Privacy Policy
HAS Property Solutions Ltd
Our website address is: http://www.20AKirkibost.com.
| Data Controller | HAS Property Solutions Ltd |
| Registered Address | 27 Old Gloucester Street, London, WC1N 3AX |
| Company Number | 14295588 |
| ICO Registration | ZB393505 |
| Data Protection Contact | hello@hasproperty.co.uk |
| Website | www.20akirkibost.com |
| Policy Version | 2.0 |
| Effective Date | February 2026 |
| Review Date | February 2027 |
Introduction
2. What Personal Data We Collect
- Full name
- Home address
- Email address and telephone number
- Booking dates, party size, and special requirements
- Payment reference information (we do not store card details — see Section 7)
Enquiry and Contact Data
- Name and contact details provided when you submit an enquiry via our website contact form, by email, or by telephone
- The content of your correspondence with us
Website Usage Data
- IP address, browser type, device type, and pages visited, collected via Google Analytics
- Cookie identifiers (see Section 9)
Marketing Data
- Email address if you have consented to receive marketing communications from us
Guest Review Data
- Your name (or a pseudonym of your choosing), comments about your stay, and any photographs you voluntarily provide
3. How and Why We Use Your Data
UK GDPR requires us to have a lawful basis for each processing activity. The table below sets out our processing purposes, the data involved, the lawful basis we rely on, and how long we retain the data.
| Processing Purpose | Data Categories | Lawful Basis (UK GDPR Art. 6) | Retention Period |
| Processing and managing your booking | Booking & guest data | Art. 6(1)(b) — Performance of a contract | 6 years from checkout (HMRC compliance) |
| Responding to enquiries | Enquiry & contact data | Art. 6(1)(f) — Legitimate interests (responding to pre-contractual requests) | 1 year from enquiry date if no booking results |
| Sharing limited data with our housekeeping team | Guest name, arrival/departure dates only | Art. 6(1)(b) — Performance of a contract; Art. 6(1)(f) — Legitimate interests (property management) | Deleted by housekeepers following each stay |
| Sending you marketing communications (newsletter or offers) | Name, email address | Art. 6(1)(a) — Consent | Until you withdraw consent, then deleted within 30 days |
| Using your guest review for promotional purposes | Review content, name or pseudonym, photographs (non-identifying) | Art. 6(1)(a) — Consent; or Art. 6(1)(f) — Legitimate interests where review was submitted publicly | For the duration of active use; deleted on request |
| Website analytics (Google Analytics) | IP address, browsing behaviour, device data | Art. 6(1)(a) — Consent (analytics cookies only placed after consent) | 26 months (Google Analytics default, adjusted in account settings) |
| Social media engagement (Meta/Facebook Pixel) | Browsing behaviour, pixel data | Art. 6(1)(a) — Consent (marketing cookies only placed after consent) | 90 days (Meta default retention) |
| Fraud prevention and legal compliance | All relevant data | Art. 6(1)(c) — Legal obligation; Art. 6(1)(f) — Legitimate interests | As required by law |
Note on legitimate interests: Where we rely on legitimate interests as our lawful basis, we have conducted a Legitimate Interests Assessment (LIA) to ensure our interests are not overridden by your rights and freedoms. You may request a copy of any relevant LIA by contacting us at hello@hasproperty.co.uk.
4. Who We Share Your Data With
We do not sell your personal data. We share your data only as necessary and only with the following parties:
Third-Party Data Processors
We use the following third-party service providers who process data on our behalf. Each is subject to a Data Processing Agreement (DPA) with us, as required by Article 28 UK GDPR:
| Processor | Purpose | Location | Transfer Safeguard |
| Lodgify | Booking management system | EU / EEA | UK Adequacy Regulations |
| Stripe | Online payment processing | USA / EU | UK IDTA / Standard Contractual Clauses |
| Google Analytics (Google LLC) | Website analytics and visitor behaviour | USA | UK IDTA / Standard Contractual Clauses |
| Meta Platforms (Facebook Pixel) | Social media advertising and retargeting | USA / EEA | UK IDTA / Standard Contractual Clauses |
Housekeeping Team
We share limited booking data (guest name and arrival/departure dates only) with our housekeeping contractors solely to enable property preparation. Our housekeeping contractors are bound by confidentiality obligations and are required to delete this information following each stay. They are not authorised to use this data for any other purpose.
