Privacy Policy

Rock Estates (Cornwall) Limited, trading as John Bray and Partners and John Bray Cornish Holidays


This notice is to help you understand how and why we collect your personal information and what we do with that information. It also explains the decisions that you can make about your own information.

What is personal information?

Personal information is information that “the company”, Rock Estates (Cornwall) Limited, trading as John Bray and Partners and John Bray Cornish Holidays, holds about you and which identifies you. This can include information such as your name, age category, contact telephone numbers alternative contact numbers, e-mails and address as well as things that are required under the law for selling property such as identity check information.

Our legal bases for using your information

Legitimate interest
This means that the company is using your information when this is necessary for the purpose of fulfilling our contractual obligations to you in the legitimate purpose of carrying out the business purpose. We won't rely on this basis when your interests and fundamental rights override our legitimate interests. Specifically, but not exclusively, these services are:

Providing Self-Catering holidays as an agent for the owner of a property (including sharing your data with the legal contracting parties and contractors who need the information to carry out their legitimate function);
Providing Maintenance services (including instructing and sharing your data with legitimate sub-contractors) for both owners and guests;
Providing Holiday Insurance services (including instructing and sharing your data with the insurer and ITC compliance Ltd which is authorised and regulated by the Financial Conduct Authority – their regulation number is 313486 - for the purposes of monitoring and/or enforcing compliance with any regulatory rules and codes);
Providing Estate Agencies services (including instructing and sharing your data with contracting parties and their professional advisors);

Legal obligation
The company might need to use your information in order to comply with a legal obligation. Such as to disclose your information to third parties such as the courts, the local authority or the police (where legally obliged to do so).

Vital interest
In limited circumstances we may use your information to protect your vital interests or the vital interests of someone else (e.g. if you or they are seriously hurt).

Performance of a task carried out in the public interest (or carrying out public tasks)
This applies where what we are doing is for the benefit of people generally. The following are examples of where this applies:
Providing you and others with administration over an emergency;
Safeguarding and promoting your welfare and the welfare of anyone who could be in the property with you;
Ensuring that we comply with all of our legal obligations.

Employment and social protection and social security law and taxation law
There will be times when the company needs to use your information because we are an employer. Also, the company could use your information to comply with social protection law, social security laws and taxation laws. Social protection law is concerned with preventing, managing, and overcoming situations that adversely affect people’s wellbeing.

Legal claim
We are allowed to use your information if this is necessary, in relation to legal claims. For example, this allows us to share information with our legal advisors and insurers. This applies whenever sharing special category data is necessary in relation to legal claims.

Medical purpose
This includes medical treatment and the management of healthcare services.

We collect information about you when:

When you request a specific service, such as ask us to holiday let your house; to book a house for a holiday, or when you register with us to sell or by a house, or for subscription to our newsletter, brochure (or any promotional function or magazine that we may from time to time invite or send out to our clients). We collect the data from you that we need to carry out that legitimate function as requested by you. As said already the type of information we collect this way may include your name, address, phone numbers and email address alternative contact information. Our website sends your debit or credit card details to sagepay our website does NOT hold card information beyond that point it is immediately deleted. For that reason, refunds can only be processed (via sagepay) to the specific card that you made the payment through. Information gathered for this purpose will never be used for any other purpose or shared with any other companies except in the legitimate fulfilment our contracted service to you. We will always give you the option to unsubscribe from our newsletter/marketing facility by clicking the ‘Unsubscribe’ button that appears on each newsletter and marketing communication or simply contact us at All information provided by you will be accurate, relevant and up to date and will be treated securely and strictly in accordance with the law. Any inaccuracies will be corrected promptly. Just to repeat we have never and will never disclose any information about you to any third party unless it is in the legitimate fulfilment our contracted service to you or any other legal obligation. We use software on our websites that allows us to collect statistics such as how many people are visiting the site, which pages they are looking at and how long they are spending on the site. This information is anonymous and is used only in order for us to understand visitor needs and improve the site (see “Use of cookies” section at end of this privacy notice).

