KAMSAN INVESTMENTS – PRIVACY & DATA POLICY

1. WHO WE ARE Kamsan Investments is responsible for the personal information we collect and use in connection with direct bookings and stays with us. For privacy or data protection enquiries, please contact: Kamsan Investments Email: info@kamsaninvestments.com

2. INFORMATION WE MAY COLLECT When you visit our website, contact us, make a booking or stay at one of our properties, we may collect information including: • Your name, email address, telephone number and other contact details. • Booking information, including property, stay dates, number of guests and booking value. • Information about additional guests where reasonably required. • Information supplied through our online check-in process, including information reasonably required to verify or administer a booking. • Communications between you and Kamsan Investments. • Payment and transaction information. Card payments may be processed by third-party payment providers and Kamsan Investments does not necessarily receive or store complete card details. • Information relating to damage, incidents, complaints, rule breaches or disputes. • Technical information generated when our website is used, which may include IP address, browser/device information, access times and website usage information. • Images, video and associated information captured by disclosed exterior security devices, such as Ring video doorbells, where fitted. We aim to collect only information reasonably necessary for the purposes described in this policy.

3. WHY WE USE YOUR INFORMATION We may use personal information to: • Process, administer and confirm bookings. • Take and verify payments and administer refunds. • Communicate with guests before, during and after a stay. • Complete online check-in and provide property access information. • Verify booking information where reasonably necessary for security or fraud prevention. • Manage the safety and security of our properties, guests and neighbours. • Prevent, identify and investigate suspected fraud, unauthorised occupancy, property damage, security incidents and serious breaches of our Terms & Conditions or House Rules. • Establish, exercise or defend legal claims and resolve payment disputes or chargebacks. • Maintain appropriate booking, financial and accounting records. • Comply with legal, regulatory, tax or law-enforcement requirements. • Maintain, secure and improve our website and services.

4. OUR LEGAL BASES FOR PROCESSING Depending on the circumstances, we process personal information because: • It is necessary to enter into or perform our contract with you, including administering your booking and stay. • It is necessary for us to comply with a legal obligation. • It is necessary for our legitimate interests, including operating and protecting our accommodation business, maintaining property and guest security, preventing fraud, enforcing booking terms, resolving disputes and protecting legal rights, provided those interests are not overridden by your rights. • You have provided consent where consent is required. Where processing is based on consent, you may withdraw that consent for future processing at any time.

5. ONLINE CHECK-IN & IDENTITY INFORMATION We may request information reasonably necessary to administer, secure or verify a booking through our online check-in process. Information collected for check-in will be used only for appropriate purposes such as booking administration, access management, security, fraud prevention and compliance with applicable requirements. We will not retain identity information for longer than reasonably necessary unless continued retention is required or permitted by law or is reasonably necessary in connection with a dispute, security incident or legal claim.

6. PAYMENTS Payments may be processed using third-party payment providers. Payment providers may collect and process payment-card, authentication, fraud-prevention and transaction information in accordance with their own privacy policies. Kamsan Investments may receive information such as payment status, amount, transaction reference, payment method and information necessary to administer a booking or investigate a disputed transaction, but does not necessarily receive or store full payment-card details.

7. SECURITY CAMERAS Some Kamsan Investments properties use disclosed exterior security devices, including Ring video doorbells positioned at property entrances. These devices may capture video, images and, where enabled and lawful, audio in the area covered by the device. They are used for legitimate security purposes, including protecting guests and property, managing access, investigating security incidents and suspected serious breaches of our booking terms, and establishing, exercising or defending legal claims where necessary. Kamsan Investments does not install security cameras inside the private accommodation. Security footage will only be accessed, used or disclosed where reasonably necessary and will not be retained for longer than necessary for the purpose for which it was collected, subject to any longer period reasonably required for an incident, dispute, insurance matter or legal claim.

8. WHO WE MAY SHARE INFORMATION WITH We do not sell guests' personal information. Where reasonably necessary, information may be shared with service providers and other recipients involved in operating our accommodation business, including: • Smoobu and other booking/property-management technology providers. • Payment processors and financial institutions. • Online check-in, identity verification or guest-management providers used by us. • IT, website, communications and security providers. • Cleaners, maintenance providers or property personnel, but only where information is reasonably necessary for them to perform their role. • Professional advisers, insurers, payment-dispute providers and legal representatives where necessary. • Police, courts, regulators, local authorities or other competent authorities where required or permitted by law. Service providers may process personal information on our behalf or, in some circumstances, as separate data controllers.• Authorised contractors, operational partners and service providers who assist us with property management, cleaning coordination, booking administration or other accommodation-related services, but only where access to information is reasonably necessary for those purposes.

9. INTERNATIONAL DATA TRANSFERS Some technology or service providers may process personal information outside the United Kingdom. Where UK data-protection law requires safeguards for an international transfer, we will rely on an appropriate lawful transfer mechanism or other protection recognised under applicable data-protection law.

10. HOW LONG WE KEEP INFORMATION We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, including booking administration, accounting and tax obligations, fraud and security prevention, resolving disputes and establishing or defending legal claims. Different categories of information may therefore be retained for different periods. Where information is no longer reasonably required and there is no legal reason for continued retention, it will be deleted or securely disposed of in accordance with our data-retention practices.

11. YOUR DATA-PROTECTION RIGHTS Depending on the circumstances and applicable law, you may have rights including: • The right to request access to personal information we hold about you. • The right to request correction of inaccurate information. • The right to request deletion of information in certain circumstances. • The right to request restriction of processing in certain circumstances. • The right to object to certain processing. • The right to data portability where applicable. • The right to withdraw consent where processing relies upon consent. These rights are not absolute and may be subject to lawful exemptions. For example, we may need to retain certain information to comply with legal obligations or establish, exercise or defend legal claims. Requests can be made to info@kamsaninvestments.com. RIGHT TO OBJECT: Where we process your personal information on the basis of legitimate interests, you have the right to object to that processing. We will consider any objection in accordance with applicable data-protection law.

12. SECURITY OF INFORMATION We take reasonable organisational and technical measures to protect personal information against unauthorised access, alteration, disclosure, loss or misuse. However, no method of transmitting or storing information electronically can be guaranteed to be completely secure.

13. COOKIES & WEBSITE TECHNOLOGY Our website and the services used to operate it may use cookies or similar technologies that are necessary for website functionality, booking functionality, security or other purposes. Where consent is legally required for non-essential cookies or similar technologies, they should only be used in accordance with the applicable consent requirements. Further information may be provided through the website's cookie controls or cookie notice where applicable.

14. THIRD-PARTY SERVICES Our website and booking process may use or link to services operated by third parties. Those organisations may process information under their own privacy policies where they act as independent data controllers.

15. DISCLOSURE FOR SECURITY, DISPUTES & LEGAL CLAIMS Where lawful and reasonably necessary, relevant booking information, communications, transaction records, photographs, security footage, access information and incident records may be preserved and used to investigate suspected fraud, property damage, unauthorised occupancy, serious House Rule breaches, payment disputes or other incidents, or to establish, exercise or defend legal claims. This does not permit Kamsan Investments to collect or use information unlawfully or disproportionately.

16. COMPLAINTS If you have concerns about how we use your personal information, please contact us first at info@kamsaninvestments.com so that we can investigate. 

17. CHANGES TO THIS POLICY We may update this Privacy & Data Policy from time to time to reflect changes to our services, technology or legal requirements. The current version published on our website will apply from its stated effective date.