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Privacy portal
Privacy statement
Pigsback takes your privacy seriously and we want to ensure that your data is secure. Below is a brief summary of what data we collect, how we use it and how you can control it. If you would like more information and more details, this can be found in our privacy and cookies policy below.
We will collect personal information from you when you sign up to use the site and when you make a booking. This includes your name, email address, and phone number, and in some cases your postal address, date of birth and passport number.
We use this information to allow us to (i) create your account (ii) keep you up to date with deals we think you want to hear about and (iii) track your activity on the website to allow us to tailor your site experience;
We primarily share information with third parties to fulfil any bookings you make and with our technical providers that allow us to send emails about our deals and to analyse website behaviour;
As part of the Pigsback service, we send you regular email updates with our best deals, tailored to suit your preferences. If you would prefer not to receive these emails, or reduce their frequency, you can change your preferences at any time on signing up or in the account section of the website.
You have various rights under data protection law, including the right to request access to the personal data we hold on you, and a right to request that we delete all such personal data. You can delete your account in the account section, but for all other requests please contact customersupportie@secretescapes.com.
1. Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users. This privacy policy (the "policy") tells you about your privacy rights and sets out how we collect, use and disclose your personal information (or "personal data") when you use the website, in accordance with the provisions of any applicable data protection laws and regulations including the General Data Protection Regulation 2018 ("GDPR") and the Data Protection Act 2018.. For the purposes of this policy, "you" and "your" means you as a user of the www.secretescapes.ie website (the "website"), and "we", "us" and "our" refer to the joint controllers Empathy Marketing Limited and Secret Escapes Limited. For more information about us and the joint controller arrangements, see Section 19. This Notice should be read in conjunction with the Terms & Conditions [insert link] for using the website.
1.2 This policy applies to any personal data collected or processed through our website.
1.3 We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.
1.4 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive marketing communications. You can access the privacy controls via the “My Profile” menu.
2. How we collect and use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we collect and process, including any special category data that we collect which is more sensitive in nature and therefore require a higher level of protection;
(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing of your personal data.
2.2 We use different methods to collect data from and about you including through:
Direct interactions. You may give us your identity, profile data, contact data and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us some feedback.
Automated technologies or interactions. As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
a. Analytics providers such as Google based outside the EU;
b. Advertising networks (such as Google Adwords) and Facebook based inside OR outside the EU;
c. Search information providers (such as Google) based inside OR outside the EU;
d. Contact, financial and transaction data from providers of technical, payment and delivery services such as our payment providers identified in section 4.4;
e. Your name and email address from social networks you use to create or log-in to your account with us, for example Facebook. We will not be provided with your password or other account login details for those accounts and we will not post to your social network or to your friends, followers or contacts without your consent;
f. Information provided by other visitors to our site or users of our app if they want to invite you to use our site, our app or to share information with you about our service or offers. We will use personal information that they provide about you to assist them in doing this. We will only do this where they indicate that you have provided your consent for them to communicate with you in this way;
2.3 We currently collect and process the following information:
Personal identifiers, contacts and characteristics, including your name, date of birth, gender, postal address, delivery addresses, telephone number, email address, interests and hobbies
Financial information, including your payment method, card details and transaction details on the website. Although we keep records of any transactions you make through the site or app, we do not store any financial details such as your credit card numbers as we use a third party payment provider to process any payments you make through the site.
Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use (sourced from our analytics tracking system)
Communication content and metadata contained in or relating to any communication that you send to us
Information provided to us for making or managing your booking, including passport numbers, information about any disability you have, dietary requirements and/or religious beliefs
Comments and opinions
2.4 We may collect, store, use and process your personal data solely for the purposes and legal bases set out below:
2.4.1 Data about your use of our website and services ("usage data"), for the purposes of analysing the use of the website and services.
Type of Personal Data: Your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use, the computer, tablet, smartphone or other electronic device you use to connect to our site or app including details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our site or our app through the device, your Internet service provider or mobile network, your IP address and your device's telephone number (if it has one). The source of the usage data is our analytics tracking system.
Lawful basis of processing: To support our legitimate interests, namely monitoring and improving our website and services and to offer you content tailored for your preferences.
2.4.2 Your account data ("account data"), for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
Type of Personal Data: Your name, postal address, delivery addresses, telephone number and email address.
Lawful basis of processing: Our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4.3 Information included in your personal profile on our website ("profile data"), for the purposes of enabling and monitoring your use of our website and services.
Type of Personal Data: Your name, address, telephone number, email address, gender, date of birth, interests and hobbies, comments and opinions.
Lawful basis of processing: Our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.4.4 Your personal data that are provided in the course of the use of our services ("service data"), for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you, and verifying your identity.
Type of Personal Data: Your comments and opinions, IP address, website and app log-in details username and password, and if you consent to this information about your exact location.
Lawful basis of processing: Our legitimate interests, namely the proper administration of our website and business and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract, and your consent.
2.4.5 Information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"), for the purposes of offering, marketing and selling relevant goods and/or services to you, and providing customer services and support.
