This website is owned and operated by Sobamo Limited (“we”, “us”, “our”, and “ourselves”) trading as Sobamo Ltd. For the purposes of the Data Protection Act 1998 (Act), the data controller is Sobamo Limited.
The Website and the Sobamo Ltd Services are not intended for children, and we do not knowingly collect personal data relating to children.
Sobamo Ltd is the controller and responsible for your personal data (we, us or our).
Personal data we collect and process
When registering for a user account, using any Sobamo Ltd Service and/or browsing the Website, we will collect and gather the following categories of personal data:
- Identity Data such as first name, surname, gender.
- Contact Data such as e-mail address and telephone number.
- Profile Data such as your username and password, interests and preferences.
- Communication Data which includes any communication that you send to us whether that be through the contact form on our website, through email, text, social media messaging, social media posting or any other communication that you send us. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.
- Financial Data
- Technical Data
- Usage Datasuch as information about how you use the Website and Sobamo Ltd. Services.
The type of personal data collected and used by us varies depending upon whether you are a registered user of just browsing the Website, or if you use one or more of the Sobamo Ltd services.
We collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data but is not considered personal data under applicable data protection law as this data does not directly or indirectly reveal your identity.
How we collect personal data on the Website
It is not necessary to register a user account in order to search and view property listings or day-trip packages on the Sobamo Ltd Websites. However, we will receive Technical Data and Usage Data when you browse the Website. This is further explained below.
Methods used to collect personal data from and about you
Direct interactions: You may give us your Identity, Contact, Profile, Financial (Customers only) by filling in your online profile, changing details in Your Account, filling in online forms or by communicating with us. The personal data we receive from direct interactions with you includes personal data you provide when you:
- subscribe for our Website;
- create a user account on our Website and when you add to and manage your personal profile;
- contact or communicate with us via the Website;
- provide feedback, rate properties/services or make available any other content on the Website;
- request marketing communications to be sent to you;
Automated technologies or interactions: As you interact with the Website, we collect Technical Data and Usage Data including details of your device, browsing actions and patterns, searches, traffic data, web logs and other communication data and the resources that you access. We collect this personal data by using cookies, tracking codes, server logs and other similar technologies.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw your consent at any time by contacting us.
We do not request from you and we request you do not provide any special categories/sensitive personal data (e.g. personal data relating to racial or ethnic origin, political or religious opinions, membership of a trade union, physical or mental health or condition or sexual life or orientation). This type of personal data is subject to special protections under EU law.
Sobamo Ltd is not responsible for the data protection practices of its business partners.
We use your personal data in the following ways:
- We will collect and use Identity, Contact, Technical, Usage, Profile and Communications Data to communicate to users of the Website via email about products or services of Sobamo Ltd.
- We will collect and use Identity; Contact, Technical and Communications Data to administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) which is necessary (i) for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) and (ii) to comply with a legal obligation;
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosure of personal data to others
- our partners – travel service providers (B&B owners, taxi drivers, winery managers, tour guides, etc.) whose services you have booked via the Website;
- we contract with other entities that perform certain tasks on our behalf and who are under our control (“Service Providers”). This is required in order to provide and manage the Websites of Sobamo Ltd. Such Service Providers include IT systems suppliers and support, data storage, IT developers, insurance, credit card companies, payment processors, analytics companies, website hosting providers and other service providers;
- professional advisors such as accountants, auditors, lawyers, bankers, insurers, and other outside professional advisors;
- entities that regulate or have jurisdiction over Sobamo Ltd. We will disclose your personal data in order to comply with any legal obligation, if we are ordered to do so by a court of competent jurisdiction, law enforcement, regulatory or administrative authorities or in order to enforce or apply our Terms and Conditionsand other agreements, or to protect our Customers, Website users or others. This includes exchanging personal data with third parties for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our Service Providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Unless prevented by applicable law, we will notify you when your personal data may be provided to third parties in ways other than explained above, and you may have the option to prevent such sharing at the time that we notify you.
Customer control of your personal data
If you request a tourism service (e.g. book accommodation or a wine tour) or otherwise communicate with Travel Service Providers you have hired via the Website, the relevant Travel Service Provider will control the personal data you disclose. This will typically relate to your Identity and Contact Data. Such data will be subject to the Travel Service Provider’s own data protection and privacy practices. If you wish to understand the Travel Service Provider ‘s data protection and privacy practices, please contact the Travel Service Provider directly. You will be able to exercise your Data Protection Rights directly with the Travel Service Provider.
International data transfers
- Where the country has been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Sobamo Ltd is committed to protecting the personal data you provide us. To prevent unauthorised access or disclosure of personal data under our control, Sobamo Ltd has appropriate security management systems in place to safeguard the personal data we collect. Our Website is protected by firewalls, intrusion detection and virus scanners provided by our hosting service provider InMotionhosting. Encryption during transmission is also used on sections of the Website where security is particularly important. While Sobamo Ltd makes reasonable efforts to protect all personal data, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, Sobamo Ltd cannot ensure or warrant the security of any personal data you transmit to us, you do so at your own risk. You acknowledge that we are not responsible for any intercepted information sent via the Internet, and you hereby waive, release and discharge us from any and all claims arising out of or related to the use of intercepted information in any unauthorised manner.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. You must not to share your Website password with anyone.
Updating your personal data
It is important that the personal data we hold is accurate and current. Please keep us informed using the Contact Us form or writing directly at firstname.lastname@example.org if any of your personal data changes during your relationship with us. It is your responsibility to keep your personal data up to date at all times.
IP addresses and cookies
We may collect information about your computer, including (where available) your IP address, operating system and browser type, for system administration and statistical purposes.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. On revisiting the Website our computer server will recognize the cookie, giving us information about your last visit. They help us to improve the Website and to deliver a better and more personalized service. They enable us:
- to estimate our audience size and usage pattern;
- to speed up your searches.
We retain personal data for no longer than is allowed under data protection law and, in any case, no longer than such personal data is necessary for the purpose for which it was processed. 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, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
As a registered user of the Website we will retain your Identity, Contact, Profile, Technical and Usage Data for as long as your user account is live. We retain the personal data you provide while your account is in existence or as needed to provide you access to the Website. Even if you only use the Website occasionally, we will retain your Identity, Contact, Profile, Technical and Usage Data until you decide to close your user account. In some cases, we retain certain Usage Data (e.g. visitor and application statistics in a depersonalized or aggregated form). Also, we retain personal data for longer if required by applicable law or regulation or justified under applicable statutory limitation periods.
Your legal rights
Under certain circumstances you have rights under applicable data protection law in relation to personal data, namely:
- Request access to your personal data(commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you.This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data.This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal datawhere we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data.This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consentat any time if and to the extent we are relying on consent as the legal basis to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. 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.
Regarding your right to have your personal data erased, you can delete your user account with myplacecuba at any time by sending an e-mail request to email@example.com.
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.
In order to exercise one or more of your rights in respect of your personal data please contact us at firstname.lastname@example.org. We will respond to your request(s) as soon as reasonably practicable, but in any case within the legally required period of time.