CHNW - Privacy Notice

CHNW OWNER PRIVACY NOTICE
Version: v1.0
Effective date: 19 July 2026
Status: REVIEW DRAFt approv
ed - 19 July 2026
Controller: VNPD Properties Limited trading as Caravan Holidays North Wales
Company number: 15792102
Registered office: 66 Heysham Road, Southport, PR9 7EB
Privacy email: [email protected]
Telephone: 07712 580512

1. ABOUT THIS NOTICE

This Owner Privacy Notice explains how VNPD Properties Limited trading as Caravan Holidays North Wales (“CHNW”, “we”, “us” or “our”) collects and uses personal information relating to prospective, current and former caravan owners, joint owners, company or partnership representatives, authorised signatories, payees, emergency contacts and other people connected with an owner-managed caravan.

It applies to information collected through the CHNW Owner Onboarding Portal, forms, email, telephone, messaging services, the CHNW website, booking and property-management platforms and during the continuing owner-management relationship.

This notice does not replace the CHNW Owner Agency Agreement. Guest information is subject to the relevant guest-facing privacy information and booking terms.

2. WHO IS RESPONSIBLE FOR YOUR INFORMATION?

The data controller is VNPD Properties Limited, company number 15792102, trading as Caravan Holidays North Wales.

Registered office: 66 Heysham Road, Southport, PR9 7EB.

Privacy contact email: [email protected]. Telephone: 07712 580512.

Please mark privacy enquiries “Data protection request”. CHNW has not appointed a statutory Data Protection Officer; privacy matters are handled by CHNW’s authorised privacy contact.

3. PERSONAL INFORMATION WE COLLECT

Depending on the owner, ownership structure, caravan and services requested, we may collect the following:

• Identity and contact information: legal and preferred names, postal and correspondence addresses, email addresses, telephone numbers, signatures and information visible on identification or proof-of-address documents.
• Ownership and authority information: proof of caravan ownership or letting authority, joint-owner details, company or partnership information, Companies House details, authorised-signatory information and Park permission.
• Caravan and operational information: Park, plot, address, facilities, sleeping arrangements, access arrangements, owner-use dates, existing bookings, emergency contacts and maintenance information.
• Safety, insurance and compliance information: insurance policies and expiry dates, gas and electrical evidence, fire and risk assessments, alarm records, inspection outcomes, Park requirements and related correspondence.
• Payment and tax information: legal payee and bank-account names, bank name, sort code, account number, bank evidence, VAT status and registration details, payments, owner statements, refunds, charges and reconciliation records.
• Contract and communication information: accepted agreement and privacy-notice versions, electronic acceptance records, correspondence, complaints, instructions, call or message notes and review decisions.
• Technical and security information: portal account and managed-user identifiers, email-verification and one-time-passcode events, IP address and device or browser information where supplied by the service provider, form activity, upload metadata, timestamps, audit logs and automation references.
• Information about other people: details supplied about joint owners, company officers, signatories, emergency contacts, contractors or other relevant people.

Please provide only information that CHNW requests. Do not include transaction histories, balances, special-category information or unrelated personal information in uploaded documents where it can reasonably be redacted.

4. IDENTIFICATION DOCUMENTS AND SENSITIVE INFORMATION

Photo identification and financial information require additional care. CHNW uses identity documents for manual identity and authority verification, fraud prevention and protecting Owners, Guests and CHNW. CHNW does not use facial-recognition technology or create biometric templates from identification photographs.

A photograph is not automatically biometric special-category data. However, it may reveal information such as racial or ethnic origin, religion, disability or health. CHNW does not seek to use such incidental information and will restrict access to identity documents.

CHNW does not intentionally request criminal-offence information or other special-category information during standard owner onboarding. If such information is genuinely necessary, CHNW will identify an appropriate lawful basis, additional condition and safeguards before using it.

5. WHERE WE OBTAIN INFORMATION

We normally obtain personal information directly from you through onboarding forms, uploads and communications. We may also receive it from:

• another joint owner, authorised signatory or company representative;
• the holiday Park, booking platforms and property-management systems;
• public sources such as Companies House and other official registers;
• insurers, cleaners, contractors, photographers, accountants and professional advisers;
• Guests, payment providers, banks or fraud-prevention and security providers where relevant to a Booking, payment, complaint or investigation.

If you provide another person’s information, you must have authority to do so and should give them this notice unless an exemption applies.

6. WHY WE USE INFORMATION AND OUR LAWFUL BASES

The table below summarises CHNW’s main purposes and lawful bases. More than one lawful basis may apply.

