Touch Stay Privacy Statement

1. Introduction
2. The legal bases we rely on
3. When do we collect your personal data?
4. What sort of personal data do we collect?
5. How and why do we use your personal data?
6. How we protect your personal data
7. How long will we keep your personal data?
8. Who do we share your personal data with?
9. Where your personal data may be processed
10. What are your rights over your personal data?
11. How can you stop the use of your personal data for direct marketing?
12. Contacting the Regulator
13. If you live outside the UK
14. Cookie policy
15. Any questions?

1. Introduction

Touch Stay is owned and operated by JAM Start Ltd, a company incorporated in England & Wales.

Your privacy is important to Touch Stay. This privacy statement provides information about the personal information that Touch Stay collects, and the ways in which Touch Stay stores and uses that personal information.

When you are using the Touch Stay websites, JAM Start Ltd is the data controller.

For simplicity throughout this notice, ‘we’ and ‘us’ means JAM Start Ltd.

If you’re staying at a property and the owner uses our service to send a guide or other information to you, we’ll hold your details for them as a processor. This means that we act on their instructions and they are responsible for how they use your information through our service, and if you have any requests in relation to that information you should contact the property owner. By property owner, we mean anyone managing or administering the property or who otherwise uses our service to send you information.

2. The legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

Consent

In specific situations, we can collect and process your data with your consent.

For example, when you tick a box to receive marketing emails following an asset download.

Contractual obligations

In certain circumstances, we need your personal data to comply with our contractual obligations.

For example, if you use our services, we’ll collect your email address when creating your account to deliver notices about material changes to the services we offer.

Legal compliance

If the law requires us to, we may need to collect and process your data.

For example, we can pass on details of people involved in fraud or other criminal activity affecting Touch Stay to law enforcement.

Legitimate interest

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we may use a copy of your welcome book to ensure compatibility with new features being developed. Or we may send you help and support guidance during your subscription lifetime.

3. When do we collect your personal data?

When you visit any of our websites.

When you create an account with us.

When you engage with us on social media platforms.

When you contact us by any means with queries, complaints etc.

When you choose to complete any surveys we publish.

When you comment on or review our services.

When you’ve given a third party permission to share with us the information they hold about you.

When you subscribe to or request information and/or resources from us.

4. What sort of personal data do we collect?

If you have an account with us: your name, billing/mailing address, email addresses and telephone numbers (you must provide all of this information in order for us to be able to provide our service to you, otherwise we may not be able to accept you as a customer) and account history. For your security, we’ll also keep an encrypted record of your login password.

Details of your interactions with us through contact forms on our websites or otherwise (including how you viewed and interacted with guides, on an aggregated level).

Details of your visits to our websites, and which site you came from to ours.

Information gathered by the use of cookies in your web browser. Our cookies don’t store sensitive information such as your name, address or payment details: they simply hold the ‘key’ that, once you’re signed in, is associated with this information. However, if you’d prefer to restrict, block or delete cookies you can use your browser to do this or you can deny consent to our cookies using our cookie consent banner.

Payment card information is collected and used by our payment service providers in accordance with their privacy policies. We don’t store or have access to your payment details.

If you’re subscribed to our marketing lists, we’ll use your contact details to send you marketing. When we send marketing emails to you, we use "web beacons" to collect information about when you open the email, your IP address and browser or email client type, and other similar information. If you unsubscribe, we’ll keep your details on a “do not sent” list.

Your social media username, if you choose to interact with us through those channels, to help us respond to your comments or questions.

If you work for a supplier or other business that we deal with, we’ll also hold your contact details, details of your employment and our relationship with you.

Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.

5. How and why do we use your personal data?

There are several purposes for gathering your personal information, including for our legitimate interests in transaction processing, product development and marketing activities and for the legitimate interests set out below. Here’s how we’ll use your personal data, why and the lawful basis on which it will be processed:

To process your payment for any orders for subscriptions to our websites and to prevent fraudulent transactions. If you’re a customer and we don’t collect your personal data, we won’t be able to provide your services and comply with our legal obligations and our contract with you.

To respond to your queries and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.

To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll do all of this as part of our legitimate interest.

For example, by checking your password when you login and using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.

 

To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, significant feature changes to our services, and legally required information relating to your subscription. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.

To administer any of our competitions which you enter.

To develop, test and improve the systems and services we provide to our clients (including reviewing and providing data on how guides are viewed and interacted with). We’ll do this on the basis of our legitimate business interests.

To comply with our legal obligations to share data with law enforcement.

6. Marketing

We may contact you from time to time for the purpose of marketing activities and communications, including newsletters, surveys, competitions, offers, social media, events and so on. The legal basis for processing data in these situations is legitimate interest (of us, to promote our products and services, and of our customers, to keep them up to date with product development, news, promotions and subscriptions which may be relevant to their use of our service) if you are a business.  