Review Platforms
If you submit a review via a third-party platform such as Airbnb or Google, that platform’s own privacy policy governs the processing of your data. We may reference or display such reviews on our own website with appropriate attribution.
Legal Disclosure
We may disclose personal data to law enforcement, regulatory authorities, or other third parties where we are required to do so by law or in order to protect our legal rights.
No Sale of Data
We will never sell, rent, or trade your personal data to any third party for their own marketing purposes.
5. International Data Transfers
Some of our third-party processors operate outside the United Kingdom, in particular in the United States of America and the European Economic Area (EEA). Where personal data is transferred outside the UK, we ensure appropriate safeguards are in place as follows:
- Transfers to EEA countries: protected by the UK’s adequacy regulations, which recognise EEA countries as providing an equivalent level of data protection.
- Transfers to the USA and other third countries: protected by the UK International Data Transfer Agreement (IDTA) or Standard Contractual Clauses (SCCs) approved for use under UK law, supplemented where necessary by additional technical safeguards.
You can obtain further information about the safeguards in place for international transfers by contacting us at hello@hasproperty.co.uk.
6. How Long We Keep Your Data
We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by law. Our retention periods are as follows:
- Booking and financial records: 6 years from the date of checkout, in line with HMRC requirements.
- General guest contact data: 2 years from the date of your most recent stay.
- Enquiries that did not result in a booking: 1 year from the date of enquiry.
- Marketing data (where consent given): retained until you withdraw your consent, after which it will be deleted within 30 days.
- Website analytics data: 26 months (standard Google Analytics retention period).
- Guest reviews used for promotional purposes: retained for the duration of active use and deleted upon request.
At the end of each applicable retention period, data is securely deleted or anonymised. You may request early deletion of your data in accordance with your rights under Section 8.
7. Payment Processing
Bank transfer payments can be arranged directly with us. In such cases, only your bank account name and transaction reference are visible to us in our bank records, and these are retained as part of our financial records for 6 years in accordance with HMRC requirements.
8. Your Data Protection Rights
Under UK GDPR, you have the following rights in relation to your personal data. We will respond to all valid requests within one calendar month of receipt. There is no charge for exercising your rights, except in cases of manifestly unfounded or excessive requests.
Right of Access (Subject Access Request)
You have the right to request a copy of the personal data we hold about you, along with information about how and why we process it.
Right to Rectification
You have the right to ask us to correct any inaccurate or incomplete personal data we hold about you.
Right to Erasure (‘Right to be Forgotten’)
You have the right to request that we delete your personal data in certain circumstances, for example where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent on which processing was based. Note that we may be required to retain certain data to comply with legal obligations (for example, financial records under HMRC rules).
Right to Restrict Processing
You have the right to ask us to temporarily stop processing your personal data in certain circumstances, for example while the accuracy of data is being contested.
Right to Data Portability
Where processing is based on your consent or on a contract, and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to have it transmitted to another controller where technically feasible.
Right to Object
You have the right to object to processing based on our legitimate interests. You also have an absolute right to object to your personal data being used for direct marketing purposes at any time.
Rights in Relation to Automated Decision-Making
We do not carry out any automated decision-making or profiling that produces legal or similarly significant effects on you.
Right to Withdraw Consent
Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out before withdrawal.
To exercise any of your rights, please contact us in writing at hello@hasproperty.co.uk. We may need to verify your identity before processing your request.
9. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies. Cookies are small text files placed on your device when you visit our website. We use cookie management software (Complianz) to ensure that non-essential cookies are only placed on your device after you have given your explicit consent.
Types of Cookies We Use
- Functional / Strictly Necessary: Essential for the website to operate correctly. These are always active and do not require your consent.
- Preference Cookies: Remember your settings and preferences to improve your experience.
- Analytics Cookies (Google Analytics): Used to understand how visitors interact with our website. These are only set after you consent. Data collected is anonymised where possible and does not identify you personally.
