Home Base Holidays - Privacy policy


1.       Introduction

1.1     We are committed to safeguarding the privacy of Home Base Holidays website visitors and members.

1.2     This policy applies where we are acting as a data controller with respect to the personal data of Home Base Holidays website visitors and members; in other words, where we determine the purposes and means of the processing of that personal data.

1.3     By using our website and agreeing to this policy, you consent to our use of cookies in accordance with the terms of this policy.

1.4     The term “Website” and “Site” in this document will refer to the Home Base Holidays website.

1.5     All content within this site, including each home exchange listing, is copyright and exclusively available to members of Home Base Holidays and members of agencies belonging to the First Home Exchange Alliance (see section 5) for the express purpose of arranging home exchanges. No part of its contents may be used for commercial solicitations by any other company, organisation or individual.

1.6     This site is a service of a subscription based, private membership organisation, and all information contained herein is unconditionally private and not in the public domain. This information is not sold or distributed publicly. No part of this online database may be reproduced, stored in a retrieval system, transmitted in any form or in any language, by any means, electronic, mechanical, photocopied, recorded or otherwise. Unauthorised use of this site will be fully exposed and will be confronted to the fullest degree of all applicable laws, both national and international. Further, all monies will be forfeited if unauthorised use is established.

1.7     Home Base Holidays is based in England and is registered with The Data Protection Registrar (registration no: PZ6863280). Home Base Holidays fulfils all obligations as a registered data user under the Data Protection Act 1998.

1.8     We do not store credit card details.

2.       Disclaimer

2.1    All information included in listings published on this website is provided by our members. Home Base Holidays publishes extensive guidelines to aid members in arranging exchanges, but we make no warranty, either expressed or implied, about the information provided. Home Base Holidays is not party to, and bear no responsibility for any agreement or contract entered into by members, subscribers or other users of information provided on this website.

2.2    Home Base Holidays relies entirely upon the integrity of members and does not guarantee the accuracy of the information provided herein, condition of the homes before or after an exchange, nor conduct of the members or users of the information in this website at any time, nor that an exchange will be available. The only responsibility of Home Base Holidays is to make available listings to its members.

2.3    Should any information provided by members be found to be grossly misrepresented, Home Base Holidays reserves the right to remove, at our discretion, any listing at any time, without refund.

2.4    Members agree that Home Base Holidays shall not be liable in any way what so ever for any direct, indirect, consequential or other damages whatsoever, regardless of the form of the claim, including but not limited to liability for cancellations, injuries to persons or damages to property, including cars or vehicles. This does not affect your statutory rights as a consumer.

3. How we use your personal data

3.1    Information you provide to us:

When signing up to a Home Base Holidays membership, you will be asked to fill in forms on the Home Base Holidays website. The information entered when signing up to a membership includes:

  • Contact information: when signing up to the Home Base Holidays website we may collect information that could reasonably be used to contact you or to identify you personally, such as your name, email address, telephone number, mobile phone number, or mailing address. This information, unless shared voluntarily by you, will always remain confidential.
  • Home swap listing information: by adding your home swap listing to the Home Base Holidays website, you will add information about the property and its location. Information you add in your home swap listing will be visible to all visitors of the Home Base Holidays website. 
  • Profile Information (Profile data): when signing up to the Home Base Holidays website you will have the option to add additional information about yourself in your Profile section. This information includes interests, number of people travelling in your exchange group, a profile photo and languages spoken.
  • Communications: when you use the Home Base Holidays website’s messaging tools to contact other members, use swap tools such as the trip reports and swap agreement, enter a competition, promotion or complete a survey, we may collect information provided by you in these communications. If you contact us for any reason, we may keep a record of that correspondence.

 

3.2 Updating your profile and personal information

By signing up to use our home swap service, you will have control of your user profile. Therefore, you will be able to access your details by logging in to your profile page on the Home Base Holidays website where you will be able to review, correct and/or update the most of your information at any time.

3.3 Passwords

We advise you to never disclose your password to any third party. Your password is encrypted for your security. You are responsible for all actions taken with your login information and password. If you choose to share this information with any third party, you are responsible for all actions taken with your login details. If your password has been compromised in any way, you should immediately change your password.

