Welcome to The Villas Collective’s privacy notice.

The Villa Collective 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) or when you otherwise provide personal data to us via other
means (such as over the telephone) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so that you can easily click through to the specific
areas set out below. Alternatively you can download a pdf version of the policy

Please also use refer to the Glossary that we have set out at the end of the Policy, if there is any
terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.

Collective Group Ltd t/a The Villa Collective is the controller and responsible for your personal data
(collectively referred to as The Villa Collective, “we”, “us” or “our” in this privacy notice.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this
privacy notice. If you have any questions about this privacy notice, including any requests to exercise
your legal rights, please contact the data privacy manager using the
details set out below.

Our full details are:

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the
UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so please contact us in the first
instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 16/05/2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us
informed if any of the details you provide to us should change, during the course of your relationship
with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those
links or enabling those connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their privacy statements. When you
leave our website, we encourage you to read the privacy notice of every website you visit.

This includes data relating specifically to your identity, such as your first name, maiden name, last
name, marital status, title, date of birth and gender.

This includes data relating specifically to your identity, such as your first name, maiden name, last
name, marital status, title, date of birth and gender.

This includes data relating to how you may be contacted, such as your billing address, delivery address,
email address and telephone numbers.

This includes data relating to your means and methods of payment, such as your bank account and payment
card details.

This includes data relating to the transactions you have carried out with us, such as details about
payments to and from you and other details of products and services you have purchased from us.

This includes more technical data that we may obtain when you make use of our website, such as your
internet protocol (IP) address, your login data, browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform and other technology on the
devices you use to access this website.

This includes information about how you use our website, products and services.

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. For example, we may aggregate your Usage
Data to calculate the percentage of users accessing a specific website feature. However, if we combine
or connect Aggregated Data with your personal data so that it can directly or indirectly identify you,
we will treat the combined data as personal data which will be used in accordance with this privacy
notice.

We collect the following special categories of personal data about you.

Details about your:

• dietary requirements which may disclose your religious or philosophical beliefs;
• health

We collect and process the above data only where it is strictly necessary to do so in order to deliver
the travel service that you have purchased. Furthermore, we will only collect and process the above
special categories of sensitive personal data where you have provided us with your explicit consent to
do so.

You are not under any obligation to consent to us processing your sensitive personal data. However,
without your consent, we won’t be able to make the necessary arrangements to provide the travel services
that you have booked or are attempting to book. As a result, if you do not provide your consent, we will
be unable to proceed with your booking.

If you are happy to consent to our use of your sensitive personal data, you will also be able to
withdraw your consent at any time. However, as this will prevent us from providing the travel service
you have booked, we will be required to treat any withdrawal of consent as a cancellation of your
booking and the cancellations in clause [TBA] of our Booking Terms and Conditions will become payable.

Where we need to collect personal data by law or under the terms of a contract we have with you and you
fail to provide that data when requested, we may not be able to perform the contract we have or are
trying to enter into with you.

In other words, where we require details from you in order to provide you with your chosen travel
services, if you do not provide us with the necessary details then we will not be able to provide the
services you have booked or are attempting to book.

In this case, depending upon when you fail to provide the necessary data, we may either not be able to
process your booking or we may have to cancel your booking, in which case we will treat this as a
‘cancellation by you’ in accordance with our Booking Terms and Conditions. We will notify you if we are unable to process a
booking or are required to cancel a booking for this reason.

You may give us your Identity, Contact, Financial, Transaction, Technical, Usage and Marketing
Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise.
This includes personal data you provide when you:

• make a booking of travel services;
• subscribe to our newsletter or other publications;
• make an enquiry via the contact form;
• request marketing to be sent to you;
• enter a competition, promotion or survey;
• give us some feedback;

As you interact with our website, we may automatically collect Technical Data about your equipment,
browsing actions and patterns.

We collect this personal data by using cookies, server logs and other similar technologies. We may also
receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further
details.

We may receive personal data about you from various third parties as set out below:

Technical Data from the following parties:

• analytics providers such as Google based outside the EU;
• advertising networks such as Facebook based outside the EU; and
• Twitter based outside the EU
• Instagram based outside the EU
• Linkedin based outside the EU

Search information providers such as:

• Google based outside the EU
• Bing based outside the EU
• Yahoo based outside the EU

We have set out below, in a table format, a description of all the ways we plan to use your personal
data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific
purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on
to process your personal data where more than one ground has been set out in the table below.

• Where we need to perform the contract we are about to enter into or have entered into with you.
• 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.
• Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in
relation to sending direct marketing communications to you via email or text message . You have the
right to withdraw consent to marketing at any time by contacting us.

We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.

We have established the following personal data control mechanisms :

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you
may want or need, or what may be of interest to you. This is how we decide which products, services and
offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased
services from us and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any company outside The
Villa Collective group of companies for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the
opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data that you
have provided to us as a result of a purchase of travel services or other such transactions.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or
access cookies. If you disable or refuse cookies, please note that some parts of this website may become
inaccessible or not function properly. For more information about the cookies we use, please see our cookies policy .

We will only use your personal data for the purposes for which we collected it, unless we reasonably
consider that we need to use it for another reason and that reason is compatible with the original
purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact
us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain
the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with
the above rules, where this is required or permitted by law.

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.

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.

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.

• Internal Third Parties

  Other companies in The Villa Collective acting as joint controllers
  or processors and who are based Vietnam and provide IT and system administration services and
  undertake leadership reporting.

• External Third Parties.

  1. Suppliers of travel services based in the United Kingdom, Greece, France, Italy, Spain and
     Morocco who provide the travel services that make up any booking of travel services that you
     make with us.
  2. Service providers based in Vietnam who provide IT and system administration services.
  3. Professional advisers including lawyers, bankers, auditors and insurers based in the United
     Kingdom who provide consultancy, banking , legal, insurance and accounting services.
  4. HM Revenue & Customs, regulators and other authorities based in the United Kingdom who
     require reporting of processing activities in certain circumstances.

You have the right to:

• 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.

• 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.

• 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.

• 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.

• 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:

  1. if you want us to establish the data’s accuracy;
  2. where our use of the data is unlawful but you do not want us to erase it;
  3. 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
  4. you have objected to our use of your data but we need to verify whether we have overriding
     legitimate grounds to use it.

• 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.

• 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.