Privacy Policy

Privacy Policy From La Cala Lettings

Protecting our users personal data is an important concern for our company. All of La Cala Lettings web activities comply with European legislation and the GBDe Recommendations (linked to: issued in September 2001.

This privacy policy governs the treatment of the information La Cala Lettings gathers on you when you visit this Web site.

Collection and Processing of Personal Data 

Personal data is information that identifies you, e.g. your name, your address, e-mail or postal addresses. La Cala Lettings does not collect personal data from you except when you specifically provide it, e.g. Email or telephone contact.

Use and Divulgence of Personal Data 

La Cala Lettings 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. La Cala Lettings will neither sell your personal data to third parties nor market it elsewhere unless you give us permission to do so. The employees of La Cala Lettings are duty-bound to respect the confidentiality of your data and abide by the the assoicated Industry Codes of Conduct.

Freedom of Choice

You control the information you provide La Cala Lettings about yourself. However, if you choose not to share your information with La Cala Lettings, please be aware that you may be unable to access some of the Area of the web site or place an order online and may be impacting on the level of service we can provide you.

Automatically recorded information (non-personal data) 

When you access the La Cala Lettings 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 Web site's appeal and to improve its content and functionality. Your data is not processed any further nor is it transmitted to third parties.


Cookies are tiny files that are temporarily stored on your hard disk, enabling our site to recognise your computer the next time you visit the La Cala Lettings web site. La Cala Lettings uses cookies in the gustbook area of the site and reserves the right to use Cookies exclusively to collect information concerning the use of our Web site. Cookies contain no personally identifiable data, so the protection of your privacy is ensured. Depending on your settings, your Internet browser will automatically accept Cookies. However, you may change your browser settings at any time and choose to access La Cala Lettings web site without accepting Cookies.


La Cala Lettings 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.


La Cala Lettings 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 La Cala Lettings Web site without the permission of their parents or guardians. La Cala Lettings 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 Web sites 

This statement on privacy protection applies for the homepage hosted by i-pro. The Web pages in this hompage may contain links to other providers within and outside the La Cala Lettings website, to which this privacy protection statement does not extend. When you leave the La Cala Lettings Web site, please be aware of and read the privacy statements of each and every Web site that collects personally identifiable information.

Online Payments and Transactions 

All online payments made on this Website are handled by WorldPay. For full legal documentation for their service usage and privacy policy please contact WorldPay.

Please note that La Cala Lettings do not store any financial information i.e. credit card details, once your payment has been processed these details are destroyed.

Right to information

If you have questions concerning our privacy protection policy or how your personal data is processed, please feel free to contact us.


Upon request, you will promptly be informed - in writing which of your personal data, if any, was collected during your visits to the La Cala Lettings Web site.

Notification of changes 

Any changes to our privacy policy will be posted to this privacy statement, the homepage, and any other places we deem appropriate. 

Online Content

The author assumes no liability whatsoever for the topicality, correctness, completeness or quality of the information provided. The author shall be held harmless for any and all liability claims against the author for material or intangible damage arising from the use or non-use of the information provided, or from the use of defective and incomplete information unless the author's intentional or grossly negligent fault is proven. All content is subject to change without notice and is non-binding. The author expressly reserves the right to modify, supplement or delete parts of the pages or the entire content without prior advance notice, or to suspend or terminate publication.

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 guestbooks, 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.

Adverts and Sponsored Links

This website may contain sponsored links and adverts. These will typically be served through our advertising partners, to whom may have detailed privacy policies relating directly to the adverts they serve.

Clicking on any such adverts will send you to the advertisers website through a referral program which may use cookies and will tracks the number of referrals sent from this website. This may include the use of cookies which may in turn be saved on your computers hard drive. Users should therefore note they click on sponsored external links at their own risk and this website and it's owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and it's owners participate on are custom to the terms and conditions as well as the privacy policies held with each social media platform respectively.

