About this policy
The Data Controller (the organisations responsible for looking after your data) is KeyStay Ltd and When we say “we”, “our”, “us”, etc., that’s who we’re talking about.
We are grateful for the trust you place in us, to arrange holidays, manage holiday properties and to use personal information responsibly. We are committed to protecting your information and we believe you have a right to know how we will use it. This policy sets out the data protection principles we follow.
This policy covers our dealings with customers and owner – people who have booked or are looking for a holiday, and people who let their holiday properties through us. Please note that our customers and owners must be over the age of 18 and we do not therefore collect personal information from children.
We will update our Privacy and Cookies Policy as data protection law or business practice changes. You can always find the latest version of this policy on our website, keystay.co.uk This version of the policy is effective from 25 May 2018.
Data Protection Officer
Our Data Protection Officer is Jane Upton, who may be contacted via email at firstname.lastname@example.org or via post, to our registered address: KeyStay Ltd, Queensbury House, 3rd Floor, 106 Queen's Road, Brighton, East Sussex, BN1 3XF
We generally use your data either on the basis of your consent or based on a contract between us (e.g. when you book a holiday). You have the right to withdraw your consent.
If you withdraw your consent (e.g. by opting out of marketing communications), we will stop processing your data as requested. Bear in mind if you have a holiday booked and you have not yet travelled, we’ll still need to hold onto your data so we can process the holiday. That’s because the contract between us is the basis for using your data (rather than consent). For more information, see the “Legal basis of processing” section below.
If you are concerned about the processing of your data, please contact our Data Protection Officer (see above). If you are unhappy with our use of your data, you also have the right to make a complaint to the Information Commissioner’s Office, which supervises data protection in the UK.
You have the right to receive a copy of your personal data. You also have the right to request that we correct or remove your data, when there remains no legal basis for keeping it. Please note that when these rights are exercised, we will conduct identification checks in order to ensure your privacy is safeguarded. You will need to contact us by email or post, to exercise these rights
Personal information we collect
In order to provide you with the best possible holiday service, we collect the following information:
Identification: name, title, date of birth, age/age range, gender.
Contact details: postal addresses (main and billing), phone numbers, email addresses.
Account Owner login details: email address, password (which is stored in encrypted form).
Bookings: property booked, holiday start/end dates, check in time/ check out time/ cost of holiday, amounts paid, limited details of other people booked on the same holiday (names, gender, age range), (travel times).
Marketing preferences: whether you wish to receive marketing information from us, and if so, by which methods (postal, email, telephone, SMS). We have an area where you can specifically submit and opt to join our newsletter
Payment: method, amounts collected, third party payment service provider references. Please note that we do not capture or store your full card details: payment is handled by our payment service providers (see below).
Browsing: historical searches, how you use our website and mobile apps, website experience user survey responses, the devices and IP addresses you use to access our services (operating system, browser, …). We collect this information so that we can continuously improve our website and our service to you.
Holiday experience: any feedback you leave, responses to customer satisfaction surveys, review requests, whether you have a pet, reason for booking eg Group or family holiday.
Specific to property owners: addresses of your properties, historical and future booking information (see above), photographs/videos of the properties you own, your contact details, and email address.
Communication: possible recordings of phone conversations, web chat messages, emails, customer service cases, responses to questionnaires, competition entries, your interaction with our marketing (clicking links in our marketing emails, for example – we track this to help ensure our communications are relevant and interesting).
Electronic identifiers: cookies, IP addresses. These electronic identifiers are essential to enable you to log into your online account and to assist you if you encounter difficulties using our online services. You can disable cookies if you wish, but this will hamper our ability to provide online services securely.
Through our partnerships, we may receive some of the above information from other companies you use (e.g. other online holiday companies that feature our properties). In such cases, those companies must also inform you about their use of your data.
How we use your personal information
We use your personal information to:
Manage your holiday booking/letting eg share your contact details with cleaners, property managers and owners.
Understand how to improve our services, to select the best holiday properties and provide the best information and offers, for example
Personalise your online experience – showing you the most suitable holiday properties, for example
Enable the display of the most appropriate adverts on our websites and on other websites and services where we place advertising.
Communicate with you, including for example, responding to your emails, messages on social media, web chat requests, handling customer service matters and so on
Process your payments ( via PayPal payment processing or similar PCI compliant payment processor )
With your permission, send you relevant marketing information such as details of competitions, special offers and properties we think will be of interest to you
Manage promotions and special offers in which you participate
Make sure our servers and websites are operating correctly
How we collect personal information
We receive personal information from:
You, as you provide it to us (e.g. when booking a holiday, leaving a review or enquiring about letting a property)
Your use of our websites and mobile apps e.g. sending an enquiry or placing a booking.
Third party holiday providers you may book with, who advertise our properties
Your interaction with our marketing activities (provided you have not unsubscribed)
Third party review services such as TripAdvisor
Legal basis of processing
There are several grounds on which we will store and use your data. As follows:
Consent: for certain types of processing (e.g. marketing activities), we rely on your consent to use your data. You may withdraw your consent at any time (see “Your rights”, above).
Contract: much of the time, our use of your data will be because of the contract between us – that is, in relation to your holiday booking. Eg you agree to our booking terms & conditions. We will usually retain relevant data for up to six years from the date the contract completes – e.g. the last day of your holiday.
Legal obligations: we are under certain binding legal obligations, such as accounting to the government for tax and making financial records available for audit. In such cases, we are typically obliged to retain data for up to seven years from the date of the transaction.
