Touch Stay Privacy Statement
- The legal bases we rely on
- When do we collect your personal data?
- What sort of personal data do we collect?
- How and why do we use your personal data?
- How we protect your personal data
- How long will we keep your personal data?
- Who do we share your personal data with?
- Where your personal data may be processed
- What are your rights over your personal data?
- How can you stop the use of your personal data for direct marketing?
- Contacting the Regulator
- If you live outside the UK
- Any questions?
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.
We’ll notify you of any significant changes to this Privacy Notice.
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.
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:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive our email newsletter or marketing emails.
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.
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.
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.
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.
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. 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.
Details of your visits to our websites, and which site you came from to ours.
Payment card information.
Your social media username, if you choose to interact with us through those channels, to help us respond to your comments or questions.
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?
Here’s how we’ll use your personal data and why:
To process your payment for any orders for subscriptions to our websites and to prevent fraudulent transactions. If we don’t collect your personal data during checkout, we won’t be able to process your order and comply with our legal obligations.
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.
With your consent, we will use your personal data, preferences and details of your subscription to keep you informed by email about relevant services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
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, based on your consent given at the time of entering.
To develop, test and improve the systems and services we provide to you. We’ll do this on the basis of our legitimate business interests.
To comply with our contractual or legal obligations to share data with law enforcement.
6. 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.
7. 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.
Some examples of customer data retention periods:
When you subscribe to our services, we’ll keep the personal data you give us for five years after the termination of your subscription so we can comply with our legal and contractual obligations.
8. 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, 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 our Data Protection Officer.
9. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA).
Protecting your data outside the 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 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 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 our Data Protection Officer.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
10. 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 firstname.lastname@example.org.
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.
11. How can you stop the use of your personal data for 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, 31A Park Rd, Burgess Hill, RH15 8EU, UK
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
12. 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)
13. 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.
For all non-UK customers
By using our services or providing your personal data to us, you expressly consent to the processing of your personal data by us or on our behalf. Of course, you still have the right to ask us not to process your data in certain ways, and if you do so, we will respect your wishes.
Sometimes we’ll need to transfer your personal data between countries to enable us to supply the goods or services you’ve requested. In the ordinary course of business, we may transfer your personal data from your country of residence to ourselves and to third parties located in the UK.
By dealing with us, you are giving your consent to this overseas use, transfer and disclosure of your personal data outside your country of residence for our ordinary business purposes.
This may occur because our information technology storage facilities and servers are located outside your country of residence and could include storage of your personal data on servers in the UK.
We’ll ensure that reasonable steps are taken to prevent third parties outside your country of residence using your personal data in any way that’s not set out in this Privacy Notice. We’ll also make sure we adequately protect the confidentiality and privacy of your personal data.
If you have any questions, please contact our Data Protection Officer.
To make full use of Touch Stay, your computer, tablet or mobile phone will need to accept cookies, as we can only provide you with certain features of this website by using them.
We use the following cookies:
- Strictly necessary cookies.
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of payment services.
- Analytical/performance cookies.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies.
These are used to recognise you when you return to our website. This enables us to personalise our content for you and keep you logged in to your account.
- Targeting cookies.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
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 from any website, you can use your browser to do this.
Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.
Third Party Cookies
When you visit our websites you may notice some cookies that aren’t related to Touch Stay. If you go on to a web page that contains embedded content, for example from YouTube, you may be sent cookies from these websites. We don’t control the setting of these cookies, so please check the third-party websites for more information about their cookies and how to manage them.
All these third party cookies detailed below may collect personal data. Please note that we can’t be responsible for the content of external websites.
15. 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 our Data Protection Officer who will be pleased to help you:
Email us at email@example.com
Or write to us at Data Protection Officer, 31A Park Rd, Burgess Hill, RH15 8EU, UK
This notice was last updated on 25 May 2018
JAM Start Ltd: Registered office: 31A Park Rd, Burgess Hill, RH15 8EU, UK
Registered in England. Company registration number 09352517.