Users are advised to use social media platforms wisely and communicate / engage upon them with due care and caution in regard to their own privacy and personal details. This website nor it's owners will ever ask for personal or sensitive information through social media platforms and encourage users wishing to discuss sensitive details to contact them through primary communication channels such as by telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account.

Shortened Links in Social Media

This website and it's owners through their social media platform accounts may share web links to relevant web pages. By default some social media platforms shorten lengthy url's [web addresses] (this is an example: 

Users are advised to take caution and good judgement before clicking any shortened url's published on social media platforms by this website and it's owners. Despite the best efforts to ensure only genuine url's are published many social media platforms are prone to spam and hacking and therefore this website and it's owners cannot be held liable for any damages or implications caused by visiting any shortened links.

Copyright and Trademark Law

The author endeavors 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 simple mention shall not be interpreted as such that brands are not protected by third-party rights. 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.

To protect our unique content we consistently copyscape our site to ensure that our content is not duplicated by other sites.  If your site if found using our content then all search engines will be notified with the aim of having you removed from the index permanently, legal action will proceed to claim back possible damages caused.

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.




Data Controller:

Name: Howard Johnson

Address: 4 Victoria Avenue, Grappenhall, Warrington, WA4 2PD

Telephone Number: 01925 596565

Email address:


What this Notice is about

 This Privacy Notice tells you what information we obtain and hold about you whether you are a past or future client, guest, party member or property owner (You). it explains what information we collect, why we collect it, and what we do with it, as well as who we share it with.  We collect and handle personal information about you to enable us to provide holiday accommodation.  This includes dealing you're your enquiries and reservations, arranging lettings, key collection information, property arrival and departure times, property management (including dealing with repairs), rent collection, dealing with any complaints, maintaining our accounts and records, information collected on behalf of the authorities in Spain and administering breakage deposits.  

We call this information "your information".  It is also referred to as "data". 

Where this notice is given to the lead party member and information for all occupants of the property (the party) then it is agreed that permission has been granted by all travelling party members for the lead part member to do so in representing the whole party and that the notice given is deemed to have been given to each party member separately.

You should read this notice when you give us information, so you are aware of how and why we are using this.  Please update us if any information supplied by you changes.

Why we are giving you this notice

We are required by data protection law to give you this notice.  We must be open with you about why information is collected about you and then what is done with it.  We must act fairly in relation to this information.  You have various legal rights relating to this information which are spelt out in more detail in this notice.    

In order that we can collect or use information about you there must be a legal basis or gateway for doing so.  This notice identifies the relevant gateway for the various types of information we collect and hold about you. A detailed explanation of these gateways is given in this notice. 

Under data protection legislation we can only process data "as necessary" and only to the extent that it is needed.  For example, we can use your passport details to satisfy the legal requirements of the Spanish authorities and other limited purposes only.  However, in certain instances, as necessary, we can share any of your data, e.g. with our own professional advisers or property managing agents.  We may also share any of your data, as necessary, with the police/law enforcement agencies or regulatory authorities. 

The data we collect/hold about you

We use different ways to collect data about you including the information you supply to us when enquiring or reserving a holiday property.  If you fail to provide this information we may not be able to proceed. 

As necessary personal data is processed by us (or by any property managing agent we retain) relating to you consisting of the following as applicable: -

  • Identity and contact details.
  • Deposit.
  • Lead party member and all other party members.
  • Rent and other payments.
  • Arrival and departure times and airline flight details if applicable.
  • Passport details.
  • Andalusian Tourist Registration forms (ATR)
  • Recovery of arrears, claims or possession proceedings
  • Repairs/health and safety/housing conditions
  • Breach of holiday letting terms/nuisance/anti social behaviour
  • Audio and CCTV recordings (if any)
  • Complaints
  • Health or disability
  • Emails texts and other communications and via our website.  
  • Website and online portal information.

We also generate and use data internally, e.g. our holiday letting records.

We also collect and receive data about you from third parties.  This may be information given to us by other guests or residents or neighbours or property owners.  Public bodies such as local authorities or the police, or other law enforcement agencies may give us information about you.  Where the property is let or managed on our behalf by an agent the agent may supply us with information about you. 

