Welcome to Bilyana Golf’s privacy notice.
Bilyana Golf respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc.
Who are we?
We are Bilyana Golf (UK) Limited (Company Registration Number 06130760) is the controller and responsible for your personal data (collectively referred to as “Bilyana Golf” , “we” “us” or “our” in this privacy notice).
Bilyana Golf (UK) Limited
Suite 5 M6 Motorway House,
0044 1625 800 110
If you have queries regarding how we use and process your personal data you can contact us by email, phone or post.
What do we do with your data?
Personal data, or personal information, means any information about an individual from which that person can be identified.
We use different methods to collect data from and about you including through:
(a) Direct interactions - phone, emails, post
• deal with any enquiry you make about the holidays we sell;
• handle administration associated with any holiday arrangements you book with us (for example making amendments to the arrangements, collecting payment from you or asking you to review your trip);
• ensure that our suppliers (e.g. hotels, golf courses, airlines) are able to provide the services that make up your holiday;
• contact you about the products we sell, which we hope will be of interest to you; ensure the smooth running of our online services and call centre operations..
This includes personal data you provide when you, make a booking, subscribe to our newsletter, enter a competition, promotion or survey, give us some feedback.
(b) 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, and other similar technologies.
Bilyana Golf Holidays is a Golf Resort Specialist, and we process your personal data when we:
• Deal with your inquiry;
• Handle administration, amendments & payments;
• Deal with hotels, golf courses and flight companies;
• Contact you regard other products we provide;
• To ensure the highest level of customer service is provided.
The following information describes the way in which we process your data, allowing us to comply with GDPR regulations. This includes:
• The ‘lawful basis’ we rely on;
• What information we collect and how we use it;
• Your rights to opt-out/object;
• How long we store your details
• Any rights you have to opt-out of or object to the processing.
We may have to share your personal data with 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.
Definitions of terms applied:
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service 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 firstname.lastname@example.org
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.
How do we process your information when you enquire about our holidays?
When you contact us to make an enquiry or express further interest in a possible holiday booking we may need further personal data. We may contact you via email or telephone to ask for the following
- email address;
- telephone number(s);
- postal address; and
- golf handicap.
Your personal data will be processed so that we can provide you with the information you requested, and we rely on the ‘contract’ lawful basis when we perform this.
The information you provide (e.g. an email address) when you request information prior to making a booking, will also be used in order to send you information about other, similar holidays sold by us in the future. At the point we collect your contact details (email address, telephone number or postal address) we will ask you if you would prefer not to receive marketing materials from us.
Even if you choose to receive these materials, you can change your mind at any time by telling us to stop sending them in the future, by either by clicking the ‘unsubscribe’ link in an email, by calling us, or by contacting email@example.com When we process the personal data received in the course of a sale (or negotiations for a sale) in order to send marketing materials, we are doing so under the lawful basis called ‘legitimate interest’.
How do we process your information when you make a booking?
When you enter into a contract/make a booking we may need further personal data. This will enable our suppliers to fulfil their obligations to you. When booking a flight we will need your date of birth and passport details so that the relevant arrangements can be made with the airlines. This information will only be used to ensure you receive the best service and the information will only be processed in order for this service to be delivered.
When your holiday is confirmed, we confirm the arrangements with our suppliers, (hotels, golf clubs and airlines) ensuring you are aware of the suppliers involved. Your data will only be passed on so that the suppliers can deliver the services relevant to your holiday.
Together with our suppliers, we act as data controllers when you book with us. Your contact details are never shared with our suppliers unless necessary to deliver the services you have requested, and even in this case, our contract with them does not allow those details to be used for marketing purposes. If you have any questions about how our suppliers process your information you can call us or email firstname.lastname@example.org
During your booking, we may need to contact you directly in relation to your booking, for example, to notify you of changes or request balance payments. We will ask you to make sure that other members of your party are happy for us to process their details in the same way as your own. In order to provide you with the services you have booked with us, we rely on the ‘contract’ legal basis for all the processing.
Independently of this, we would like to ask you for a review both of our booking process and on your trip after you have travelled. For this processing we rely on our ‘legitimate interests’, but you can ask us at any time not to process your details for this reason.
How do we process your information when you email us?
All emails sent to Bilyana Golf are stored enabling us to resolve any complaints or disputes. We rely on our ‘legitimate interests’ for this processing.
How do we process your information when you visit our website?
When you visit our website, a log of your information, such as your IP address, type of browser used and the pages you visited, are stored. To ensure we analyse how visitors utilise our website and the effectiveness of our internet marketing, we use Google Analytics. We collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
The information described above, relies on the ‘legitimate interest’ lawful basis, preventing fraud, network and information security and indicating any criminal acts, or threats to public security, in line with GDPR regulations.
What rights do I have when you process data about me?
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
a) Right to be informed
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
b) Right to rectification
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.
c) Right to erasure
You can ask us to delete or remove personal data where there is no good reason for us continuing to process it. 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.
d) Object to processing of your personal data
You 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.
e) Request restriction of your personal data
This enables you to ask us to suspend the processing of your personal data.
f) Request transfer of your personal data.
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.
g) Right to withdraw consent.
Where we are relying on consent 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.
Third party data processors
We have agreements with third parties (data processors) who process personal data for us in accordance with our instructions. Below is a list of the data processors who may be processing your data on our behalf, and a brief summary of the type of processing they perform.
Google will process your personal data on our behalf as provider of our email services, as hosting provider for our websites and internal systems and as operator of Google Analytics and AdWords.
Gsuite Google provides our transactional email services and process, for example, the emailed copy of your booking documents.
Secure Trading (Secure Trading Group) provide our payment processing services.
Benchmark Email provides our email marketing service.
Your right to lodge a complaint with a supervisory authority
If you believe there is any problem relating to the way we are processing your personal data, you can always contact us by telephone or as email@example.com If you are not satisfied with the way we have handled your query, you can contact the Information Commissioner’s Office.