What we hold, and why

01The short version

We collect the two contact details you type into a trip plan, and the plan itself. We use them to reply to you, and we never add you to a mailing list.

Visits are counted twice, by Vercel and by PostHog, in a way that writes nothing to your device and cannot follow you from one visit to the next. A small card asks about the two things that would go further, remembering you between visits and measuring our advertising with Meta, and both stay off unless you turn them on.

The enquiry form asks one question of its own: whether we may let Meta know you enquired, to help us see which of our ads resonate best. If you tick it, your email address goes to Meta only in a coded form that cannot be read back, and it never goes at all unless you do.

Nothing leaves until you say so in writing. Once you have, your details go to the villa and to the people delivering your week, and no further. The villa is contracted and invoiced by whoever manages it. Whichever of the four services we provide at that villa, we invoice you for directly, so those billing details are held by us.

Whichever half of the week you are asking about, you write to us and Lisa answers. You are never handed to a queue, and we remain your contact once a villa has your booking.

02Who we are

Padel Hideaways is run by Lisa, who is the named contact on every page of this site and the person who reads your enquiry. For data protection purposes the controller is Emberpath LTD, trading as Padel Hideaways.

The registered company, its number and its registered address are on the terms page under Who you are dealing with, which is where the rest of what you are entitled to know before dealing with anyone online is written down.

Write to lisa@padelhideaways.com about anything on this page and it reaches Lisa directly.

03Cookies, and the two you choose

Nothing is set on your device until you say so. Two seconds into your first page a small card asks, with Allow all, Essential only and Let me choose, and the two choices it offers are described below. Essential only, or not answering at all, leaves the site working exactly as it does for everyone, and nothing is stored.

Your answer is the one thing kept without asking, because without it the card would ask on every page. It is held in your own browser under the name ph-consent, it records the two choices and the date, it never leaves your device, and after six months the card asks again. Cookie settings, under Legal at the foot of every page, opens it again, and turning a choice off deletes what that choice had stored.

We count visits, so we know which pages people read. The first counter is Vercel Web Analytics, it is served from this domain by the company that hosts the site, and it writes nothing to your browser. It records the page, roughly which country the request came from, and which site you arrived from. There is no identifier, so two visits cannot be joined up as the same person, and nothing is tied to your name, your email or an enquiry you send.

There is a second counter, and it does two jobs the first cannot: it records which villa an enquiry was about and which of the five routes you picked, and it replays how a page was used, so we can see where a villa page loses people. It is PostHog, its code is part of this site rather than fetched from them, and unless you choose "Remember me next time" it sets nothing on your device and holds no profile of you. The replay is the page as you moved through it, the scrolling and what you pressed. Anything you type is masked inside your own browser before it is sent, so what you write into an enquiry is never in it, and a recording ends when you reload or leave rather than following you. We have it set to discard the IP address a request came from. We also count the answers people give on the card, the same way, so we can see how many say yes.

"Remember me next time" is the first choice. With it on, PostHog keeps a random identifier in a cookie of this site and in your browser's storage, both named beginning ph_, for six months, so a second visit, or a villa opened in a new tab, counts as the same browser rather than a new one, and a replay can follow you across a reload. It is still not tied to your name, your email or an enquiry. With it off, which is how it starts, the identifier lives in the page and is gone when you leave.

"How you found us" is the second. With it on, the Meta Pixel loads from Meta and sets two cookies of this site: _fbp, a random identifier for your browser, and _fbc, the click identifier Meta added to the link if you arrived from Instagram or Facebook. Meta gives both 90 days. The Pixel tells Meta which page you are on and, when you send an enquiry, share a trip plan, or tap WhatsApp, a call, email or the phone number, that you did, and for an enquiry or a shared plan, which villa it was about. With each of those it sends your screen size and time zone. It runs in your browser, so Meta also receives what any request to it carries: your IP address, the kind of browser you use, the page you came from, and, if you are signed in to Facebook or Instagram in the same browser, Meta's own cookies, which let it connect the visit to that account. It is set to send only those things: it does not read the form or what you type into it. The same moments go to Meta a second time from PostHog's servers, carrying the same reference so Meta counts each once, with the two cookie identifiers and the kind of browser but without your IP address, which PostHog discards. With it off, which is how it starts, nothing from Meta loads at all.

For what the Pixel gathers and sends, Meta Platforms Ireland and we decide together what is collected, which the law calls being joint controllers, and we answer for that part here. What Meta then does with it is Meta's, under its own privacy policy, and some of it is processed in the United States.

There is no other advertising tag and no embedded video. The typefaces are served from this domain rather than from Google, and so are both counters, so opening a page does not tell any advertiser, any social network or any font service that you did, unless you have turned on "How you found us".

The Journal has share buttons, and they are worth a sentence because they are not what they look like. Nothing is loaded from X, LinkedIn, WhatsApp or anyone else when the page opens, so those companies are not told you read it. Each button is a plain link that does nothing until you press it. Press one and it hands you to that app, which then knows what you shared, exactly as it would if you had copied the address and pasted it in yourself.

One other thing is stored in your own browser, and only if you send an enquiry: the summary shown on the confirmation page is held for the single step between pressing send and that page loading, then deleted. It never leaves your device and it is not a cookie.

The site is hosted for us, and like any web host the server keeps short lived technical logs, including the IP address a request came from. That is a security and reliability measure, not a way of recognising you, and we do not use those logs to build any picture of a visitor.