3.4 Your use of other members' personal information

We do not typically share the identity, address, email address, phone number or any other contact details of members with other members. Members communicate with each other via the Home Base Holidays website’s messaging system or via any contact details they have chosen to share with another member. In rare instances where a member urgently needs to contact another member, we may, at our discretion, provide a member's contact information to another member. By using our service, you agree that under no circumstances will you disclose another member's personal information to any third party without the express consent of that member.

4. Information we collect about you

Each time you visit the Home Base Holidays website, even if you are not a member, we may automatically collect and process certain information, “usage data” (about how you access or use the Home Base Holidays website (this is technical or statistical data and does not identify any individual). Usage data may include 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 source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely the monitoring and improving our website and services.

4.1 We may process your "account data". The account data may include your name and email address. The source of the account data is you. The account data may be processed 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. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and services.

4.2 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 proper administration of our website and services.

4.3 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is to provide the service to which users have subscribed.

4.4 We may process your personal data that are provided in the course of the use of our services ("service data"). The service data may include your name, email address, interests, home location, home description, messages sent through the Website’s messaging system. The source of the service data is you. The service data may be processed 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. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

4.5 We may process information contained in any enquiry you submit to us regarding services ("enquiry data"). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.

4.6 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details, your card details and the transaction details.  The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is providing the service. We do not store any credit or debit card details.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

5.       Providing your personal data to others

5.1 Where we store your data

The Home Base Holidays website and members’ details are stored within a SSAE-16 Certified Data Centre based in Oklahoma, USA. Our web hosts are signed up to the EU-U.S. Privacy Shield.

By submitting your personal data on the Home Base Holidays website, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is secure and in accordance with this privacy policy.

5.2 Payment processing

Financial transactions relating to our website and services are handled by our payment services providers, PayPal. 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.  We do not store any credit card, debit card or PayPal account details and so these details are not available to anyone at Home Base Holidays or our associates. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/privacy-full

5.3 In addition to the specific disclosures of personal data set out in this Section 5, 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.

5.4 Use made of the information

We will not sell or license any personal information about you to any third party. We collect personal information to help us provide you with a smooth, user friendly experience. The information you submit on the Home Base Holidays website may be used for a variety of uses, including, for example:

  • Help us improve the website experience
  • Communicate with you
  • Allow you to use certain features of the website (e.g. contacting other members, adding your home swap offer, adding your trip reports)
  • Help to resolve any disputes
  • Provide targeted marketing
  • Contact you with relevant promotions, newsletters, information about our services (you can opt out of any communications at any time).
  • Verify your identity

All information you provide to us will only ever be used in a manner that is fully consistent with this Privacy Policy.

6. FHEA (Federation of Home Exchange Agencies

Home Base Holidays is part of FHEA (Federation of Home Exchange agencies). Members of FHEA include:

  • Home Base Holidays
  • Guardian Home Exchange
  • Radio Times Home Swap
  • Green Theme International
  • Invented City

All home swap listings are shared across all FHEA websites to provide additional offers to our members. FHEA websites use the same database. Details you add to the Home Base Holidays website (including details about your home, communication through the messaging system, trip reports and swap agreement) will be available on all FHEA member websites. Your personal contact details (such as email address, phone number, postal address) will not be made available to other FHEA members unless you have given consent or you have chosen to add it to your home swap details available to members and non-members (we highly recommend that you don’t include personal identifying information in your home exchange listing as this is available to both members and non-members). By using our service, you agree that the data you provide to us will be available on all FHEA websites.

7. Promotions (including newsletters, blogs and featured offers)

As a member of Home Base Holidays, we may use information you have added to the website in our blog, newsletter, on social media and email promotions. This may include any photos, details about your home swap offer and trip reports you have added. The only information we will ever include is information that you have chosen to add to your listing or to another member’s listing (e.g. a home swap trip report).