Type of Personal Data: Your name, email address, and any other personal information you choose to provide us with for your query.
Lawful basis of processing: Your consent.
2.4.6 Information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website or other channels ("transaction data"), for the purpose of supplying the purchased goods and services and keeping proper records of those transactions.
Type of Personal Data: Your contact details, your card details, payment method and the transaction details, passport numbers, information about any disability you have, dietary requirements, and/ or religious beliefs.
Lawful basis of processing: The performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely our interest in the proper administration of our website and business.
2.4.7 Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"), for the purposes of sending you the relevant notifications and/or newsletters.
Type of Personal Data: Your name, email address, preferences, usage data.
Lawful basis of processing: Your consent.
2.4.8 Information contained in or relating to any communication that you send to us ("correspondence data"), for the purposes of communicating with you and record-keeping.
Type of Personal Data: The correspondence data may include the communication content and metadata associated with the communication. Our website and applications will generate the metadata associated with communications made using the website contact forms.
Lawful basis of processing: Our legitimate interests, namely the proper administration of our website and business and communications with users.
3. Your Consent
3.1 Our service is about providing you with the latest hotel and luxury travel offers. Most marketing messages we send will be by email but occasionally we may also contact you by post or phone. If you are using our website or app we may also send you push notifications if you accept to receive them. If you do not want to receive, or wish to reduce, marketing messages from us, you will be able to tell us by changing your marketing preferences in your account.
3.2 You can also change your marketing preferences at any time by following the instructions outlined below.
Email – click on the unsubscribe link at the bottom of our marketing emails. If you have an online account with us you can also opt-out of marketing emails through your account settings. You can also visit the “your account” section of our site to manage the frequency of our communications to you. In the “your subscriptions” tab of the “your account” section of the site, you can choose to opt out of receiving communications for a period of time by clicking on the relevant slider. You can also choose to reduce the frequency of our emails by choosing the summaries option on the mail preferences slider. You can also unsubscribe here. Once you have chosen your mail preferences, please click “Save Changes” button to let us know of your preferences.
App push notifications – you can change your push notification preferences at any time in the account settings for the app. If you receive marketing from us through other channels e.g. post or by phone, and you no longer want to receive such messages, you can tell us to stop marketing to you by post or phone by using our contact details at the end of this privacy notice. Please note that most marketing messages we send will be by email.
3.3 From time to time we include offers from selected third parties that we think will be of interest to you in our newsletters. If you decide you no longer want to receive such messages, you can tell us not to send such messages through your account settings. Visit the "your account" section of the site, then untick the box titled "Hand-picked partner offers".
4. Compliance With A Legal Obligation
4.1 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.2 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
4.3 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We will only use and process your personal data in accordance with the GDPR, any local implementing legislation and any replacement legislation governing the processing of personal data.
4.4 Please do not supply any other person's personal data to us, unless you have their consent and we prompt you to do so.
5. Automated decision-making
5.1 We will use your personal data for the purposes of automated decision-making in relation to selecting content to display to you within our websites and applications and the to include in notifications in emails and other messages and to decide which content to advertise to you on 3rd party sites.
5.2 This automated decision-making will involve using your transaction data, usage data and personal data to determine your content preferences and provide you with content that matches those preferences.
5.3 The significance and possible consequences of this automated decision-making are that you will be offered content that matches your observed and declared preferences and that you will receive emails and other notifications containing content that is closely aligned with your determined preferences.
6. Providing your personal data to others
6.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
6.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.3 We may disclose your personal data to our suppliers or subcontractors and other third parties insofar as reasonably necessary for the purposes of providing our services to you and for the completion of contracts entered into by you through our websites and applications, for example airlines, hotels, tour operators and appropriate public authorities. A full list of these suppliers or contracts can be obtained by contacting us directly.
6.4 Financial transactions relating to our website and services are handled by our payment services provider Stripe Payments Europe Limited. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at their websites.
6.5 We may disclose your enquiry data and transaction data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can complete the service for which you have contracted and arrange your booking. Each such third party will act as a data controller in relation to the enquiry data and transaction data that we supply to it.
6.6 We may disclose your personal data to third party companies in order to display advertising from us or partners in other locations on the internet. We do not share or sell member personal data for the purposes of direct marketing by third party companies.
6.7 Where you have given us permission to do so, we may share your contact details with selected third parties so that they can provide you with information about travel offers that they believe may be of interest to you. We will only do this if you have given us your express consent to do so. To do this we, or our advertising partners, may collect information about how you use or connect to our site, our app or the types of other web pages, social media services, content and ads you, or others who are using the device you connect to our site or app with, interact with, visit or view. The information collected might also include the IP address of the device you connect to our site or our app and a de-identified, non-human readable version of your email address which may be match to other data about you to improve the relevance of online advertising and personalisation. At no time is your actual email address shared with these partners. We, or our advertising partners, use the information that is collected to make sure the adverts you see either on our site, our app or other parties’ websites and apps (where our partners have advertising space) are more relevant to you. Typically cookies and similar technologies are used to provide this type of advertising. You can find out more about cookies and how to manage their use by reading our cookie notice below.