Sharing data with others

We will share information we hold with others, where this is necessary.  When we do this, we must comply with data protection legislation.  Information can be shared with the Property Manager, Property Community Manager, the Property Owner and the Spanish Police and Authorities. Contractors/ suppliers; utilities and service providers; tradespeople; financial organisations (including banks and insurance companies); debt collection and tracing agents; public and government bodies courts; police and law enforcement agencies; taxation authorities; letting and managing agents; and any future owner of the property. We may need to share information with your next of kin etc., e.g. in an emergency.  It may be necessary for us to share information with a future owner of the property if the current owners are selling.  We also may share information with professional advisers such as lawyers and accountants or an advice agency which involves sharing information about you with them.  In some cases, we may be under a legal obligation to provide information either because of the law or because of a contractual obligation binding on us. What we share will depend on what is necessary in the circumstances.  

Search engines, websites, etc

As necessary, we may obtain information about you which is publically available via search engines such as Google or Facebook and websites.  This will include information about you which you yourself made public.  Further details are set out in the Table.  However, when doing so we make sure that we comply with applicable guidelines under data protection legislation.

Special categories of data/sensitive personal data


In limited situations we will process information about your health or any disability.  This data is given special protection under data protection law.  Normally we would expect to ask you for your explicit consent before we collect or use this kind of data. 


In cases where you rent a property where a child resides, information will be given to us about resident children; usually by an adult such as a parent on their behalf.  Data protection law requires us to give such information additional protection where we collect or use it. 

Obligation to process data

Private renting is highly regulated, so we are under various legal obligations.  These include an obligation to provide the Spanish authorities with the details of all members in your travelling party including passport numbers, dates of birth and travel dates in Spain. We may need to handle data for this purpose, e.g. to give the authorities the information that they demand from us.

Why we collect data and the legal basis for processing your personal data

We must tell you why we collect and hold information about you.

We must also have a legal basis before we can collect or process your personal data.  Processing personal data includes recording, storing, altering, using, sharing or deleting data.  We only need one of these "gateways" and for our purposes they are -

  • You consent.  Consent may be requested in certain cases, but generally we do not rely on your consent to process your personal data.
  • To perform our contract so that we can carry out our responsibilities under the holiday letting agreement with you, including anything you request us to do with a view to you becoming a client.
  • Compliance by us with a statutory or other legal obligation.
  • Where this is in your vital interests, e.g. if there is a life-threatening situation.
  • Where we are pursuing our own legitimate interests or those of a third party.  This will not apply if our interests are overridden by your interests or your fundamental rights and freedoms.  We must carry out a balancing exercise therefore to decide whether we can rely on this gateway to ensure that it applies.  In each case we have done this, and we do not consider your interests, rights or freedoms outweigh our own or those of the third party concerned. 

This notice identifies the relevant gateway applicable in each case.  In some cases, we will rely on more than one gateway depending on the purpose for which we are using your data.

Additionally, any data must be processed by us fairly and openly. 

Why we process your data

The various purposes for which it may be necessary for us to process various categories of your information include: -

  • In our legitimate interests for deciding on the suitability of a proposed client
  • To perform our holiday letting contract to deal with all party members who are linked to the booking
  • In our legitimate interests to secure rental payments/performance of client obligations, e.g. deposits and balance payments and payments for booked extra's.
  • For contractual performance for rent collection and collection of other payments including banking details and debit and credit card payment processing.
  • For contractual performance for managing the holiday letting and the property
  • For contractual performance and/or in our legitimate interests for record keeping
  • For contractual performance for arranging repairs and maintaining the condition of the property and keeping it in a safe condition.
  • For contractual performance for monitoring and enforcement of client responsibilities
  • For contractual performance for monitoring and enforcement of property owner responsibilities
  • For contractual performance or in our legitimate interests for recovering debts and other payments due, including any possession proceedings
  • In our legitimate interests in relation to holiday let agreement termination including the return of any deposit or balance payment agreed to be repaid.
  • In our legitimate interests for processing complaints
  • For contractual performance or in our legitimate interests for dealing with health and disability issues relating to clients/residents
  • In our legitimate interests for obtaining and holding audio and cctv recordings
  • To perform our legal obligations to provide information to public or local authorities who are legally entitled to require this information
  • In your vital interests for contacting next of kin etc., in an emergency
  • In our legitimate interests for the storage of emails, records of calls and other communications
  • In accordance with our legal obligations if you exercise your rights under data protection law
  • To perform our legal obligations for compliance with legal and regulatory requirements
  • In our legitimate interests for the establishment and defence of legal rights
  • In our legitimate interests for prevention, detection and investigation of crime and anti social behaviour and the security of any website or other means of electronic communication