Legitimate interests: we use data to manage our operations and to make business process improvements. Rest assured, our legitimate interests will never override your right to privacy
How we share your personal information
We give some of your contact information to property owners, so they can get in touch about key collection and so on. (We also give you their contact details, for the same reason.)
If you permit us to send you marketing information, we may share your data with companies that provide specialist marketing platforms. These companies are under strict obligations to protect your privacy and comply with your marketing preferences.
TripAdvisor Homeaway Airbnb Booking.com
· 1. We store your data in certain cloud services provided by third parties e.g. Booking system
Online payments and Transactions
Please note that Keystay does not store any financial information. We do not store credit card details nor do we share customer details with any 3rd parties
In order to ensure your transactions are as secure as possible, payment card processing is carried out by PayPal
We allow some third party advertisers to place cookies on our websites – and from there, in your browser. Please note that you may use your browser’s controls to disable cookies at any time.
Use and Divulgence of Personal data
KeyStay will use your personal data exclusively for purposes of individual customer care, to give you access to special information, or for general communication with you. We will neither sell your personal data to third parties nor market it elsewhere unless you have given us expressed permission to do so. Keystay are duty-bound to respect the confidentiality of your data and abide by the associated Industry Codes of Conduct.
Freedom of Choice
You control the information you provide Keystay. However, if you choose not to share your information with Keystay please be aware that you may be unable to access some of the Areas of the web site or place an order online and may impact on the level of service that we can provide.
Automatically, recorded information (non-personal data)
When you access the Keystay web site, general non-personal information (Internet browser used, number of visits, average time spent on site, pages viewed) is recorded automatically (not as part of website maintenance). This information is used to gauge our website appeal and to improve its content and functionality. Your data is not processed any further nor is it transmitted to third parties.
Keystay takes great care to ensure the security of personal data. Your data is conscientiously protected from loss, destruction, distortion/falsification, manipulation and unauthorized access or unauthorized disclosure.
Keystay strongly advises all parents and guardians to teach their children safe and responsible handling of personal data on the Internet. Minors should not transmit any personal data to the Keystay web site without the permission of parents or their guardians. Keystay will never knowingly collect personal data from minors, or use it in any way, or disclose it to third parties without permission.
Links to other websites
This statement on privacy protection applies to the www.keystay.co.uk website. The Web pages may contain links to other providers within and outside the Keystay website, to which this privacy protection statement does not extend. When you leave the Keystay website, please be aware of and read the privacy statements of each and every website that collects personally identifiable information.
Notification of Changes
Referrals and links
With respect to direct or indirect referrals to third-party Internet pages ("links") outside the author's area of responsibility, liability would come into force only if the author were aware of the content and if he/she were reasonably and technically able to prevent the use of illegal content. The author therefore expressly declares that the respective linked pages were free from illegal content at the time the links were placed. The author has no influence whatsoever on the current or future design or on the content of the linked/connected pages. Therefore, the author shall be exculpated from any damages arising from the content of any linked/connected pages that have been modified since the link has been placed. This applies to any links and referrals placed within the company's Internet content as well as to postings or messages to guest books, discussion boards and mailing lists set up by the author. Solely the provider of the page linked to shall be liable for illegal, defective or incomplete content and particularly for damage arising from the use or non-use of such information; the provider of the page merely linking to the respective publication shall not be held liable for any such damage.
Copyright and Trademark law
The author endeavours to respect the copyright of any graphics, audio files, video sequences and texts used in all publications, to use self-created graphics, audio files, video sequences and texts, or to make use of royalty-free graphics, audio files, video sequences and texts. Any brands and trademarks named in the Internet content that may be protected by third-party rights are fully subject to the provisions of the currently applicable trademark law and the possessory rights of the respective registered owner. The author retains the copyright for any published objects that have been created by the author. The duplication or use of such graphics, audio files, video sequences and texts in other electronic or print publications is not permitted without the author's express approval.
Legal validity of this Disclaimer
This disclaimer shall be regarded as part of the Internet publication from which you were referred. If any sections or individual formulations of this text do not or no longer correspond to current law, either in part or completely, the content and validity of the remaining provisions shall remain unaffected.
· Analyse our web traffic using an analytics package. This aggregated data on usage helps us improve the website design, structure, content and function
· Test content on the website. For example, 50% of our users may see one piece of content, the other 50% will see something else
Cookies do not provide us with access to your computer or any information about you, other than that which you choose to share with us.
How to control cookies on your computer:
If you do this, it will not affect your ability to view our website.
Controlling information about you:
When you enter your email address to subscribe to the KeyStay newsletter on the website, this will allow you to:
· Opt-in to receive latest news, new property additions and special offers marketing communications from KeyStay by email.
Should you wish to change these preferences in the future, you can easily do so by contacting us by
We will never lease, distribute or sell your personal information to any third party unless we receive explicit permission from you or the law requires us to do so.
Any personal information we hold about you is stored and processed under our Data Protection Policy, in line with the “Data Protection Regulation or General Data Protection Regulation (GDPR)” and new UK legislation, the “Data Protection Act 2018”.
We will always hold your information securely.
To prevent unauthorised disclosure or access to your information, we have implemented strong physical and electronic security safeguards.
Some of these third party systems used by KeyStay Limited store their data in the US. However, in these cases, the third parties have warrantied that they abide with EU GDPR Data Protection legislation with regards to the sharing of EU data with servers in the US.
We also follow stringent procedures to ensure we work with all personal data in line with the “Data Protection Regulation or General Data Protection Regulation (GDPR)” and new UK legislation, the “Data Protection Act 2018”.