This policy is a working draft. The bracketed placeholders must be completed, and it should be reviewed by a solicitor before you rely on it — particularly the sections on international transfers and affiliate tracking.
Swiss City Breaks (“we”, “us”) publishes travel guides to Switzerland at swisscitybreaks.co.uk. This policy explains what we do with personal data, and applies to visitors to this website.
For the purposes of UK data protection law we are the data controller for the processing described here. Our details are:
- Business name: [LEGAL ENTITY NAME]
- Address: [REGISTERED ADDRESS]
- Contact: [PRIVACY CONTACT EMAIL]
- ICO registration number: [ICO NUMBER — most UK sites using analytics or marketing cookies must register with the ICO; the fee is currently £52 a year for small organisations]
The short version
We do not sell your data. We do not take bookings or payments on this site — when you book, you do it on a partner’s website under their own privacy policy. We earn commission when you book through our links, and that tracking relies on cookies which we only set with your consent.
The personal data we handle
Information you give us
- Your name and email address, if you contact us or subscribe to updates.
- The content of any message you send us.
Information collected automatically
- Your IP address, browser type, device type, referring page and the pages you view. This is standard server log data, kept for security and troubleshooting.
- Cookie and similar identifiers, described in the cookies section below.
Information we receive from partners
- Affiliate networks and merchants report transactions to us. This is normally aggregated or pseudonymised — a transaction reference, a commission amount, the merchant and the date. We do not receive your name, address or payment details from a booking you make on a partner’s site.
Affiliate links and how the tracking works
Many links on this site are affiliate links, including links served through Awin and links to accommodation and travel partners such as Booking.com and Expedia.
When you click one of these links:
- The affiliate network or merchant sets a cookie in your browser, or records a click identifier, so that any booking you go on to make can be attributed to us.
- That party is acting as an independent data controller for what it does with that information. Its own privacy policy governs it, not ours.
- We receive a commission report. We do not see your booking, your payment details, or who you are.
If you would rather not be tracked this way, decline non-essential cookies in our cookie banner, or use your browser’s tracking protection. You can still use every part of this site.
Product data we import from partners
We import listing information — property names, descriptions, images, prices and booking links — from affiliate product feeds and partner APIs. That is information about businesses, not about you, and importing it does not involve your personal data.
When you use a search or availability feature that queries a partner in real time, the search terms you enter (such as a destination and dates) are sent to that partner in order to return results. Depending on how that request is made, your IP address may also be visible to them.
Cookies and similar technologies
Under the Privacy and Electronic Communications Regulations we may only set non-essential cookies with your consent. We use three categories:
- Strictly necessary — these keep the site working and remember your cookie choice. They do not need consent.
- Analytics — these tell us which pages are read and how people arrive. Set only with your consent.
- Affiliate and performance — these attribute a booking to us so we are paid commission. Set only with your consent, and typically set by the affiliate network rather than by us.
You can change or withdraw your choice at any time via the cookie settings link in the footer, or by clearing cookies in your browser.
Our legal bases for using your data
- Consent — for analytics and affiliate cookies, and for marketing emails. You may withdraw consent at any time.
- Legitimate interests — for keeping the site secure, preventing fraud and abuse, understanding aggregate usage, and receiving commission reports. We have considered your rights and do not believe this processing is intrusive.
- Legal obligation — for keeping accounting and tax records.
Who we share data with
- Our hosting provider, which stores server logs on our behalf.
- Our analytics provider, if you have consented to analytics.
- Affiliate networks and merchants, in the sense described above.
- Professional advisers and authorities, where the law requires it.
We do not sell personal data, and we do not share it for third-party advertising.
Sending data outside the UK
Some of our partners are based outside the UK, including in the United States. Where personal data is transferred outside the UK, we rely on one of the safeguards permitted by UK GDPR — usually the UK International Data Transfer Agreement, or the UK Addendum to the EU Standard Contractual Clauses, or a finding of adequacy. You can ask us for details of the safeguard applying to a particular transfer.
How long we keep things
- Server logs: [RETENTION PERIOD, e.g. 30 days].
- Enquiry emails: [RETENTION PERIOD, e.g. 24 months] after the enquiry is resolved.
- Newsletter subscriptions: until you unsubscribe.
- Commission and accounting records: six years, as required for tax.
Your rights
Under UK data protection law you have the right to ask us to give you a copy of your data, correct it, delete it, restrict how we use it, or transfer it. You may object to processing carried out on the basis of legitimate interests, and withdraw consent where processing relies on it. Withdrawing consent does not affect processing that already happened.
To exercise any of these, email [PRIVACY CONTACT EMAIL]. We will respond within one month.
If you are unhappy with how we have handled your data you can complain to the Information Commissioner’s Office at ico.org.uk, by calling 0303 123 1113, or by writing to Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF. We would appreciate the chance to address it first.
Children
This site is aimed at adults planning travel. We do not knowingly collect data from children under 13.
Changes
We may update this policy. The version date below tells you when it last changed, and material changes will be flagged on the site.
Last updated: [DATE]