Purpose: Respond to enquiries, assess suitability and take onboarding steps
Information: Contact, identity, ownership, caravan and communication information
Lawful basis: Steps requested before entering a contract; legitimate interests in operating and protecting the management service

Purpose: Verify identity, ownership, authority and bank instructions; prevent fraud
Information: Identity, authority, ownership, bank evidence, technical and audit information
Lawful basis: Contract; legitimate interests in preventing fraud, misdirected payments and unauthorised listings; legal obligation where applicable

Purpose: Provide management, booking, communication, statement and payment services
Information: Owner, caravan, booking, payment and communication information
Lawful basis: Performance of the Owner Agency Agreement

Purpose: Check safety, insurance, Park permission and compliance
Information: Compliance, insurance, Park, property and inspection information
Lawful basis: Contract; legal obligations where applicable; legitimate interests in protecting Guests, Owners, CHNW and the Park

Purpose: Accounting, tax, audit and reconciliation
Information: Payment, VAT, statement, booking and contract records
Lawful basis: Legal obligation; contract; legitimate interests in accurate financial administration

Purpose: Handle complaints, incidents, disputes, refunds and legal claims
Information: Communications, booking, evidence, photographs, contractor and audit information
Lawful basis: Contract; legal obligation; legitimate interests in resolving disputes and establishing, exercising or defending claims

Purpose: Secure systems, detect misuse and maintain audit trails
Information: Account, IP, device, login, file and automation information
Lawful basis: Legal obligations relating to security; legitimate interests in protecting systems, confidential information and funds

Purpose: Improve processes, reporting and service quality
Information: Operational and usage information, preferably aggregated or minimised
Lawful basis: Legitimate interests in improving CHNW’s services, balanced against Owner rights

Purpose: Send optional marketing
Information: Name and contact preferences
Lawful basis: Consent or legitimate interests where permitted by PECR; the right to opt out always applies

Purpose: Comply with regulators, courts, tax authorities or law enforcement
Information: Information relevant to the lawful request
Lawful basis: Legal obligation; legitimate interests; vital interests in an emergency where applicable

7. IF YOU DO NOT PROVIDE INFORMATION

Some information is needed to take steps towards or perform the Owner Agency Agreement, verify payment instructions, protect against fraud, meet legal or accounting requirements, and confirm that a caravan can be marketed safely and lawfully.

If required information is not provided, CHNW may be unable to complete onboarding, verify ownership or bank details, publish or continue a listing, make an owner payment, administer Bookings or continue providing management services. CHNW will explain where a particular item is optional.

8. WHO WE SHARE INFORMATION WITH

We share personal information only where reasonably necessary for the purposes described in this notice. Recipients may include:

• Chris, Vicky and other authorised CHNW personnel who need access for their role;
• technology and cloud providers used for forms, automation, secure accounts, document storage, email, website hosting, property management, communications, backups and security, including Zapier, Google, Microsoft and Lodgify where used;
• booking platforms such as Airbnb, Booking.com and Vrbo where the caravan is listed;
• banks, payment-service providers, accountants, bookkeepers, tax advisers and auditors;
• the relevant Park, insurers, cleaners, maintenance providers, photographers and other operational contractors, limited to the information they need;
• legal advisers, insurers, courts, regulators, tax authorities, law-enforcement agencies or other public authorities where required or permitted;
• a prospective buyer, investor or successor if CHNW restructures, sells or transfers all or part of its business, subject to appropriate confidentiality and data-protection safeguards.

CHNW does not sell personal information. Booking platforms and some professional or payment providers may act as independent controllers and will provide their own privacy information. CHNW does not ordinarily give identity documents or full bank details to Parks, cleaners or Guests.

9. SERVICE PROVIDERS AND PROCESSOR CONTRACTS

Where a supplier processes personal information on CHNW’s behalf, CHNW will use appropriate contractual and due-diligence measures. Supplier contracts should address instructions, confidentiality, security, subprocessors, individual rights, assistance, deletion or return of information, audits and data incidents where required by law.

Suppliers may change over time. CHNW maintains an internal supplier and processing record and will update this notice where a change materially affects Owners.

10. INTERNATIONAL TRANSFERS

Some technology, booking and support providers or their subprocessors may process information outside the United Kingdom, including in the European Economic Area and the United States.

Where a restricted transfer occurs, CHNW will use a lawful transfer mechanism where required, such as UK adequacy regulations, the UK Extension to the EU–US Data Privacy Framework where applicable, the International Data Transfer Agreement, the UK Addendum to approved standard contractual clauses, or another lawful safeguard. CHNW will carry out reasonable supplier and transfer checks appropriate to the risk.

You may contact CHNW for further information about the categories of recipient and safeguards relevant to your information.

11. HOW WE PROTECT INFORMATION

CHNW uses technical and organisational measures designed to protect personal information against accidental or unlawful loss, alteration, unauthorised access or disclosure. These include managed-user portal access, email one-time-passcode verification, restricted Tables and document folders, role-based access, multi-factor authentication for authorised business accounts where available, secure upload routes, audit records, supplier checks, backups and incident-response procedures.

Access to identity and bank information is restricted to authorised CHNW users and relevant professional or technology providers. Owners must use the secure portal rather than ordinary email for identity documents, bank evidence and bank-detail changes.

No internet or storage system is completely secure. If you believe information has been sent to the wrong person, an account has been compromised or a document has been exposed, contact CHNW immediately.

