Welcome to the Onee (“Onee”) privacy policy. Onee Travel Services Ltd owns and operates the Onee website www.onee.com (the “Website”) and the booking platform (the “Platform”) collectively referred to as the Onee “Service”. For more information about Onee, please visit our website www.onee.com.
We have developed the Onee Service to facilitate the active distribution of vacation rental properties through a global list of travel advisors (“Travel Advisors”) and providing suppliers (“Suppliers”) with a tool to decide on reseller margins for properties. We are committed to protecting and respecting the privacy of the users of the Service. This privacy policy (“Privacy Policy”) sets out the basis on which (i) your personal data, as a Travel Advisor or Supplier, will be processed by us as a controller and (ii) your end customer guests’ personal data will be processed by us as a processor. Please read the Privacy Policy carefully to understand how we will use your personal data.
If you have any questions about your personal data, how we look after it or if there are any changes to your personal data, please:
If you visit our Website or register on our Platform we may use your personal data in connection with your request for or use of our Services. In order to use the Services, you must accept our Terms and Conditions which are available here. Where this is the case, in accordance with UK and European Economic Area (“EEA”) data protection laws, we will be the controller of the personal data that you provide to us or that we collect from you. We will be responsible for safeguarding your personal data which will be processed in accordance with this Privacy Policy.
Our Service is intended for use by Travel Advisors and Suppliers. However, our Service provides the functionality for Travel Advisors and Suppliers to input and collect information about the end customer guest (“Guest”). Where we process any Guest personal data, our role will be limited to that of an intermediary and we will be considered a processor in accordance with UK and EEA data protection laws. We will be processing Guest personal data on behalf of Travel Advisors and/or Suppliers, who will be the controllers of any Guest personal data, under the terms and conditions that we have in place with the Travel Advisors and Suppliers. The Travel Advisors and/or Suppliers will be responsible for the processing of Guest personal data on our Website or Platform, which will be processed in accordance with their own privacy policies. For example, a Travel Advisor may input Guest personal data in order to search for a vacation rental property and provide a quote or complete the reservation. The Supplier will use the Guest personal data to receive the payment from the guest and issue the completed booking documentation.
We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate Guest personal data from confirmed bookings for internal reporting purposes.
When you use the Service, we may collect, use, store, transfer and otherwise process the following types data depending on your relationship with us:
| Category of data | Types of data collected |
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| Business representative contact details | When you register for our Service on behalf of your organisation, you may be required to provide us with your:
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| Company Data |
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| Billing Data |
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| Feedback and Enquiry | Information about you from correspondence that you send to us, any conversations between us and any feedback you give to us. |
| Marketing and Communications Data | Information about your preferences in receiving marketing material from us and your communication preferences. |
| Technical Data | We may automatically collect the following types of information when you use our Services:
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| Usage Data | We may generate information about how you navigate and engage with our Services and download materials and online activity data such as clickstream data, page interaction information, your preferences (including country and language) and methods used to browse away from our content or Services. |
The law treats some types of personal data about you as “special” and such data requires more protection because of its sensitive nature. This includes information about your race, religion, health, sex life, sexual orientation or criminal offences. We will only collect or use this type of personal data (a) with your explicit consent or (b) if the law requires us to do so.
The Travel Advisor and/or Supplier may choose to input, collect or use some or all of the following types of the data from their Guests when using our Service:
| Category of data | Types of data collected |
|---|---|
| Identity and contact data | When you register for our Service on behalf of your organisation, you may be required to provide us with your:
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| Payment Data | We may automatically collect the following types of information when you use our Services:
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| Special requirements Data |
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We collect your personal data in different ways, depending on whether you are Travel Advisor, Supplier or Guest, including:
We will collect your personal data directly from the Website or Platform when you choose to register an account with us.
When you provide us with personal data about your Guests, you must ensure that you are authorised to disclose that information to Onee and Onee may collect, use and share such data for the purposes described in this Privacy Policy.
When you interact with the Website or Platform we may automatically collect technical data about your mobile device, browsing actions and patterns. We collect this personal data using cookies and other similar tracking technologies. We may also receive technical data about you if you visit other websites through the Website or Platform using our cookies. For more information about cookies, please see our cookie policy at: here
Travel Advisors and/or Suppliers registered for our Services, may input, use and share personal data about Guests for the purpose of making a reservation at a property.
Any Guest personal data processed and used in connection with our Services, will be done so in accordance with the relevant Travel Advisor’s and/or Supplier’s privacy policy.
We collect your personal data so that we can provide you with our Services, whether as a Travel Advisor or Supplier. We will only use your personal data where we have a valid lawful basis to do so. We have included a table below which lists all the ways in which we use your personal data and the lawful bases we rely on to do so.