We may change the purposes where this is compatible for the purpose for which we obtained the data originally.  If we need to use your data for a non-compatible purpose, we will notify you and explain the legal gateway that allows us to do so.  We may process your information without your knowledge where this is required or permitted by law.   

More information about what we do with data and why, along with the relevant legal gateway is given in the Table.  This also tells you who we share data with and receive it from. 

Retaining Communications

We will monitor, record and retain your calls, emails, text messages, social media messages and other communications.  This is in our legitimate interests to maintain an accurate record of these.  This may be necessary to manage your holiday let / holiday letting or the property or to deal with your enquiry and/or reservation for a holiday let or to deal with clients / residents / property owners or prospective clients / residents / property owners.  We need these records for our ongoing dealings with you, including our data protection obligations.

Length of storage of data

Data can only be stored on a time limited basis and not indefinitely.  We will hold personal data about you for the duration of your holiday let and for seven years after your occupation has ended.   This is the statutory limitation period six years plus a further year to allow for service of proceedings should proceedings commence later.  We are also required to retain information for up to six years for tax purposes.  If your enquiry does not go ahead then we retain data for one year. 

Storage and security of data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.  In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.  They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

All our information is stored securely electronically on servers or devices.  Certain information is also retained on a secure basis in hard copy format. 

Telephone calls

To protect our legitimate interests telephone conversations may be recorded electronically for monitoring and to ensure that we have a record of what is said.  You or others may leave messages when calling.


When we install CCTV, this is for security purposes in cases where we consider that it is in our legitimate interests to carry out such monitoring which must be done in accordance with legal requirements.  We may also use CCTV to detect breaches of the occupancy terms, e.g. in the common parts or outside the building.   Recordings will be kept for these purposes.

Information legally required under your Holiday Letting Agreement

Your Holiday Letting Agreement provides that in certain situations you must give us information when asked.  This is a legal obligation because it is a contractual requirement.  You should refer to the relevant clauses in your Holiday Letting Agreement which tell you the situations in which such information must be given.

Holding data outside the European Union

Our email account and web provider is i-pro software.  Our email account is web based.  Providers store related data internationally and not necessarily within the European Union.  The recipient of this data is the provider concerned.  You need to refer to the provider concerned to determine if they have the required clearance (adequacy decision) from the EU authorities or whether, instead, there is an agreement containing appropriate and suitable safeguards and to obtain a copy of this agreement. 

Your rights

Where we hold personal data about you, you are the data subject.  Data protection legislation gives you several rights.  To exercise any of these rights you should contact us.  You can do so by email at the address given above or you can telephone us on the number given above.  You can also write to us at our address given at the top of this notice.   Normally no fee is payable. 

You have a right to object to the processing of your information where we are processing this in our own legitimate interests or those of someone else.  This applies if you feel that this impacts on your own interests or your fundamental rights or freedoms. 