- Marketing Cookies (Meta/Facebook Pixel): Used to deliver relevant advertising on social media platforms and to measure the effectiveness of our marketing. These are only set after you consent.
Managing Cookies
When you first visit our website, you will be presented with a cookie banner that allows you to accept or decline non-essential cookies. You can change your cookie preferences at any time by clicking the ‘Manage Consent’ link on our website. You may also control cookies through your browser settings, though this may affect the functionality of the website.
For more information about cookies and how to manage them, visit www.aboutcookies.org or www.allaboutcookies.org.
10. Guest Reviews
We collect guest reviews from a variety of sources, including direct submissions to us by email or through our website, via our Lodgify booking platform, and via third-party platforms such as Airbnb and Google Reviews.
How We Use Reviews
- To improve the quality of our accommodation and services.
- For promotional purposes, including display on our website, social media channels, and in marketing materials. Where we use a review for promotional purposes, we will use your first name only, a pseudonym, or anonymise the review entirely, unless you have given us explicit consent to use your full name.
Photographs
We will not use any photograph in which an individual can be identified for promotional purposes without your explicit consent. We assess each photograph individually before use.
Your Control Over Reviews
If you do not wish your review to be used for promotional purposes, or if you wish to withdraw consent for its continued use, please contact us in writing at hello@hasproperty.co.uk. We will action your request promptly.
11. Marketing Communications
We will only send you direct marketing communications if you have given us your explicit consent to do so. We will always make it easy for you to opt out.
To unsubscribe from any marketing communications, you can use the unsubscribe link included in every marketing email, or contact us directly at hello@hasproperty.co.uk. We will process your request within 10 working days.
We do not share your marketing preferences or contact details with third parties for their own marketing purposes.
12. Our Website and Social Media
Website Security
Our website is operated using industry-standard security measures. While we take all reasonable steps to protect information submitted through our website, please be aware that no method of electronic transmission or storage is 100% secure. We encourage you to take care when sharing personal information online.
Links to Third-Party Websites
Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites, and we encourage you to review their privacy policies independently.
Social Media
We maintain an active presence on Facebook and Instagram. When you interact with us on social media, your activity is also subject to the privacy policies of those platforms. We will never ask you to share sensitive personal information through social media channels. If you have a matter requiring confidential discussion, please contact us by email or telephone.
Our website includes social sharing buttons. If you use these to share content, the relevant social media platform may collect data about you. Please refer to each platform’s privacy policy for details.
13. Security of Your Personal Data
We take the security of your personal data seriously and have implemented appropriate technical and organisational measures to protect it against unauthorised access, loss, destruction, or alteration. These include:
- Restricting access to personal data to those who have a genuine business need to access it.
- Using password management and two-factor authentication on all systems that hold personal data.
- Ensuring that third-party processors provide sufficient guarantees about their security arrangements before we share data with them.
- Maintaining a data breach response procedure to enable us to detect, investigate, and report personal data breaches without undue delay.
In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours and, where required, inform you directly without undue delay.
14. Children’s Data
Our services are not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If you believe we have inadvertently collected such data, please contact us immediately at hello@hasproperty.co.uk and we will delete it promptly.
15. Your Right to Complain to the ICO
We take our data protection obligations seriously and encourage you to contact us in the first instance if you have any concerns about how we handle your personal data. However, you have the right at any time to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection matters.
| ICO Website | www.ico.org.uk |
| ICO Helpline | 0303 123 1113 |
| ICO Address | Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF |
| ICO Online Report | ico.org.uk/make-a-complaint |
16. Changes to This Privacy Policy
We encourage you to review this policy periodically. Previous versions are available upon request by contacting hello@hasproperty.co.uk.
17. Contact Us
If you have any questions about this Privacy Policy, wish to exercise your data protection rights, or have a concern about how we handle your personal data, please contact us:
| Data Protection Contact | HAS Property Solutions Ltd |
| hello@hasproperty.co.uk | |
| Address | 27 Old Gloucester Street, London, WC1N 3AX |
| STR Licence No. | ES01218F |
This policy is effective from February 2026 and replaces all previous versions.
© HAS Property Solutions Limited | Company No. 14295588 | ICO Registration: ZB393505