We collect certain personal data about you and about any other person you include on your reservation. The sort of personal data we collect is information that you provide to us, that we collect from you or observe about you, or that we obtain from other sources. Personal data you give to us:

• When you make a reservation or inquiry we may ask you for your name, address, e-mail address, telephone number, date of birth, and personal travel preferences. We need to collect this information to arrange the travel and other services you are requesting.
• When you request to make a reservation, depending on the arrangements you ask us to make for you, we will ask if you have any special requirements. You may give us information concerning dietary requirements, medical /health conditions, disabilities and diving history/experience. This information is referred to as special categories of personal data and when you give us this information we’ll use it to try and ensure your needs in relation to a reservation are met.
• If you complete a survey we will collect your name and relevant contact information and any other personal information you choose to give us.
• We may ask for passport details.
• If you contact us online, we may keep a record of your e-mail or other correspondence. If you call us by telephone, we may monitor and/or record phone conversations for training and customer service reasons.
• If, when using our Services, you enter or provide any of your personal data (including telephone number or e-mail address), but do not make a reservation or other purchase, we will keep and use the data you’ve provided for a limited time and purpose, as mentioned below.

To help us keep your information current, accurate and complete, please ensure you tell us if anything needs to be changed.

Based on how you have used our Services in the past and your activity on our website, at our Resort, via our US-based Reservations Office or social media channels, we collect the following personal data about you:

• Details of the services we have provided to you in the past, including your previous travel arrangements with us and matters related to those arrangements, such as details of your previous requirements or complaints.
• We collect details of your visits to our website (including, but not limited to, traffic data, location data and weblogs) whether this is required for our own purposes or otherwise, and of the resources that you access. We use third party technology services, such as Google Analytics to administer these services.
• We collect details of website(s) you visited before you use a link to our Sites, pages visited in our Sites, and time spent on each page.
• We may collect information about your computer (or mobile device/tablet) including, where available, your IP address, operating system, device location, browser type, cookie identification numbers, for system administration purposes and marketing. This is statistical data about our users’ browsing actions and patterns, and reports do not identify any individuals.
  Personal data obtained from other sources

We might also receive your personal data from third party sources who collect information about you on our behalf. This includes:

• If you tell a third party that you would like to receive marketing communications from us, they will securely transfer your contact details and marketing preferences to us.
• If you book a reservation through a third-party travel agent, certain personal data (as applicable to your reservation, such as your name, date of birth or any special requirements you have) will be passed to us to provide the services you have requested/booked.

Your personal data is held on a combination of our own systems and systems of the suppliers we use to provide our services.
When you give your personal data to us, some of the personal data you provide will need to be given to and processed and stored by relevant third parties. These third parties include:

• Travel Resource Solutions, Inc, our US-Based Reservations Office
• Wufoo, an on-line form builder used for guest surveys.
• Mail Chimp, an email marketing service.
• Airline Reservation Providers
• Our card payment facilitators, that help us process customer credit card payments and assists us in detecting and preventing fraudulent payments or reservations.

To provide our services to you, we use the information we hold in several different ways. We process your information either because it is necessary for us to do so as part of a contract you enter, or because we have a legitimate business reasons for doing so.

The following activities are carried out by us using your personal data because it is necessary in relation to a contract which you have entered into or because you have asked for something to be done so you can enter into a contract:

• Administering your reservation internally and communicating your reservation externally with our suppliers, to ensure the services you have requested are arranged.
• To communicate with you regarding your reservation or any other purchase, including sending reservation confirmation and travel documents.

We may use and process your personal information as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so:

• To improve customer experience:
  1. To ensure that content from our site and reservation systems is presented in the most effective manner for you and for your computer;
  2. To notify you about changes to our service.
• To protect our business against financial loss:
  1. For debt collection or credit vetting
  2. For payment card and reservation verification
• To promote our business, improve our products and services:
  1. To send marketing correspondence about products and services like those you have previously bought from us. You can opt out of our sending you electronic marketing information. This option will be included in every marketing message we send you.
  2. To contact you if you make an inquiry with us on our website but do not complete a reservation to check if there was a problem or you need any assistance to book;
  3. For internal research/analysis to improve the quality of our Services, the products we offer and new products we are developing by inviting customers to take part in surveys.
• To promote our business and measure the reach and effectiveness of our marketing campaigns.

We may use and process your personal information where we consider that it is in your vital interests that we do so to assist you or arrange for assistance to be provided to you by third parties either in the event of an incident or emergency.
We may use and process your personal information as set out below where we have your consent to do so:

• To assist you or arrange for assistance to be provided to you by third parties where you have special requirements in relation to special categories of personal data (please refer to the section: ‘What types of personal data do we collect about you and why do we collect it’).
• To send marketing correspondence about our products and services where we have asked for your permission to do so.