These rights are as follows -


  • Access - you have the right to make a request to be told what personal data we hold about you. This is a right to obtain confirmation that data has been processed and to have access to your personal data and the right to information details which should be provided with the privacy notice.
  • Correction/Rectification - if you consider any data we hold about you is inaccurate you can tell us so that where appropriate this can be corrected.  Where a mistake is made in data processing then you can ask to have it rectified.  Any third parties who have received the data from us should then be told of the rectification and you should be informed by us of any such third parties.   
  • Erasure - you have a right to ask us in certain circumstances to erase any data we hold about you (the so called right to be forgotten). Individuals can request the right to have personal data erased to prevent processing in specific circumstances, i.e. it is no longer necessary, consent has been withdrawn, there is an objection and where applicable your rights etc., override the legitimate interests to continue our processing, or data has been unlawfully processed.
  • You can object to our processing of data - this allows you to object to our processing of data about you.  We must then stop processing data unless we can establish legitimate reason for continuing.  In particular this applies where we are relying on our own legitimate interests or those of a third party to process data but it can also apply in other situations.
  • Restricting processing - you can ask us to suspend processing of your personal data and we must then restrict processing of data.  This includes where you are contesting the accuracy of a statement or the lawfulness of the processing.
  • Data portability - this allows individuals to reuse their personal data for their own purposes across different services allowing them to move, copy or transfer personal data more easily.

Withdrawal of consent

Where your consent provides us with the legal gateway to process data about you you can withdraw this at any time by telling us by email or post using the telephone/addresses given above.  


We operate our own internal complaints policy and if you have any concerns about the way in which we collect or handle data please contact us.

Additionally, you have the right to lodge a complaint with the Supervisory Authority who is -

Information Commissioner

Information Commissioner's Office
Wycliffe House
Water Lane




About this Table


As necessary, we collect, use and otherwise process different categories of information (data) about you relying on the various legal gateways available to us.  This relates to your application for a holiday letting and, if this goes ahead, so that we can manage the holiday letting and the property along with associated matters.   This part of this notice gives you a general description of these processing activities for the different categories of information and the purposes for which we process your information.  If you consider that we have not given sufficient details of what we do, then you can make an access request for more information.




Renting out residential holiday accommodation and managing holiday lettings and rental properties is multi-faceted.  As clients, residents and property owners are at the centre of this service, we must process your data for many different purposes.  Data protection law requires us to give you information about these processing activities as concisely as possible.  To do so we have split information about you into different categories, which is in line with requirements in the legislation.  We also must tell you the extent for which your information can be used and shared.  Due to the nature of our business information falling into one category will be combined with information in other categories to be handled by us as permitted for the stated purposes under the relevant legal gateway which we have to identify.  For example, information about your identity/contact details will be combined with other categories of information to correctly identify you, e.g. when we compile our accounts or pass information about a repair over to a contractor so that they can deal with the problem at the property you rent.  However, we only do this to the extent that it is necessary in the circumstances.


Expressions used


To make this Table as concise as possible we employ several expressions -


Handle information - collecting, compiling, using or storing information (data).


Use information - when we use information this means we consult it, compile it, refer to it to make a decision, or act on it, or combine it with other data.  When using it in this way we may have to alter it. 


Share data - this includes transferring data to someone else where this is necessary, or receive it from a third party.


Collect data - this is where we receive information either from you, e.g. when you sign a holiday letting application form or from a third party, e.g. a reference about you.


Compile data - this is where we use information about you which we have collected to generate information about you, e.g. our rent payment records or repair records.


Next of kin etc. - this includes close relatives.


Altering Data


We are required by data protection legislation to keep your information up to date and it is of course in our own legitimate interests to do so for us to ensure that we have accurate records.  For example, we keep our record of your rent payments up to date as they are received. 


Storing Data


We keep information both electronically and in a manual filing system to maintain our records.  We do this because we need to use it from time to time.  Normally the legal gateway permitting us to do so which will apply will be the same as applies when we use the data.  Additionally, however, there are legal obligations to retain data under data protection law, taxation legislation and housing law.  We also need to do so to fulfil our contract with you.  In our own legitimate interests, we also need to retain information to deal with enquiries or disputes and for audit purposes.


Destruction of Data


We delete/destroy data once it is no longer needed.  This is a requirement of data protection law.  This notice tells you the period for which we normally store data. 


