Hedo villas is a trademark owned by Silvio Giannullo VAT Y3105254S, Avenida del Coral 6, 29688 Estepona, Spain.
We do care deeply about the privacy of its visitors and users and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our visitors and users regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
Capitalized terms which are not defined herein shall have the meaning ascribed to them in our terms and conditions
1. Please read carefully!
2. What information do we collect?
2.1. Visitor and User Information
We collect two types of information regarding our Visitors and Users:
1. Un-identified and non-identifiable information pertaining to a Visitor or un-identified User, which may be made available to us, or collected automatically via his/her use of the Services (“Non-personal Information”). Such Non-personal Information does not enable us to identify the Visitor or User from whom it was collected. The Non-personal Information collected by us mainly consists of technical and aggregated usage information, such as Visitors’ and Users’ browsing and ‘click-stream’ activity on the Services, session heatmaps and scrolls, non-identifying information regarding the Visitor’s or User’s device, operating system, internet browser, screen resolution, language and keyboard settings, internet service provider, referring/exit pages, date/time stamps, etc.
2. Individually identifiable information, namely information that identifies an individual or may with reasonable efforts cause the identification of an individual, or may be of private or sensitive nature (“Personal Information”). The Personal Information collected by us mainly consists of contact details (e.g., e-mail address or phone number), billing details (name, physical billing address, payment method and transaction details), which are only collected from Users with Paid Services or Users who are registered on the website, details regarding a browsing or usage session (IP address, Geo-location and/or device unique identifier), details regarding connected third party accounts (such as the e-mail or username for a connected PayPal, Stripe, Google or Facebook account), scanned identification documents provided to us (such as an ID card, driver’s license, passport or official company registration documents), correspondences (including those made through or uploaded to our Services), and any other Personal Information provided to us by Visitors and/or Users through their access to and/or use of the Services. For the avoidance of doubt, any Non-personal Information that is connected or linked to Personal Information (for example, in order to improve the Services we offer) is deemed and treated by us as Personal Information, as long as such connection or linkage exists.
2.2. Users of Users Information
We may also collect similar information pertaining to visitors and users of our User’s websites or services (“Users-of-Users”), solely for and on our Users’ behalf (as further described in Section 6 below).
3. How do we collect such information?
There are two main methods we use:
1. We collect information through your use of the Services. When you visit or use our Services, including when you browse the Website or any User Website, register a User Account, inquire for a villa or services, edit your User Website and upload information and content, and/or download and use any Hedovillas Apps and/or Mobile Apps, we are aware of it and will usually gather, collect and record such uses, sessions and related information, either independently or with the help of third-party services as detailed in Section 8 below, including through the use of “cookies” and other tracking technologies, as further detailed in Section 9 below.
2. We collect information which you provide us voluntarily. For example, we collect the Personal Information you provide us when you register to our Services; when you sign in to our Services via third party services such as Facebook or Google or Wixhotel or Wix restaurant or Wix booking or Wix store; when you submit or upload such Personal Information as you use any of our Services; and/or when you contact us directly by any communication channel (e.g., Hedo’s support tickets, inquiries form, emails).
3. We also collect information from third party sources as described in Section 8 below.
4. Why do we collect such information?
We collect such Non-personal and Personal Information for the following purposes:
1. To provide and operate the Services;
2. To offer quotes and share links about our villas and related services to upgrade your holiday.
3. To further develop, customize and improve our Services, based on Visitors’ and Users’ common or personal preferences, experiences and difficulties;
4. To provide our Users with ongoing customer assistance and technical support;
5. To be able to contact our Visitors and Users with general or personalized service-related notices and promotional messages (as further detailed in Section 10 below);
6. To facilitate, sponsor and offer certain contests, events and promotions, determine participants’ eligibility, monitor performance, contact winners and grant prizes and benefits;
7. To create aggregated statistical data and other aggregated and/or inferred Non-personal Information, which we or our business partners may use to provide and improve our respective services;
8. To enhance our data security and fraud prevention capabilities;
9. To comply with any applicable laws and regulations.
We will only use your Personal Information for the purposes set out in Section 4 where we are satisfied that:
1. our use of your Personal Information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to provide you with a villa rental or a chef service, to provide you with our customer assistance and technical support), or
2. our use of your Personal Information is necessary to comply with a relevant legal or regulatory obligation that we have (e.g. to register your check-in according to the regional rental law or to emit the invoices for your payments), or
3. our use of your Personal Information is necessary to support legitimate interests that we have as a business (for example, to maintain and improve our Services by identifying user trends and the effectiveness of Hedo villas campaigns and identifying technical issues), provided it is conducted at all times in a way that is proportionate, and that respects your privacy rights.
Our Services are not permitted to children under 18 years of age. No one under age 18 should provide any Personal Information to us through any of our Services. We do not knowingly collect Personal Information from children under 18. Parents and guardians should supervise their children's activities at all times.
5. Where do we store your information?
Hedo Visitors’, Hedo Users’ and Users-of-Users’ Personal Information may be maintained, processed and stored by Hedo on the Wix platform (Wix is one of the leading company in the world offering platform for website and booking services) for the proper delivery of our Services and/or as may be required by law (as further explained below).