12. HOW LONG WE KEEP INFORMATION

CHNW keeps personal information only for as long as reasonably needed for the relevant purpose, legal or accounting duties, fraud prevention, insurance requirements and the establishment, exercise or defence of legal claims. The following are the standard periods proposed for this owner-onboarding process:

• Incomplete or abandoned onboarding: 12 months after the last activity, then delete or anonymise unless a dispute, fraud concern or legal hold applies
• Declined or withdrawn onboarding: Normally 12 months after the decision; minimal decision and suppression records may be retained longer where reasonably needed for a dispute, fraud prevention or legal claim
• Owner Agreement, acceptance and core relationship records: For the active relationship and normally 6 years after it ends
• Booking, statement, payment, invoice, tax and accounting records: Normally 6 years from the end of the relevant accounting period or longer where HMRC, an enquiry or another legal requirement applies
• Raw photo ID, proof of address, authority evidence and raw bank evidence: Delete securely after verification and normally within 90 days of successful onboarding or verification; retain only the verification result, document type/reference, reviewer and date unless the original is needed for a live fraud, dispute, insurer or legal matter
• Current bank details: While needed to make payments; superseded details are deleted or restricted when no longer needed, except where a limited record is required for accounting, payment disputes, fraud prevention or claims for up to 6 years
• Insurance and safety/compliance documents: Keep current evidence while the caravan is managed; superseded evidence normally for up to 6 years after replacement or the relationship ends, subject to insurer, legal and claims requirements
• Complaints, incidents, damage and legal claims: Normally 6 years after closure, or longer where an insurer, court, personal-injury/minor claim or legal hold requires it
• Portal, security and audit logs: Normally 24 months, or longer for a security, fraud or legal investigation
• Marketing preferences and suppression records: While marketing continues; minimal suppression information for as long as needed to respect an opt-out

CHNW may retain information longer for a legal, tax, insurer, regulatory, fraud or claims hold, and delete it sooner where no longer required.

13. ACCURACY AND OWNER RESPONSIBILITIES

Please keep your information accurate and tell CHNW promptly about changes to ownership, authority, address, contact details, VAT status, bank details, insurance, Park permission or compliance. Bank-detail changes must use CHNW’s secure verification process.

CHNW may ask Owners to confirm key details annually or when a risk, payment change, expiry or inconsistency is identified.

14. YOUR DATA-PROTECTION RIGHTS

Depending on the circumstances, you may have the right to:

• ask for access to your personal information and information about how it is used;
• ask for inaccurate or incomplete information to be corrected;
• ask for information to be erased where there is no continuing lawful reason to keep it;
• ask for processing to be restricted in certain circumstances;
• object to processing based on legitimate interests or to direct marketing;
• receive certain information in a structured, commonly used and machine-readable format and ask for it to be transferred where the right to portability applies;
• withdraw consent at any time where consent is the lawful basis, without affecting earlier lawful processing;
• ask for safeguards or human review where a solely automated decision would have a legal or similarly significant effect.

To exercise a right, contact [email protected]. CHNW may need to verify your identity and authority before acting. Rights are not absolute, and CHNW may retain information where another lawful reason applies. CHNW will normally respond within the statutory time limit and will explain any refusal or extension.

15. AUTOMATED PROCESSING

CHNW may use automations to route forms, name and file documents, calculate reminder dates, flag missing information and create review tasks. These automations support administration and human review.

CHNW does not currently make decisions about accepting an Owner, verifying a bank account, approving compliance or publishing a caravan solely by automated processing where the decision has a legal or similarly significant effect. An authorised person reviews those decisions.

16. MARKETING COMMUNICATIONS

Service messages about onboarding, Bookings, payments, compliance, safety, document expiry and the Owner relationship are not optional marketing messages and may be sent where necessary for the contract or CHNW’s legitimate interests.

CHNW will send optional promotional emails or texts to individuals only where permitted by the Privacy and Electronic Communications Regulations, for example with consent or where a valid soft opt-in applies. Every electronic marketing message will provide a clear way to opt out. An objection to direct marketing will be respected, although CHNW may retain minimal suppression information to ensure the person is not contacted again.

17. PORTAL, WEBSITE AND COOKIES

The portal and website may use essential cookies or similar technologies for login, security, session management, CAPTCHA, preferences and service operation. Non-essential analytics or advertising technologies should be used only in accordance with the applicable cookie requirements and choices presented to users.

Third-party websites and booking platforms have their own privacy and cookie information. CHNW is not responsible for how an independent third party uses information after you choose to use its service.

18. CHILDREN

The Owner onboarding service is intended for adults and authorised business representatives. CHNW does not knowingly invite a person under 18 to enter an Owner Agreement or provide identity or bank documents through the owner portal. Contact CHNW if information about a child has been submitted unintentionally.

19. COMPLAINTS

Please contact CHNW first so that we can investigate a privacy concern.

You also have the right to complain to the Information Commissioner’s Office (ICO): ico.org.uk/make-a-complaint; telephone 0303 123 1113; or Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

20. CHANGES TO THIS NOTICE

CHNW will review this notice regularly and when its systems, suppliers, purposes or legal obligations change. The version and effective date appear at the beginning of the notice.

Material changes will be brought to affected Owners’ attention before the new use begins where required. An acknowledgement records that the notice was made available; it is not blanket consent to all processing.

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