What this Table tells you


Information is handled as necessary from time to time.  As already stated, information falling under one category can be amalgamated with or added to information in another category to carry out the stated purposes. 


Part 1 of this Table tells you, depending on the relevant category of your information, what our processing activities are and what is the legal gateway permitting processing as well as the purpose for which we carry out these processing activities.


Where the legal gateway in question is our own legitimate interests (or those of a third party) we identify the relevant legitimate interests. 


Details about sharing data are set out in Part 2, whether we transfer it to someone else or receive from a third party. 


Part 1 - Collecting, compiling, using and storing your information


In this Part we list out the different categories of your information, briefly explain them where needed, explain what we do with the information and why, as well as specifying the relevant legal gateway we rely on to do so.


We use the word "handle" to cover collecting, compiling, using or storing this information. 


Identity and contact details


  1. This includes name, contact details, date of birth and national insurance number
  2. We handle this information to enter into the holiday letting agreement and subsequently to manage the holiday letting and the property.  This is done to perform the contract.


Personal and background information


  1. This includes details of the client's present residence and contact details.  
  2. This information is handled to provide contact information to enable us to communicate effectively with you.
  3. We also handle this information which relates to next of kin etc., to contact them in the event of an emergency.  This is to protect your vital interests.
  4. This information will also be handled if we need to trace you to contact you in connection with the holiday letting or the property or to pursue a claim against you, e.g. for rent arrears.  This is in our own legitimate interests.  These are to enforce your obligations, deal with property left behind at the property or to recover property. 


Holiday letting details


  1. This includes details of the holiday letting.  Information within this category includes the address of the property, start date for the holiday letting, period of occupancy, rent and other payments.
    1. We handle this information to prepare and complete the holiday letting agreement and then to manage the holiday letting and the property.  This is done to perform our contract.
  2. Where you are a joint client all other party members are linked with the holiday letting/property.
    1. We handle this information to prepare and complete the holiday letting agreement and thereafter to manage the holiday letting and the property.  This is done so that we can form a contract.
  3. We handle this information to protect our own legitimate interests.  This is to provide security for the payment of the rent and to ensure compliance with holiday letting obligations.  

Rent and payment collection

 This includes records we compile to record receipt of rent and other payments from you and associated documentation relating to such payments.  This also includes any documentation where we need to issue reminders for payment, including invoking booking suspension and booking cancellation policies if payment is not received on time.

  1. We keep this information to compile correct and up to date records.  This is done for contract performance.

Repairs/housing standards/health and safety

  1. This includes condition surveys, inspection reports, reports of repairs required and information about actions taken.  This extends to conditions and standards generally at the property including health and safety, e.g. gas safety. 
  2. We handle this information to ensure that the property and its contents are properly maintained.  This is done both for the purposes of contractual performance and, where applicable, to comply with our legal obligations.

Breach of holiday letting agreement/nuisance etc.

  1. This includes complaints which we receive or information which we hold relating to alleged breaches by a client or resident (which could include a child) including nuisance and anti social behaviour.  This includes records and related communications.   This includes complaints about these matters made by neighbours or other clients or residents.
  2. We handle this information to ensure that holiday letting obligations are complied with and that clients and residents live harmoniously with neighbours.   This is to protect our own legitimate interests and the legitimate interests of affected third parties.  These legitimate interests are ensuring the holiday letting obligations are complied with as well as the prevention and detection of crime and anti-social behaviour. 




  1. We operate a complaints procedure which may be informal.  Although we will do all we can unfortunately sometimes things go wrong so complaints may arise. 
  2. Information handled concerns complaints which you may make, or which may be made on your behalf.   These will give rise to communications and records being compiled by us. 
  3. We handle complaints with a view to resolving these, although this might involve external intervention, e.g. by the courts. 
  4. We handle complaints for contract performance.  This is also done in our own legitimate interests.  These are to protect ourselves against claims and to ensure that the complaints are properly resolved.  