If you are booked to stay at a property and receive information about it from the owner through our service (or you otherwise use our website or service) we may also ask you for consent to send you marketing information (for instance on other properties you may be interested in). In those circumstances, we won’t be acting on behalf of the property owner, but in our own right.

Of course, you are free to opt out of hearing from us by any of these channels at any time. Touch Stay will never send a marketing communication that doesn’t have a method of opting out within it.

If you are booked to stay at a property, we may also collect consent on behalf of the property owner for them to send you marketing. When we do this, we act on behalf of the property owner, and they will be the ones sending you marketing. If you wish to unsubscribe from their marketing you will need to contact them directly. Property owners may also send you administrative communications by email or text message, they are responsible for sending these communications and deciding their content.

7. How we protect your personal data

We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.

We secure access to all transactional areas of our websites using ‘https’ technology.

Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured and tokenised to ensure it is protected.

8. How long will we keep your personal data?

Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.

At the end of that retention period, your data will be deleted completely, although in some circumstances it may be necessary to keep your information for longer than that due to potential legal claims, or for accounting, technical, or reporting reasons.

Some examples of customer data retention periods:

Subscriptions

When you subscribe to our services or you or your organisation have a contract with us, we’ll keep the personal data you give us for up to seven years after the termination of your subscription or the contract so we can comply with our legal and contractual obligations.

Website visitor data

When we collect information about your visits to our website, including through cookies, we’ll keep that information for up to 5 years. 

Marketing Information

If we hold your information in order to send marketing emails to you, we’ll keep this until you unsubscribe (at which point we’ll add your details to a “do not send” list).

Other communications

If we otherwise hold your details because we’ve interacted with you (for instance in relation to enquiries or prospective customer queries) we will keep this information for up to 5 years, unless it relates to a contract or subscription, (in which case we’ll keep it as set out above).

9. Who do we share your personal data with?

Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:

• We provide only the information they need to perform their specific services.
• They may only use your data for the exact purposes we specify in our contract with them.
• We work closely with them to ensure that your privacy is respected and protected at all times.
• If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the kind of third parties we work with are:

• IT companies who support our website.
• Direct marketing companies who help us manage our electronic communications with you.
• Google/Facebook to show you our services that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites.

Sharing your data with third parties for their own purposes:

We will only do this in very specific circumstances, for example:

With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.

For example, to property owners if you have consented to this when viewing their property guide, or if we run a joint promotion with another website or service, and you agree to receive direct communications from them.

For fraud management, we may share information about fraudulent or potentially fraudulent activity on our systems. This may include sharing data about individuals with law enforcement bodies.

We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.

We may, expand, reduce or sell the Touch Stay and this may involve the transfer of the business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.

For further information please contact us.

10. Where your personal data may be processed

Sometimes we will need to share your personal data with third parties and suppliers outside the UK and European Economic Area (EEA).

Protecting your data outside the UK and EEA

The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the UK and EEA.

For example, this might be required in order to process your payment details or by IT companies who support our website.

If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the UK or EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact us.

Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

11. What are your rights over your personal data?

You have the right to request:

Access to the personal data we hold about you, free of charge in most cases.

The correction of your personal data when incorrect, out of date or incomplete.

The deletion of the data we hold about you, in specific circumstances; for example, when you withdraw consent or object, and we have no legitimate overriding interest, or once the purpose for which we hold the data has come to an end.

A computer file in a common format (CSV or similar) containing the personal data that you have previously provided to us, and the right to have your information transferred to another entity where this is technically possible.

Restriction of the use of your personal data, in specific circumstances, generally while we are deciding on an objection you have made.

That we stop processing your personal data, in specific circumstances; for example, when you have withdrawn consent, or object for reasons related to your individual circumstances.

That we stop using your personal data for direct marketing (either through specific channels, or all channels).

That we stop any consent-based processing of your personal data after you withdraw that consent.

You can contact us to request to exercise these rights at any time by emailing us at info@touchstay.com.

If we choose not to action your request, we will explain the reasons for our refusal.

Your right to withdraw consent

Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.

Where we rely on our legitimate interest

In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data, such as.

12. How can you stop the use of your personal data for direct marketing?

Direct marketing

You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.

Checking your identity

To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice.

If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.

There are several ways you can stop direct marketing communications from us:

Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.

If you have an account, log in to your account, visit the ‘Settings’ area from the ‘Dashboard’ and change your preferences.

Write to Touch Stay, 130 Wood Street, London, EC2V 6DL, United Kingdom

Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.

13. Contacting the Regulator

If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.

You can contact them by calling 0303 123 1113.

Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)

14. If you live outside the UK

If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.

16. Any questions?

We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions that haven’t been covered, please contact us:

Email us at info@touchstay.com

Or write to us at 52 New Town, Uckfield, East Sussex, England, TN22 5DE.

This notice was last updated on October 2024

JAM Start Ltd: Registered office: 52 New Town, Uckfield, East Sussex, England, TN22 5DE

Registered in England. Company registration number 09352517.