1 - Scope
The United Kingdom General Data Protection Regulation (hereafter called UK GDPR), along with the Privacy and Electronic Communications Regulations (PECR), seek to protect and enhance the rights of data subjects. These rights cover the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the UK, EU and its storage within the EEA.
2 - Who we are
2a - The business operates an App and website for making hotel bookings
3 - Personal Data
a) Pogo uses the information collected from the App, when you email, access the website or speak with you to respond to your enquiries.
b) For marketing purposes, Pogo may use the personal data you have provided to send you information concerning hotels and other travel related news, which we believe may be of interest to you.
c) In you making initial contact you agree to Pogo maintaining a marketing dialogue with you until either you opt out (which you can do at any stage) or we decide to desist in promoting our services. At all times, Pogo will work hard to be fully UK GDPR compliant.
d) Some personal data may be collected about you from your registration using the App or website, from any forms and surveys you complete, from records of email exchanges, from phone calls and details of your visits to our App and/or website, including but not limited to, personal identifying information like Internet Protocol (IP) addresses.
e) Pogo will only collect the information needed so that it can provide you with the hotel services required; the business does not sell or broker your data.
4 - Legal basis for processing any personal data
To meet our contractual obligations to customers and legitimate interests to respond to enquiries concerning hotels.
5 - Legitimate interests pursued by Pogo
To promote our hotel services. Communications may include App messages, digital mailers, newsletters, telephone calls, social media and any other channels to reach those who may be interested in using Pogo.
6 - Consent
7 - Disclosure
Pogo will keep your personal information safe and secure, although our administration team will have access to your contact details so that they can manage your account.
The Business will not disclose your Personal Information unless compelled in order to meet legal obligations, regulations or valid governmental requests.
8 - Retention Policy
Pogo will process personal data for the duration of any business dealings and will continue to store only the personal data needed for five years after any booking has expired to meet our legal obligations and for marketing purposes. For anything that is needed for our corporate records we are legally required to hold this data for up to seven years. After the appropriate time period, all personal data will be deleted, unless Pogo is required to retain some basic information to meet our future obligations to you, such as erasure details.
9 - Data storage
Where possible all personal data is held in the United Kingdom or the EEA.
10 - Data sharing
Due to the nature of the hotel industry, there is a requirement and sometimes a legal obligation to share your data with other organisations including airlines, hotels, and parties that provide specific services. These other parties include Booking.com, credit and debit processing companies.
Where we are required to send your personal data outside the UK and EEA, we will always put in place appropriate data protection agreements including if required an IDTA or comparable documentation.
11 - Links to Other Websites
12 - Marketing
13 - Your rights as a data subject
At any point whilst Pogo is in possession of or processing your personal data, all data subjects have the following rights:
Right of access – you have the right to request a copy of the information that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
Right of portability – you have the right to have the data we hold about you transferred to another organisation.
Right to object – you have the right to object to certain types of processing such as direct marketing.
Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling.
In the event that Pogo refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge.
At your request, the Company can confirm what information it holds about you and how it is processed.
14 - Childrens Privacy
No one under the age of 13 is permitted to use the App or website. In addition, Pogo does not knowingly collect or solicit personal information from anyone under the age of 13 or consciously allow such persons to register on the App. If you are under 13, please do not provide us with any information about yourself. In the event that we learn that we have collected personal information from anyone under the age of 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us immediately, using the contact detail on the last page.
15 - You can request the following information:
Identity and the contact details of the person or organisation that has determined how and why to process your data.
Contact details of the data protection officer, where applicable.
The purpose of the processing as well as the legal basis for processing.
If the processing is based on the legitimate interests of the Business and information about these interests.
The categories of personal data collected, stored and processed.
Recipient(s) or categories of recipients that the data is/will be disclosed to.
How long the data will be stored.
Details of your rights to correct, erasure, restrict or object to such processing.
Information about your right to withdraw consent at any time.
How to lodge a complaint with the supervisory authority (ICO).
Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
The source of personal data if it wasn’t collected directly from you.
Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.
16 - To access what personal data is held, identification will be required
Pogo will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If Pogo is dissatisfied with the quality, further information may be sought before personal data can be released.
All requests should be made to email@example.com or by phoning +44 (0) 204 571 5186 or writing to us at the address below: Office 5, Bourne Park, Exeter Park Road, Bournemouth BH2 5BD.
17 – Complaints
In the event that you wish to make a complaint about how your personal data is being processed by the Business you have the right to complain to us. If you do not get a response within 30 days you can complain to the ICO.
Wycliffe House, Water Lane, Wilmslow, SK9 5AF.
Telephone +44 (0) 303 123 1113 or email: https://ico.org.uk/global/contact-us/email/