You have the right to ask us not to use your data for marketing purposes. You can request that your data (such as the information you added to your home swap offer) not be used for marketing purposes and you can also opt out of receiving any marketing communications at any time by contacting us at [email protected] 

8. Disclosure of your information

We do not sell any personal Information about you to any third party. We may share your information with third parties, including:

  • FHEA partner agencies
  • Other members of the Home Base Holidays website or members of partner FHEA websites
  • Suppliers and subcontractors (such as web hosting, email marketing, web developers)
  • Web analytics such as Google Analytics and Bing Webmaster Tools
  • Advertisers and advertising networks such as Google Adwords and Facebook advertising (we will not disclose information about identifiable individuals to our advertisers)
  • If Home Base Holidays is acquired by a third party
  • If we are under a duty to disclose or share your personal data to comply with any legal or regulatory obligation or request (including fraud protection)

We do not promise that your personal information or private communications will always remain private. Home Base Holidays shall not be liable for any claims or damages arising from the use of your Personal Information by any third party.

9. Deactivating / deleting your account

Please contact us at [email protected] if you would like your Home Base Holidays account deactivated or deleted. Once we receive your deactivation or deletion request, we will remove your offer from our website at the soonest possible time in accordance with this Privacy Policy and any applicable laws (this is usually within three days). By default, when a member contacts us to deactivate their membership, their home swap listing is ‘hidden’ so that it doesn’t show on the website but is still stored on our database so that the member can reactivate their membership at a later date. Do please let us know if you want your data completely removed from the active database so that we can action this at the soonest possible time. When we receive a deletion request, we may need to retain your data for period as is required by applicable law or for us to resolve any disputes. Once your data has been deleted from our active databases, the data may still be stored on backup copies of the databases. Therefore, members should not expect that all their personal information will be removed from our databases after termination or cancellation of their membership.

Note: you can choose to hide your home swap listing at any time by logging in to your Member Area and changing your listing’s status to “Hidden”

10.     International transfers of your personal data

10.1   In this Section 10, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).

10.2   FHEA agencies have offices and facilities in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission’

10.3   The hosting facilities for our website are situated in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of each of the USA. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission, a copy of which you can obtain from https://www.privacyshield.gov/EU-US-Framework

10.4   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.

11.     Retaining and deleting personal data

11.1   This Section 11 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.

11.2   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.

11.3   We will retain your personal data as follows:

(a)      Your personal data will be retained for a minimum period of six months, and, if your account is inactive, for a maximum period of two years.

(b)    Your name and email address will be retained for the purposes of sending you newsletters, special offers and promotions until you unsubscribe from such communications.

11.4   Notwithstanding the other provisions of this Section 11, 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.

12.     Amendments

12.1   We may update this policy from time to time by publishing a new version on our website.

12.2   You should check this page occasionally to ensure you are happy with any changes to this policy.

12.3   We may notify you of changes to this policy by email.

13.     Your rights

13.1   You may instruct us to provide you with any personal information we hold about you.

13.2   We may withhold personal information that you request to the extent permitted by law.

13.3   You may instruct us at any time not to process your personal information for marketing purposes.

13.4   In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.

14.     About cookies

14.1   A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

14.2   Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

14.3   Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

15. Cookies that we use

These are the cookies that we may use:

15.1 Analytical cookies: These allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way the Website works. All information collected by these cookies is aggregated and, therefore, anonymous.

15.2 Necessary cookies: These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of the Website.

15.3 Functionality cookies: These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences.

15.4 Targeting cookies: These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. All information collected by these cookies is aggregated and, therefore, anonymous.

16.     Cookies used by our service providers

16.1   Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

16.2   We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

17.     Managing cookies

17.1   Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:

 

17.2   Blocking all cookies will have a negative impact upon the usability of the Home Base Holidays website.

17.3   If you block cookies, you will not be able to use all the features on our website.

18.     Our details

18.1   Home Base Holidays is a partnership business owned by Mark Sealey and Lois Sealey.

18.2   Home Base Holidays is based in England and is registered with The Data Protection Registrar (registration no: PZ6863280). Home Base Holidays fulfils all obligations as a registered data user under the Data Protection Act 1998.

18.3   Our principal place of business is at Home Base Holidays, 7 Park Avenue, London N13 5PG, England.

18.4   You can contact us:

 

Last modified on the 10th May 2018