Where we mention “legitimate interests”, this is the lawful basis we rely on when we feel that it is necessary to use your personal data for a reason which is in our and/or your interests and which does not unfairly affect your rights over your personal data.
| What we use your personal data for | What personal data we use | The lawful basis that we rely on to use your personal data |
|---|---|---|
To provide our Services to you, including registering your account on the Platform |
| Performing our contract with you. |
To send you information about our Services which you have requested by contacting us |
| To take necessary steps at your request prior to entering into a contract with you. |
To provide our customer service to you:
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To share your information with Travel Advisors/Suppliers to facilitate the communication between both sets of users |
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To use data analytics to improve our Website, Platform, products and services, marketing, user and customer relationships and experiences |
| Our legitimate interests of understanding you better to provide a better service to you for your benefit. |
To monitor operations, user activity and networks for fraud prevention and crime detection. |
| If you are a Travel Advisor, to send you marketing communications if you would like to receive them. |
If you are a Travel Advisor, to send you marketing communications if you would like to receive them. We will only send you marketing communications about Onee products/services that we consider may be of interest to you. |
| Your express consent (where legally required to do so). If you are:
we will assume you are happy to receive relevant marketing communications unless you have previously opted out of such communications. This is based on our legitimate interests in promoting our business and to provide you with offers for relevant products/services. |
If you change your mind about this, you can withdraw your consent at any time by clicking on the “unsubscribe” link at the bottom of each email or by emailing info@onee.com.
If you choose to withdraw your consent to receiving these marketing emails, we will still be able to send you service emails that are necessary for our relationship with you.
To share your information with our third-party service providers which facilitate the provision of our Services and the fulfilment of essential service functions, such as web hosting, cloud storage, analytics, marketing, accounting, security tools. |
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To share data with another organisation in the context of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business. |
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We are required to comply with certain legal and regulatory requirements and may process your personal data for compliance with such legal or regulatory obligation, to which we or regulators or law enforcement agencies are subject. To establish, exercise or defend legal claims. |
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| What we use your personal data for | What personal data we use | The lawful basis that we rely on to use your personal data |
|---|---|---|
To provide our Services to Travel Advisors and Suppliersthat have registered an account with us, including:
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| Not applicable. We only use your personal data on behalf of our registered Travel Advisor and Supplier customers and in accordance with their instructions. |
We may aggregate Guest personal data from confirmed bookings for our internal reporting purposes. | Aggregated data - this is not personal data as this data will not directly or indirectly reveal your identity | Not applicable as no personal data is processed. |
We will only use your personal data for the reasons we have set out above. If we need to use your personal data for any other reason, we will let you know and tell you the reason along with the relevant lawful basis, unless the law prevents us from doing so.
We may share your personal data with other organisations so we can provide our Service to you and comply with our legal duties. We have set out below who these organisations are and the reasons for sharing your personal data with such organisations.
.Travel Advisors and Suppliers
.Our service providers - who help us operate and improve our services by assisting with various tasks including:
.Third party purchaser - who help us operate and improve our services by - 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.
We will not transfer or store your personal data outside of the European Economic Area (EEA) (or the UK to the extent the UK is no longer part of the EU), except to selected third parties that we have instructed to help us provide the services to you.
If we do transfer or store your personal data outside of the EEA, we will ensure we have put adequate measures in place in order to protect your personal data to an equivalent data protection standard as in the UK and the EEA.
We will only share your personal data with countries and organisations that:
If there are any other circumstances which would require us to transfer your personal data outside of the EEA (or the UK to the extent the UK is no longer part of the EU), we will seek your consent to transfer your personal data outside of the EEA.
You can ask us for more information about where we may transfer or store your personal data and how we will take steps to ensure your personal data is protected by using the contact details in section 3 of this policy.
We will ensure we put security measures in place to protect your personal data from being destroyed, lost or shared with somebody that should not see it. However, we cannot guarantee your personal data will be free from every security risk that may be possible when your information is sent to and from the Website or Platform.
The Website or Platform may include links to third-party websites which may collect your personal data. We have no control over what these websites do with your personal data. Please check the policies on these websites which will tell you what they do with your personal data.
We use cookies or other similar technologies to capture certain data when you interact with the Website or Platform. For further information on our use of cookies, please see our cookie policy at here
Generally, we will keep your personal data for as long as you are a registered for our Services and have an account with us.
After this, we may keep your personal data for up to 6 years (or longer where the law requires). This is so we can:
We will only keep Guest personal data on the Platform for up to 6 years (or longer where the law requires) for the purposes of complying with our legal and regulatory obligations.
In certain circumstances, we may anonymise your personal data (so that it will no longer identify you) for research, analytical or statistical purposes, in which case we may use this information indefinitely without further notice to you.
If you want further information on how long we keep your personal data, please contact us using the details set out in section 3 of this policy.
As a result of us collecting and processing your personal data, Travel Advisors and Suppliers may have the following legal rights:
If you want to exercise any of the rights listed above at any time, please contact us using the details in section 3 of this policy.
You also have the right to make a complaint about how we have used your personal data to:
If you’re still not happy with how we have dealt with your complaint, you can contact:
We may need to change this Privacy Policy as our Service develops and offers you more exciting features or if the law changes. We will let you know if any important changes are made, otherwise, we will always display the latest version of our policy on our Website or Platform.
Last updated: June 2020