Privacy and Data Usage Policy

Bubble Property Management Ltd. from here in will be refered to as BPM, manage holiday homes for private individuals. BPM is committed to protecting your privacy. This privacy policy explains our limited data collection and usage. By using or contacting BPM, you consent to the data practices described in this policy.

Our registered address is Galmpton Farmhouse, Galmpton Farm Close, Brixham TQ5 0NP. If you have any comments or questions regarding this policy please contact us by email at

How do we collect data?

We collect data of guests that is only pertenant to their stay in one of the holiday homes we manage. We keep a record of only primary contact information ie. Name of booker, mobile phone number, county and country from which they herald. We do not collect full address or email unless they/you live abroard and only if that is the easiest form of contact. We do not collect data of visits to our web sites etc.

How we use what we collect.

Holiday Guests: Initally we use the information to contact guests in regards to issues that may arise at the property or to help guests access the property in the event of early arrivals, parking or emergency. Secondly we feed guests feedback from their welcome letter back into our system to generate anonymous feedback to the owners about how our, the property and the agencies performance were perceived. This is to help improve the property and our performance. It also informs us of anything wrong at the property that we need to put right. The data is compiled and is normally sent to the owner at the end of the season so they owners can look at it in conjuction with any feedback from the agents and then the data is permenatly erased 6 months later.

Property Owners: We use the basic information of address, email & phone to carry out our contract with regard to informing you of, delivery of service, telling you of charges, invoicing, managing and updating your personal information. We will do this on the basis of GDPR legitimate interest. We may contact you by email or telephone under the PECR ‘soft opt-in’ basis for processing of personal data. If you contact BPM for a quote or to discuss a new property, information on your address and contact details plus the holiday home address and configuration of the property will be captured to help facilitate an estimate price and communication/follow-up.

Please Note: None of our data is passed to any 3rd party

Legitimate Interest Assessment

The Information Commissioners Office (ICO) states there are three elements to the legitimate interest basis:

a. Identify a legitimate interest

b. Show the process is necessary to achieve it

c. Balance it against the individuals interests rights and freedoms

d. The legitimate interests can be BPM’s own interests or the interests of third parties. They can include commercial interests, individual interests or broader societal benefits.

e. The processing must be necessary. If BPM can easily achieve the same results in another less intrusive way, legitimate interest will not apply.

f. BPM must balance their interests against your interests. If you would not reasonably expect the processing, or it would cause unjustified harm, your interests are likely to override the legitimate interests.


Where we store your data
Data is stored offline on a standalone hard drive with one PC access. The PC always has the latest firewall, malware and spyware supplied by McAffee.

Your rights
Your rights include: The right to be informed, the right of access, the right of rectification, the right to erase, the right to restrict processing, the right of data portability, the right to object, right in relation to automated decision making. Full details of these rights can be viewed on the Information Commissioners web site. Under the data protection act 1998, you have the right as an individual, in relation to the information we hold about you.

Access to personal information
BPM tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making ‘a subject access request’ under the data protection act 1998.

To make a subject access request you need to put the request in writing to the MD at the address provided below. If you agree we will try to deal with your request informally, providing you with specific information you need over the telephone or by email We may charge a ten pound fee for a formal SAR. If we do hold information about you, you can ask us to correct any mistakes.

If we make any changes to our Privacy Policy they will be updated on this page.

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All Rights Reserved