Privacy Policy

1.0 Overview
The following Privacy Policy contains information on how personal data is processed by Smart Villas Limited. The information is provided pursuant to Article 13/14 of EU Regulation 679/2016 (hereinafter "GDPR") and the new UK Data Protection Act 2018 (which is otherwise known as GDPR) for those who interact with the services of Smart Villas Limited.

In this Privacy Policy, the terms "we", "our", "us" are used to refer to the company Smart Villas Limited. The term "customer or guest" is used to refer to the person who made the reservation.

2.0 Data Controller
Smart Villas Limited acts as an intermediary between the customer and the owner of the property, in particular by the latter is expressly authorised to rent his property.

This Privacy Policy applies to data received and processed by:
Smart Villas Limited
Registered in Leeds, United Kingdom
(+44)7503 925 581
smart.villas@outlook.com
Company number: 13865142

3.0 Type of data processed
Smart Villas Limited does not provide a list of types of Personal Data collected. 
Full details on each type of data collected are provided in the dedicated sections of this privacy policy.
Following consultation and use of the services offered by smart Villas Limited, data relating to identified persons may be processed such as, for example, name, surname, identity document number, address, photo or "other characteristic elements of your physical, economic, cultural or social identity".

We currently collect and process the following information:

Name and Surname
Date of birth
Nationality
Place of birth
ID number
Phone number and e-mail address

Unless otherwise specified, all  the requested data is mandatory, in order to exercise (b) in paragraph 5.0 Purpose of use.
Customers who have concerns about which requirements are mandatory are encouraged to contact Smart Villas Limited.
To get in touch with us, just send us an e-mail, contact us by phone or via WhatsApp.

4.0 Data communicated voluntarily by the user 
Smart Villas Limited processes the data provided when booking one of the villas, i.e. the personal data necessary to complete the booking. Depending on the booking, we may also ask for your residential address, telephone number, payment details, date of birth, the name of any other persons travelling with you in connection with your stay. 
We may also collect information through the reviews you leave us, including your display name and photo (if there is one). 

Following the booking, we process personal data to allow and optimise the services. All data available to us is saved and this data can be changed at any time.

Personal, levy and contact data, including e-mail address, and any other data provided are also processed:

• on the occasion of sending communications to our company through the methods provided on the Contact page of the website, www.smart-villas.co.uk;

We may also take your name, surname, e-mail address and telephone number, from the portals of holiday homes where the villas are advertised, at the time of booking request such as: Vrbo, Tripadvisor, Airbnb.

5.0 Purpose of use
Smart Villas Limited processes Personal Data relating to the customer in case one of the following conditions is met:

(a) if you are a customer or potential customer, for the finalisation of bookings; 
(b) the registration of all guests with the local authorities, as required by the Italian Government;
(c) for administrative purposes, for the fulfilment of legal obligations such as those of an accounting, tax, or for legal provisions to which the Data Controller is subject;
(d) to send you communications and offer assistance with one or more contact methods, such as e-mail, telephone, SMS or WhatsApp;

We use the data to manage communications sent to Smart Villas Limited, to
– respond to and manage requests;
– for sending administrative messages or security alerts;
– to invite you to leave a review;

(e) to improve our services. We may also use personal data for analysis purposes to improve our services. We undertake to use pseudonymised data only for analytical purposes.

We do not share your personal information or e-mail address with external providers.

However, it is always possible to request Smart Villas Limited to clarify the concrete legal basis of each treatment and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Under the General Data Protection Act (GDPR: The Data Protection Act 2018 in the UK), the legal bases we rely on for processing this information are:
(a) Your consent. You can withdraw your consent at any time. You can do so by contacting us using the details in paragraph 2 of this policy;

(b) We have a legal obligation;
(c) We need it to carry out a public task.

The customer's Personal Data may be transferred to a country other than the one in which the customer is located. To obtain further information on the place of processing, the customer can request more information from Smart Villas Limited. 

6.0 E-mail service
We use the e-mail address smart.villas@outlook.com to send booking notifications and/or general enquiries.

The legal basis for this is the fulfilment of our contractual obligations pursuant to Article 6 (1) (b) GDPR or consent pursuant to Article 6 (1) (a) GDPR which you can revoke at any time. The lawfulness of the data processing already carried out remains unaffected by the revocation. 

7.0 WhatsApp 
Smart Villas Limited can also be reached via WhatsApp. 
Smart Villas Limited is not responsible for the security of data transferred via WhatsApp. 
When you use the WhatsApp service, you agree to the terms of use and privacy policy of it. More information can be found here: https://www.whatsapp.com/legal/. 

8.0 Data retention
The Data are processed and stored for the time required by the purposes for which they were collected.

Smart Villas Limited takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data. 
With reference to paragraph 5.0 Purposes of use, referred to in points a. b. c. d., personal data will be processed for the entire duration of the relationship necessary to achieve the aforementioned purposes. 
For the data provided for the processing purposes referred to in point e. the data are kept for the time necessary to achieve the purpose for which they were collected, that is, to improve the service and improve any errors. More information on storage times can be requested by sending an e-mail to smart.villas@outlook.com. 

We will only retain your personal data (a copy of your personal ID) for as long as necessary; after this period, the data will be securely deleted from our systems.

We will store your data, such as name, surname, and e-mail address in our database for future marketing purposes. 

The customer has the right to contact us to request the removal of their personal data from our systems, refer to paragraph 2.0 Data Controller.

9.0 Your data protection rights 
Under data protection law, the customer has rights including:

• right of access – receive confirmation of the existence of personal data and access their content;
• right to rectification – update, modify and/or correct your personal data;
• right to erasure and restriction – request the erasure or restriction of processing of the processed data which do not require storage in relation to the purposes for which the data were collected or processed;
• right to object – The right to object to the processing of your personal information in certain circumstances;
• right to revocation – withdraw consent;
• right to data portability – request the transfer of personal information you provide to another organisation, or to you, in certain circumstances;

Requests must be addressed to Smart Villas Limited, by sending an e-mail to smart.villas@outlook.com.

10.0 Transfer of data to non-EU countries
Smart Villas Limited, is based in the United Kingdom, not belonging to the European Union, which nevertheless offers an adequate level of data protection, as set out in the UK Public General Act - Data Protection Act 2018.

11.0 Changes to our Privacy Policy
Smart Villas Limited reserves the right to make changes to this privacy policy at any time by notifying customers by e-mail, if possible, or on the website, as well as, if technically and legally feasible, by sending a notification to customers through one of the contact details in its possession.
Please therefore consult our website frequently, referring to the date of last modification indicated below. 

Last modified: 03 January 2023.

12.0 Complaints
If there are concerns about our use of your personal information, please file a complaint using the details in paragraph 2.0 Controller of this policy.