6.8 We may disclose your personal data to third parties who provide a service to us. For example, third party service providers help support our IT infrastructure, process payments from you on our behalf, develop analytical information for us about our products, services and marketing and provide professional services such as legal and accountancy services. These third parties will only be allowed to use your personal information in accordance with our instructions and will be required to keep your information secure. Such companies include Amazon Web Services EMEA SARL, which provides part of our website hosting; Salesforce.com EMEA Limited, which provides our core CRM system, allowing us to manage the sending of newsletters to our members; Sitel Europe Limited, which provides our customer service centre and which has access to customer data for the purposes of assisting customers with their bookings and enquiries; Snowflake Computing Inc, which provides database services enabling us to store customer data securely.
6.9 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
6.10 We may disclose your personal data to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
7. International transfers of your personal data
7.1 In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
7.2 The hosting facilities for our website are situated in Europe.
7.3 Our Email Service Providers servers are situated in United States of America, our Customer Service Software provider is situated in the United States, our analytics providers are situated in the United States of America. Whenever we transfer your personal data out of the European Economic Area (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 only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
7.4 You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
8. Retaining and deleting personal data
8.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
8.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. 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, and the applicable legal requirements.
8.3 We will retain your personal data as follows:
(a) Name, address, email address, phone number, and transaction history will be retained for as long as your account remains active and open. If you cancel your account, your account will no longer be accessible to you and your personal data will be kept for a minimum period of 2 years after the year in which you cancel your account in order to permit normal business functions to be conducted. For example, a normal business function is the auditing of financial data.
8.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
Security of personal data
9.1 We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
9.2 We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
9.3 Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
9.4 You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
9.5 You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
10. Amendments
10.1 We may update this policy from time to time by publishing a new version on our website.
10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
10.3 We may notify you of changes to this policy by email.
11. Your rights
11.1 In this Section 9, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
11.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
11.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 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). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
11.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
11.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
11.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
11.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
11.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
11.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
11.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 9.
Third party websites
Third party websites
12.1 Our website includes hyperlinks to, and details of, third party websites.
12.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
Personal data of children
Personal data of children
13.1 Our website and services are targeted at persons over the age of 18.
13.2 If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
14. Updating information
14.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
15. Our details
15.1 This website is operated by Secret Escapes Limited, and it is generally responsible as controller for the majority of personal data processing in connection with the offering of goods and services on the website. Marketing activities in relation to the website are carried on in Ireland by Empathy Marketing Limited. Empathy Marketing Limited owns this website, and is also the party responsible for managing correspondence with individuals in Ireland on behalf of the joint controllers.
15.2 Empathy Marketing Limited is registered in Ireland under registration number 320005, and our registered office and principal place of business is at 2 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, D04 W3V6, Ireland. Empathy Marketing Limited has appointed a DPO, who is contactable at dpo@empathymarketing.com.
15.3 Secret Escapes Limited is registered in England under registration number 07026107, and our registered office and principal place of business is at 4th Floor 120 Holborn, London, England, EC1N 2TD. Secret Escapes Limited has appointed an EU representative which is Secret Escapes GmbH, contactable at dpo@secretescapes.com.
15.4 You can contact us:
(a) by post, to Empathy Marketing Limited, The Masonry, Suite 201/202, 151-156 Thomas St., Dublin 8, D08 PY5E;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
Glossary
Lawful Basis means our reason or justification for processing personal data under Article 6 GDPR.
Legitimate Interest means 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 your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
15.1 This website is operated by Secret Escapes Limited, and it is generally responsible as controller for the majority of personal data processing in connection with the offering of goods and services on the website. Marketing activities in relation to the website are carried on in Ireland by Empathy Marketing Limited. Empathy Marketing Limited owns this website, and is also the party responsible for managing correspondence with individuals in Ireland on behalf of the joint controllers.
15.2 Empathy Marketing Limited is registered in Ireland under registration number 320005, and our registered office and principal place of business is at 2 Shelbourne Buildings, Crampton Avenue, Shelbourne Road, Ballsbridge, Dublin 4, D04 W3V6, Ireland. Empathy Marketing Limited has appointed a DPO, who is contactable at dpo@empathymarketing.com.
15.3 Secret Escapes Limited is registered in England under registration number 07026107, and our registered office and principal place of business is at 4th Floor 120 Holborn, London, England, EC1N 2TD. Secret Escapes Limited has appointed an EU representative which is Secret Escapes GmbH, contactable at dpo@secretescapes.com.
15.4 You can contact us:
(a) by post, to Empathy Marketing Limited, The Masonry, Suite 201/202, 151-156 Thomas St., Dublin 8, D08 PY5E;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
Glossary
Lawful Basis means our reason or justification for processing personal data under Article 6 GDPR.
Legitimate Interest means 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 your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
This Privacy Notice was last modified on 20 August 2024.