04What we collect when you write to us

Only what you put in, which is:

• Your email address, your mobile number, or both. One of the two is needed, or we cannot reply.
• The plan you built: the villa, the week you picked, which of the five you want, and the indicative figures shown alongside them.
• Anything else you choose to tell us once we are talking, by email, WhatsApp or on a call.

We do not ask for your address, your date of birth, your passport or any payment details, and nothing on this site takes a payment. Payment is requested later, by whoever is invoicing that half of the week.

The stay is contracted with the villa, so the villa asks you for what it needs and tells you how it holds it. Whichever of the Concierge, the Driver, the Chef and the Coach we provide at that villa, we invoice you for directly, so for that part we ask for a name and address to bill, and whatever an invoice or a transfer needs in that country. Which half is which is in your booking confirmation before you commit to either. How long we keep our own invoices is in section 07.

We do not knowingly collect anything about children. The site is for the person organising a trip.

05Why we are allowed to hold it

Under the UK and EU General Data Protection Regulation there has to be a lawful basis for holding anything about you. Two cover what you send us, and a third covers one thing only.

• Steps taken at your request before a contract: you asked us to price and arrange a week, and we cannot do that without a way to reach you.
• Legitimate interests: keeping a record of enquiries so that we can pick a conversation back up, and know what has been quoted to whom. We have weighed this against your privacy and keep what we hold to the minimum that makes it work.

Consent, for three things. The two choices on the cookie card, "Remember me next time" and "How you found us", each run only once you turn them on, and stop, with what they stored deleted, when you turn them off. And if you tick the box on the enquiry form, we tell Meta that an enquiry was sent, so that we can see whether the advertising we pay for reaches anyone. What goes across is a one-way scramble of your email address, made in your own browser before it is sent, and the click identifier Meta itself added to the link if you arrived from Instagram or Facebook. Your address is never sent, and Meta cannot read it back out of the scramble. Untick the box and none of this goes. "How you found us", if you turned it on, still tells Meta that an enquiry was sent, as section 03 says, but never with your email.

Nothing else on this site asks for consent. The counting that runs for everyone writes nothing to your device and holds nothing about you, and as we send no marketing, there is nothing to opt out of.

If you are in South Africa, the equivalent grounds under the Protection of Personal Information Act are performance of a contract and legitimate interest, and everything below applies to you in the same way.

06Who else sees it

Answering an enquiry properly means talking to the people who would look after you. Sending a trip plan is your permission for us to make those introductions, and we make them once your dates are confirmed, not before. Then, and only as far as the arrangement needs:

• The owners or portfolios who look after the villa you have chosen, to confirm your week. We speak to them on your behalf, and we stay involved throughout.
• The independent businesses and individuals we bring in to deliver the parts you asked for: the driver, the chef, the coach, the concierge. They differ from villa to villa, and each is told only what they need in order to do their part, which is usually names, dates and numbers, not the whole conversation.
• The companies that run our email and this website, who hold the message in the ordinary course of carrying it.
• Meta, and only as far as you said yes. With "How you found us" on: what the Pixel and its server copy carry, described in section 03. With the box on the enquiry form ticked: that an enquiry was sent, the villa it was about, and the scrambled email described above. This happens in the United States, and we rely on the safeguards the law provides for transfers of that kind. Meta is not told your name, your number, or anything you wrote to us.

Where a booking goes ahead, your details also go to the portfolio partner or the owner we book that villa through, who holds the contract for the stay and takes payment for it. They ask you directly for whatever they need and tell you how they hold it. That is the villa alone: where one of the four services is ours, nobody else invoices you for it, and the billing details it needs stay with us.

Everyone on that list is given your details to arrange your week and for nothing else, never for their own marketing, and we ask for nothing that would let anyone build a picture of you from it.

That is the whole list. We sell nothing to anyone, we never pass your name to another villa or agency, and there is no mailing list to join or leave.

Some of the villas are in South Africa, so answering an enquiry about one of them means sending your details outside the UK and the European Economic Area. Where that happens we rely on the safeguards the law provides for transfers of this kind, and we send only what the people at that end need.

07How long we keep it

An enquiry that does not turn into a trip is kept for 24 months and then deleted. Weeks are often planned a long way ahead and people come back the following year, so anything shorter would mean asking you for everything twice.

Where a trip goes ahead, we keep the record for as long as tax and accounting require, which is usually longer, and then delete it. Where we invoiced you for a service of ours, the invoice and its billing details are part of what we must keep, under the accounting rules that apply to us.

You can ask us to delete your details sooner and we will, unless we are required to keep something.

08What you can ask us to do

You have the right to:

• See what we hold about you, and receive a copy of it.
• Have anything wrong corrected.
• Have it deleted.
• Object to our holding it, or ask us to restrict how we use it.
• Receive it in a portable form, or have it sent on to someone else.

Ask at lisa@padelhideaways.com. Lisa reads it herself, it costs nothing, and we will reply within a month. We may ask a question to confirm you are who you say you are, which is there to protect you.

If you think we have got this wrong, you can complain to a supervisory authority: the Commissioner for Personal Data Protection in Cyprus, which is where the company is, your own national authority anywhere else in the EU, the Information Commissioner in the UK, or the Information Regulator in South Africa. We would be grateful to hear from you first, so we can put it right.

09Keeping it safe

The site is served over an encrypted connection and enquiries travel the same way. Access to our inbox is protected by a strong password and two-factor authentication.

No one can promise that anything sent over the internet is perfectly secure. What we can promise is that we hold very little, for a stated reason, for a stated time.

10Changes

If what we do changes, this page changes with it and the date at the top moves. If a change matters to someone whose enquiry we already hold, we will tell them directly.