The Sleepexchange Ltd, trading as “Hoo” (“we” / “us“), respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) – https://bookhoo.com – and tell you about your privacy rights and how the law protects you. This privacy notice, together with our Terms & Conditions, any documents referred to in it and any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. It is important that you read the following carefully so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them. This privacy notice is effective from 01/02/2020.
1.1 We are the controller and responsible for your personal data.
1.2 If you have any questions about this privacy notice, including any requests to exercise your legal rights described in paragraph 10 below, please contact us using the details in paragraph 13 of this privacy notice.
2. Personal data we may collect from you
2.1 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
2.2 How you give us personal data. You may give us information about yourself by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product or service, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. We may receive personal data about you from various third parties including analytics providers such as Google.
2.3 Personal data we collect about you. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data – includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data – includes billing address, delivery address, email address and telephone numbers.
- Financial Data – includes bank account and payment card details.
- Transaction Data – includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data – includes internet protocol (IP) address, your login data, browser type and version, time zone setting and approximate location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Profile Data – includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
- Usage Data – includes information about how you use our website (including the length of your visit to it and the number of page views), products and services. If you call us, we will record the time, date and day of the week and length of your call and whether the call was answered or not.
- Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.
2.4 Aggregated data. We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity, as the data is first hashed and pseudonymised, meaning that any data that could identify a person is replaced with an artificial identifier. This can help us to share audience information with platforms such as Facebook and Google, for the purpose of such platforms displaying our adverts to our existing customers or audiences similar to our existing customers. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
2.5 Special categories. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
4. Purposes for which we will use your personal data
4.1 Personal data you give to us. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data for the following purposes and in reliance on the legal bases underlined (as applicable): a) where we need to perform the contract we are about to enter into or have entered into with you; b) where we need to comply with a legal or regulatory obligation; and c) where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests including (without limitation):
- to provide you with information about other products and services we offer that are similar to those that you have already purchased or enquired about (providing that you have not opted out of such communications in accordance with paragraph 9.1a) below);
- to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- to allow you to participate in interactive features of our service, when you choose to do so;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
- to notify you about changes to our products and services; and
- to ensure that content from our site is presented in the most effective manner for you and for your computer.
4.2 Third party marketing. Subject to your express opt-in consent being provided in advance by checking the relevant box on the order form or registration form (as applicable), we may use your personal data to provide, or permit selected third parties to provide you, with information about third party goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
5. Disclosure of your Information
5.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
5.2 We may share your information with selected third parties including: a) business partners, suppliers and sub-contractors including data processing companies and mailing houses necessary for the performance of any contract we enter into with them or you; b) advertisers and advertising networks that require the data to select and serve relevant adverts to you and others; and c) analytics and search engine providers that assist us in the improvement and optimisation of our site.
5.3 We may also disclose your personal information to third parties: a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; b) if Hoo or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions for the supply of products and services and other agreements; d) or to protect the rights, property, or safety of Hoo, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection.
5.4 We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. Where we store your personal data
6.1 The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
6.2 Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: a) we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; b) where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in the EEA; and c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
6.3 Please contact us by emailing email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
7.1 We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure your personal information.
7.2 Please note that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site and any transmission is at your own risk.
8. Links to other websites
8.1 Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy notice.
8.2 You should exercise caution and look at the privacy notice applicable to the third-party websites in question.
9. Controlling your personal information
9.1 Opting out. You are in control of what information you provide to us through this website. You may choose to restrict the collection or use of your personal information in the following ways:
a) whenever you are asked to fill in a form on the website, look for the box that you can click to indicate that you do not want the information to be used by anybody for direct marketing purposes; and
b) if you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us via the firstname.lastname@example.org email address. A link enabling you to unsubscribe from direct marketing will be included in every direct marketing communication that is sent to you.
9.2 Please note that if you choose not to share some of your information, you may not be able to access or use some areas of the site.
10. Your legal rights
10.1 You have the right to:
(a) request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
(b) request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
(c) request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
(d) object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
(e) request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- (i) if you want us to establish the data’s accuracy.
- (ii) where our use of the data is unlawful, but you do not want us to erase it.
- (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- (iv) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
(f) request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you; and
(g) withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
10.2 You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
10.3 We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
10.4 We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
11. Data Retention
11.1 We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
11.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
12. Changes to this privacy notice
This privacy notice may be updated from time to time. Any changes we may make to our privacy notice in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to our privacy notice.