Hedo.com Ltd. is based in Spain, which is considered by the European Commission to be offering an adequate level of protection for the Personal Information of EU Member State residents.
Hedo service providers that store or process your Personal Information on Hedo’s behalf are each contractually committed to keep it protected and secured, in accordance with industry standards and regardless of any lesser legal requirements which may apply in their jurisdiction.
Hedo.com is processing of Personal Information it receives and subsequent transfers to a third party acting as an agent on its behalf. Wix platform complies with the Privacy Shield Principles for all onward transfers of Personal Information from the EU, including the onward transfer liability provisions.
With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, WIX is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission (FTC). In certain situations, WIX.com may be asked to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, and will do so where permitted by local data protection laws.
Upon request Hedo will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by following the instructions provided below in the section 11.
Please note that permanently deleting your Hedo account erases all of your information from Hedo's databases. After completing this process, you can no longer use any of your Hedo Services, your User Account and all its data will be removed permanently, and Hedo will not be able to restore your account or retrieve your data in the future. If you contact Hedo Support in the future, the system will not recognize your account and Support agents will not be able to locate the deleted account.
Hedo’s data storage providers (Wix is the main provider) are contractually committed to protect and secure your data.
Among other things, Wix adheres to the EU – US & to the Swiss-US Privacy Shield Principles, for further protecting and enhancing our users’ privacy.
Data Localisation Obligations: If you reside in a jurisdiction that imposes “data localisation” or “data residency” obligations (i.e., requiring that Personal Information of its residents be kept within the territorial boundaries of such jurisdiction), and this fact comes to our attention, we may maintain your Personal Information within such territorial boundaries, if we are legally obligated to do so.
You acknowledge that while doing so, we may continue to collect, store and use your Personal Information elsewhere, including in the United States of America as explained above.
6. Users-of-users’ information
Hedo may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with Hedo, on the User’s behalf.
For such purposes, Hedo serves and shall be considered as a “Processor” and not as the “Controller” (as both such capitalized terms are defined in the European Union General Data Protection Regulation) of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorized usage of your Users-of-Users’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
Hedo cannot provide legal advice to Users or their Users-of-Users, however we do recommend that all Users publish and maintain clear and comprehensive privacy policies on their User Websites, in accordance with the applicable laws and regulations, and that all Users-of-Users carefully read those policies and make sure that they consent to them.
For more information on how Users-of-Users Information may be handled by Hedo on the Wix platform (which may be relevant for the specific notice you provide to and/or consent you obtain from your Users-of-Users), please see Sections 8, 12 and 13 below.
If you are a visitor, user or customer of any of our Users, please read the following: Hedo has no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by Hedo on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). If requested to remove any Users-of-Users’ Personal Information, we will respond to such request within thirty (30) days. Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information for the period set forth in Section 12 below.
7. Hedo jobs applications
Hedo welcomes all qualified Applicants to apply to any of the open positions published at https://www.hedovillas.com/jobs, by sending us their contact details and CV (“Applicants Information”) via the relevant Position Application Form on our Website, or through any other means provided by us.
We understand that privacy and discreetness are crucial to our Applicants, and are committed to keep Applicants Information private and use it solely for Hedo’s internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, and contacting Applicants by phone or in writing).
Please note that Hedo may retain Applicants Information submitted to it for no longer than two years after the applied position has been filled or closed. This is done so we can re-consider Applicants for other positions and opportunities at Hedo; so we can use their Applicants Information as reference for future applications submitted by them; and if the Applicant is hired, for additional employment and business purposes related to his/her work at Hedo.
If you previously submitted your Applicants Information to Hedo, and now wish to access it, update it or have it deleted from Hedo’s systems, please contact us at firstname.lastname@example.org.
8. Sharing personal information with third parties
Hedo may share your Personal Information with third parties (or otherwise allow them access to it) only in the following manners and instances:
8.1. Third Party Services:
Hedo has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, domain name registrars, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session recording and remote access services, performance measurement, data optimization and marketing services, content providers, and our legal and financial advisors (collectively, “Third Party Service(s)”).
Such Third Party Services may receive or otherwise have access to our Visitors’ and Users’ Personal Information and/or Users-of-Users’ Personal Information, in its entirety or in part – depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes.
Note that while our Services may contain links to other websites or services, we are not responsible for such websites’ or services’ privacy practices. We encourage you to be aware when you leave our Services and read the privacy statements of each and every website and service you visit before providing your Personal Information. ]
8.2. Law Enforcement, Legal Requests and Duties:
Where permitted by local data protection laws, Hedo may disclose or otherwise allow others access to your Personal Information pursuant to a legal request, such as a subpoena, legal proceedings, search warrant or court order, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
8.3. Protecting Rights and Safety:
Hedo may share your Personal Information with others if we believe in good faith that this will help protect the rights, property or personal safety of Hedo, any of our Users, any Users-of-Users, or any member of the general public, with or without notice to you.