We and third parties acting on our instructions, such as external law firms and their employees, may use and process your personal information for resolving complaints, dealing with disputes and legal proceedings. This might include contacting you proactively if we need to resolve any issues you may be experiencing or have experienced with a reservation or other purchase.

If you have made an inquiry or purchase on our website, through our resort or US-based reservations office, your personal data may be used by us in the ways the law allows, to contact you by post, electronic means (e-mail or text message) and/or by phone with information and offers relating to products or services that you can book/purchase from us. We will only do this if you did not opt out of such marketing at the point where we collected your contact details.

• If you have not made an inquiry or purchase, we will only send you information and offers by e-mail if you sign up (opt in) to receive such marketing, either directly through us or by telling a third party that you would like to receive marketing from us.

You have the right at any time to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by selecting the ‘no marketing’ option on the forms we use to collect your data. You can also exercise this right at any later time by using the unsubscribe link on any marketing e-mail you receive.

You have a number of rights in relation to your personal information under data protection law, including:

• Your Right to Access Your Personal Information: You have the right to make a Data Subject Access Request in many circumstances. That is a request for access to the personal information that we hold about you. If we agree that we must provide personal information to you (or someone else on your behalf), we’ll provide it to you or them free of charge.
• Correcting and updating your personal information: The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change your name or address/e-mail address, or you discover that any of the other information we hold is inaccurate or out of date, please let us.
• Withdrawing your consent: Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How do we use your information when providing our services to you’, you may withdraw your consent at any time. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested. If we must cancel your booking or other purchase as a result, you may incur a cancellation charge. If you withdraw your consent, our use of your personal information before you withdraw is still lawful.
• Objecting to our use of your personal information: Where we rely on our legitimate business interests as the legal basis for processing your personal information for any purpose(s), you may object to us using your personal information for these purposes by e-mailing or writing to us at the address provided at the end of this policy. Except for the purposes for which we are sure we can continue to process your personal information, we will temporarily stop processing your personal information in line with your objection until we have investigated the matter. If we agree that your objection is justified in accordance with your rights under data protection law, we will permanently stop using your data for those purposes. Otherwise we will provide you with our justification as to why we need to continue using your data.
• Erasing your personal information or restricting its processing: In certain circumstances, you may ask for your personal information to be removed from our systems by e-mailing or writing to us at the address at the end of this policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request.

Once you have made your request and provided us with the information we need to begin a search for the data we hold on you (including proof of identity), we will have 30 days to respond.

Making a complaint:

We encourage you to contact us if you have a complaint and we will seek to resolve any issues or concerns you may have.  You have the right to lodge a complaint with the data protection regulator where you believe your legal rights have been infringed, or where you have reason to believe your personal information is being or has been used in a way that doesn’t comply with the law.

If you wish to contact us about this Privacy Policy, you can e-mail Villa on Dunbar Rock using the contact details above.

Where you’ve made a reservation or other purchase with us, your personal information will be retained to ensure we provide the best possible customer service to you. We retain your personal data for as long as is necessary for us to use your data as set out in this Privacy Policy.

The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website, therefore any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep your personal data secure and to try to prevent any unauthorized access, use or loss of your data, by putting in place appropriate security measures and limiting access to those who have a business need to know. All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS technology. We do not store customer card data on our internal systems.

Our website includes links to other websites. If you follow a link or otherwise use any of these other websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for these third-party websites. Please check these policies before you submit any personal data to these websites.

Our Sites use cookies to distinguish you from other users. You can find out more about what cookies are at: http://www.allaboutcookies.org

• Essential Cookies: Some cookies are essential to make our Sites work properly and to allow you to make your travel reservation or other purchases and enable us to fulfill your purchase requests.
• Customer Experience Cookies (Analytics, Customization & Tracking): These types of cookies help us to provide you with a good experience when you browse our sites and allow us to track your experience between different devices to improve our sites or the way we provide our service to customers.

If you choose to remove cookies parts of website you are on may not work properly or your use of the website may be impaired. If you choose to use this website you are on without declining any non-essential cookies, then your use will constitute implied consent to the non-essential cookies that are set.

Alternatively, you can review cookies by accessing the preference panels from your browser’s main menu (usually found under ‘Edit’, ‘Tools’ or ‘Options’). Do not track (DNT) is a feature offered by some browsers, with some newer browsers offering it as default. If you enable it, it sends a signal to websites to request that your browsing isn’t tracked, for example by third party advertisers or social networks, or analytic companies. No industry-wide agreed standard to determine how DNT requests should be managed has been put in place, so our Sites don’t currently support DNT requests. Until that standard is established, we’ll continue to review DNT and other new technologies, but won’t respond to DNT requests.