Privacy policy

1. Who we are

Togetherly Valtbx Media Ltd publishes togetherlyvaltbx.beauty, an independent editorial website about spa hotels in Europe. Our registered address is Second Floor, 18 Broad Street, Bristol BS1 2HG, United Kingdom. Questions about this policy or about your data should be sent to [email protected], which is also the address for our privacy contact. We have not appointed a statutory data protection officer because the scale and nature of our processing does not require one; the privacy contact performs that role informally.

2. What we collect and why

We collect as little as an editorial site can. There are no user accounts, no newsletters and no purchases. The categories of data we may process are:

• Contact form data. When you use the contact page we receive the name, email address, topic and message you provide. We use these to reply to you and to act on corrections. The lawful basis is our legitimate interest in running an accurate site and responding to correspondence, and, where you tick the consent box, your consent.
• Technical data. Our hosting provider records standard server logs, including IP address, browser type, the pages requested and the time of the request, for security and to keep the site running. The lawful basis is legitimate interest.
• Analytics data. If you accept analytics cookies, we process anonymised or pseudonymised page-view information to understand which guides are read. The lawful basis is consent, which you can withdraw at any time through the cookie preferences.
• Preference data. Your cookie choice is stored in your browser's local storage so that the banner does not reappear on every page. This is stored on your device, not sent to us.

We do not knowingly collect data from children, and the site is not directed at them. We do not collect special category data and ask that you do not include health information in contact messages; the guides are not medical advice and we cannot respond to health questions.

3. Cookies and similar technologies

The cookie policy lists every cookie and storage item the site uses, grouped as essential, analytics and functional, together with how to manage them in your browser. Essential items are set regardless of choice because the site cannot function without them. Analytics and functional items are set only if you accept them.

4. Processors and sharing

We use a small number of service providers who process data on our behalf under written terms: a web hosting provider that serves the site and stores server logs, an email provider that delivers and stores contact correspondence, and, where you have consented, an analytics provider that processes page-view data. These providers act only on our instructions. We do not sell personal data, do not share it with advertisers and do not pass it to hotels, spa operators or any third party named on the site. Where a provider stores data outside the United Kingdom or the European Economic Area, we rely on the transfer mechanisms recognised by UK and EU law, such as adequacy decisions or standard contractual clauses.

5. The law that applies

Our processing is governed by the UK General Data Protection Regulation and the Data Protection Act 2018, supervised by the Information Commissioner's Office. If you are in the European Economic Area, the EU General Data Protection Regulation applies to our processing of your data and you may complain to your local supervisory authority. If you are a resident of California, the California Consumer Privacy Act may give you rights to know what personal information we hold, to request its deletion and to opt out of its sale; we do not sell personal information, and you may exercise the other rights by email.

6. Retention

Contact correspondence is kept for as long as needed to deal with the matter raised and then for a further limited period in case of follow-up, after which it is deleted. Server logs are retained by our hosting provider for a short rolling period for security purposes. Analytics data is retained for the period set in the analytics tool and is aggregated so that it does not identify individuals. Your cookie preference remains in your browser until you clear it.

7. Your rights

Under UK and EU data protection law you may ask us to confirm what personal data we hold about you, to provide a copy, to correct it, to erase it, to restrict or object to its processing, and to provide it in a portable form. Where processing rests on consent, you may withdraw that consent at any time without affecting the lawfulness of earlier processing. To exercise any right, email the privacy contact above. We will respond within the statutory period and may need to verify your identity first. You also have the right to lodge a complaint with the Information Commissioner's Office or, in the EEA, with your local authority.

8. Security

The site is served over an encrypted connection, access to correspondence is limited to those who need it, and we use reputable providers with their own security programmes. No system is perfectly secure, and if we became aware of a breach affecting your data we would notify you and the regulator where the law requires it.

9. Changes to this policy

We may update this policy when our practices or the law change. The current version is always the one published on this page, and material changes will be signalled on the home page for a reasonable period.