  1. Importantly, this is sensitive personal information to which additional protections apply.  We may be given information about your health (whether mental or physical) or disabilities.   
  2. Health information may be given to us to explain your absence from the property or as a reason why rent has not been paid.  You may wish us to have information about your health so that we are aware of how you may need assistance on occasion.   This could also be information about health or disabilities affecting someone else which impacts on you.
  3. We may be given information about your disabilities so that we can make particular arrangements for you.  
  4. We handle information about your health or disability, and the health of others depending upon the circumstances to assist us in the management of the holiday letting and the property.  This may be to protect your vital interests.  It may alternatively be for contractual performance where it affects your ability to perform your contractual obligations under the holiday letting agreement.  It will be in our own legitimate interests if we are told of any medical condition which affects you.  This is so we are aware of possible impacts on you.
  5. In regard to information concerning any disability, we handle this information to assist in the management of the holiday letting and the property. 
  6. In addition, as this is special category data, additional legal requirements are imposed upon us about your health and/or disability and we may request your consent to handle this information.


 CCTV and Audio

 If we operate cctv you will be given information about this.  We may operate cctv to cover common parts or the exterior of the premises. 

  1. We may also hold audio recordings, e.g. messages from you on telephone answering machine or mobile phone.
  2. Where cctv is operated this is for the safety and security of the premises in question and for the prevention and detection of crime and anti social behaviour, as well as monitoring holiday letting obligations.  This is done in our own legitimate interests.  These include the protection of our property and ensuring compliance with holiday letting obligations as well as the safety and security of clients, residents and neighbours.
  3. We handle audio recordings to assist with accurate record keeping.  This is done for contract performance or in our own legitimate interests.  These are to ensure that we have reliable records of communications. 

 Correspondence etc

 Correspondence includes all ways in which we receive communications from whatever source.  This includes emails, text messages, social messaging and messages, letters and documentation.  This can include photographs and other visual recordings.

  1. We handle these communications initially relating to entering into the holiday letting agreement and then for the management of the holiday letting and the property, as well as associated matters arising under the various categories of information referred to in this Table.  This is done for contractual performance where applicable, to carry out any applicable legal obligations imposed on us, to protect your vital interests, or in our legitimate interests.  These legitimate interests are to ensure that we have the necessary information relating to these matters and for accurate record keeping.


Websites and online platforms


  1. Information about you is available in the public domain, often put there by you.  This can be accessed by appropriate searches which allow for access to the websites which hold this information.
  2. Information about you is also made available when you access online platforms, e.g. to enquire about properties which are available for renting. 
  3. We handle this information for the management of the holiday letting and the property.  This is in our own legitimate interests to ensure that clients/residents are suitable and that the holiday letting, and the property are effectively managed.  This can include ensuring that holiday letting obligations are performed.  These legitimate interests are to ensure that our property interests are protected, and our rights are enforced. 
  4. We handle information received via our online platforms for contract performance, including arranging lettings and entering into holiday letting agreements.




  1. We handle information about you which may be relevant to our insurances to arrange cover, to administer insurance contracts, to renew insurances and to make claims.  Contractually we are under certain duties, e.g. to disclose information to the insurers.  We handle this information to protect our legitimate interests.  These are to ensure that appropriate risks are adequately insured against and to recover any sums due to us under the policy because of claims.
  2. It is your responsibility to insure your own contents/belongings.  You may seek information from us relevant to arranging such insurance or making claims.  We handle this information and will do so with your consent which is provided as part of your request for any assistance or information.


Apartment management


  1. This applies in particular where the property is an apartment.  This apartment will be held by the property owner under a lease or subject to other contractual arrangements which will set out various responsibilities for the upkeep, insurance etc., of the block including common areas.  The lease or other arrangements place contractual obligations on us which in turn may be passed on to you under the terms of the holiday letting.
  2. We handle information about you to carry out our responsibilities under these leases/arrangements.  This is done in our own legitimate interests and in the interests of the freeholder etc., of the block to ensure that respective obligations are properly performed.