition, we strictly limit access to your personal data to those employees, agents, or other third parties who have a business need to know.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
When carrying out any dealings with us we strongly recommend you use a secure browser.
What are your rights?
Under the Data Protection Laws you may have the following rights in relation to your personal data in certain circumstances:
- Request Access: (also known as a "data subject access request"). You can receive full details of the personal data we hold about you.
- Request Correction: You can have any
incomplete or inaccurate data we hold about you corrected, though we may
need to verify the accuracy of new data you provide.
- Request Deletion: You can ask us to delete
or remove personal data in certain circumstances, for example where:
there is no good reason for us continuing to process it; you have
successfully exercised your right to object to processing (below); or
where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law.
- Object to Processing of your personal data: this applies where: we are relying on a legitimate interest or those of a third party and you feel our processing on this ground impacts your
fundamental rights; or where we are processing your personal data for
direct marketing purposes.
- Request Restriction of Processing: you can
ask us to suspend processing of your personal data where: you want us
to establish the data's accuracy; our use of the data is unlawful but
you do not want us to erase it; where you need us to hold the data even
if we no longer require it as you need it to establish, exercise or
defend legal claims; or you have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use it.
- Request Transfer: you can ask us to
provide to you, or a third party of your choice, your personal data in a
machine-readable format. This right only applies to automated
information which: you initially provided consent for us to use your
data.
- Right to withdraw consent;. This only applies where we are relying on consent to process your personal data. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
All requests set out in this section or other queries relating to this Policy should be addressed to Time Trails in Brittany. Please note we may not always be able to comply with your request due to our legitimate interests or other legal reasons. If applicable, these will be notified to you in response to a relevant request.
You will not usually have to pay a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive (or we may refuse to comply with your request in these circumstances).
For security reasons, we may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). We may also ask you for further information in relation to your request.
If you have any concerns about how we use your data you also have the
right in the United Kingdom to raise this with the Information Commissioner’s Office at
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF (https://ico.org.uk) or, in France with the Commission Nationale de l'Informatique et des Libertés, 3 Place de Fontenoy, TSA 80715, 75334 PARIS CEDEX 07, France. (https://www.cnil.fr)
We will, however, always try to help with any concerns so ask that you contact us in the first instance.
Will this policy change?
In order to comply with relevant legislation, we may need to update this Policy, and minor changes will be posted on this page so you should check back from time to time. Significant changes will be notified to you.
This Policy was last updated on 9th November 2020.
Who can you contact for further details?
Data Protection Officer, Time Trails in Brittany, La Ville Mainguy, La Croix Hellean, Josselin, 56120, France. Please include your name, address, and/or email address when you contact us.
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