8.4. Social Media Features and Framed Pages:
Our Services include certain Social Media features and widgets, single sign on features, such as the “Facebook Connect” or “Google Sign-in”, the “Facebook Like” button, the “Share this” button or other interactive mini-programs (“Social Media Features”).These Social Media Features may collect information such as your IP address or which page you are visiting on our Website, and may set a cookie to enable them to function properly. Social Media Features are either hosted by a third party or hosted directly on our Services. Your interactions with these third parties’ Social Media Features are governed by their policies and not ours.
In addition, our Services may enable you to share your Personal Information with third parties directly, such as via page framing techniques to serve content to or from Third Party Services or other parties, while preserving the look and feel of our Website and Services (“Frames”). Please be aware that if you choose to interact or share any Personal Information via such Frames, you are in fact providing it to these third parties and not to us, and such interactions and sharing too are governed by such third parties’ policies and not ours.
8.5. App Market Developers:
As part of oWIX App Market program, WIX allows third party developers (“Third Party Developer(s)”) to develop and offer their own applications via the WIX App Market (“Third Party App(s)”), in conjunction with WIX. Hedo villas uses these third party providers’ App on its website.
Each Third Party Developer is bound by the WIX App Market – Partner Program Agreement, which among others, contains restrictions on how they may access, store and use the Non-personal and Personal Information you and/or your Users-of-Users provide them or us. Hedo does not control and is not responsible for the actions or policies of any Third Party Developers and Hedo has no access or knowledge to verify the Wix platform or any of the Third Party App. We can only report that they guarantee that the privacy law is respected and that Hedo has chosen world leader suppliers to reduce the risk to the very minimum level.
8.6. WIXHive API:
In order to further protect your and your Users-of-Users’ privacy, WIX contractually prohibits all Third Party Developers from combining Personal Information collected across different User Websites and Services, and from sharing Users-of-Users’ Personal Information other than with other Apps installed on the same User Website or Services, for the purposes of such specific User Website or Services.
Hedo, together with its marketing, analytics and technology partners, uses certain monitoring and tracking technologies (such as cookies, beacons, pixels, tags and scripts). These technologies are used in order to maintain, provide and improve our Services on an ongoing basis, and in order to provide our Visitors, our Users and their Users-of-Users with a better experience. For example, thanks to these technologies, we are able to maintain and keep track of our Visitor’s and Users’ preferences and authenticated sessions, to better secure our Services, to identify technical issues, user trends and effectiveness of campaigns, and to monitor and improve the overall performance of our Services.
Cookies: In order for some of these technologies to work properly, a small data file (“cookie”) must be downloaded and stored on your device. By default, we use several persistent cookies for purposes of session and user authentication, security, keeping the User’s preferences (e.g., regarding default language and settings), connection stability (e.g., for uploading media, using e-Commerce features, etc.), monitoring performance of our services and marketing campaigns, and generally providing and improving our Services.
If you want to delete or block any cookies, please refer to the help and support area on your internet browser for instructions on how to locate the file or directory that stores cookies. Information on deleting or controlling cookies is also available at www.aboutcookie.org (note that this website is not provided by Hedo, and we therefore cannot ensure its accuracy, completeness or availability). Please note that deleting our cookies or disabling future cookies or tracking technologies may prevent you from accessing certain areas or features of our Services, or may otherwise adversely affect your user experience.
Clear Gifs: We and certain Third Party Services may employ a software technology called “clear gifs” (a.k.a. Web Beacons/Web Bugs), which enables them and us to improve our Services by measuring their effectiveness and performance. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, however are not stored on your device, but instead embedded within our Services.
Flash and HTML5: We and certain Third Party Services may also employ certain tracking technologies known as “Flash cookies” and “HTML5”, mainly for advertising purposes. Various browsers may offer their own management tools for removing or blocking such technologies. Additional information about managing Flash cookies is available here.
(Please note that this website is not provided by Hedo, and we therefore cannot ensure its accuracy, completeness or availability).
Behavioral Targeting/Re-Targeting: Certain Third Party Services and ad networks may display advertising on our Website, on Hedo Apps and on Hedo mobile apps, or manage our advertising on other websites. Such parties may use certain tracking technologies to collect certain information about your activities on the Services and different third party Services to provide you with targeted advertising based on your interests and preferences. You may opt-out of receiving targeted ads from certain advertisers and ad networks by clicking here (or if you are located in the European Union click here (provided by YourChoicesOnline.eu). Please note this does not opt you out of receiving all advertising and that your opt-out will only be in relation to the specific advertising. You will continue to receive advertising for which you have not opted out.
User Data Supplementation: We may receive information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you. This helps us to update, expand and analyse our records, identify new customers, and provide products and Services that may be of interest to you. Where we obtain your Personal Information from these third parties, we ensure that such parties are contractually committed to inform you that your Personal Information will be disclosed to us and we take steps to ensure the accuracy of your Personal Information before using it. If you provide us personal information about others, or if others give us your information, we will only use that information for the specific reason for which it was provided to us.
“Do Not Track” Signals: Please note that we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application.
We do use the following cookies and tracking tools.