Sometimes we get information from other sources and other professionals, or we may need ourselves to share your information with other sources and other professionals, we will only do this where we need this to carry out our legitimate functions or where we are legally obliged to do so.

  1. The company’s primary reason for sharing or obtaining any information about you from a third party will be for the provision of one of our legitimate services. On occasion this can extend to include checks on current address and ownership relationships, credit checks, health checks, Police checks (e.g. if there is a burglary or malicious damage caused to a property or person), etc.
  2. In certain circumstances we may need to share information about you (e.g. about your insurance, holiday fulfilment or the sale or purchase of a property etc) for example with the buyers/sellers solicitors and surveyors, insurance companies and any company or party related to our legitimate fulfilment of providing our services to you.
  3. If you supply us with (or we collect information about) your health from another source (such as that you suffer from an allergy or any other disability and need for example a single storey bedroom and bathroom for accessibility needs), it will be used so that we can look after you and support you.

Criminal offence information

In exceptional circumstances, we may use information about criminal convictions or offences. We will only do this where the law allows us to. This will usually be where such processing is necessary to carry out our obligations and to exercise our rights or to look after our employees, sub-contractors and clients.

More than one basis

As you will see from the information above, in some cases we will rely on more than one of the grounds for a particular use of your information. In addition, we may move from one of the legal bases listed above to another as circumstances change.


We may ask for your consent to use your information in certain ways as an alternative to relying on any of the bases already detailed. For example, we may ask for your consent before using a testimonial or taking or using some photographs and videos. If we ask for your consent to use your personal information you can take back this consent at any time. Any use of your information before you withdraw your consent remains valid. Please speak to data protection officer at the company if you would like to withdraw any consent that you have given.

For how long do we keep your information?

We keep your information for as long as we need in order to carry out our legitimate legal obligations to you. In exceptional circumstances we may keep your information for a longer time than usual, but we would only do so if we had a good reason and only if we are allowed to do so under data protection law.

What decisions can you make about your information?

You are able to make various decisions about your information. Some of these are new rights whilst others build on your existing rights. In precis your rights are as follows:
Rectification: if information the company holds about you is incorrect you can ask us to correct it.
Access: you can also ask what information we hold about you and be provided with a copy. This is commonly known as making a subject access request. This should be made to the data protection officer.
Deletion: you can ask us to delete the information that we hold about you in certain circumstances, for example, where we no longer need the information.
Portability: you can request the transfer of your information to you or to a third party in a format that can be read by computer in certain circumstances.
Restriction: our use of information about you may be restricted to simply storing it in some cases. For example, if you tell us that the information is inaccurate we can only use it for limited purposes while we check its accuracy.

How do we protect your personal information

We protect your personal information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our computers, and information access authorisation controls.

The Data Protection Officer

The company Data Protection Officer (DPO) is in charge of the company’s data protection compliance. You can contact the DPO in writing; Rock Estates (Cornwall) Limited, Trading as John Bray Cornish Holidays and John Bray & Partners, Pavilion Building, Rock, Cornwall, PL27 6JS; or If you consider that we have not acted properly when using your personal information you can contact the Information Commissioner's Office: quoting our Registered company name and ICO registration number; ROCK ESTATES (CORNWALL) LIMITED reg. no.; Z9308226

Use of cookies – data protection

To make full use of our websites your computer, tablet or mobile phone does need to accept “cookies”; as we can only provide you with certain personalised features of our websites by using them. Cookies make the use of our website easier; for example, so you can go backwards and forwards without having to re-enter your search requirements every-time on the holiday or sales websites; we also use them to see how our website is being used so we can improve the site; and to enable traffic monitoring. If you’d prefer to restrict, block or delete cookies from or or any other website, you can use your browser to do this, although this may affect the quality of your visit. Each browser is different, so check the ‘Help’ menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences. The cookies our site creates can’t harm your computer; they don’t store personally identifiable information (such as credit card details); they are there to help retain search information so you do not have to re-input as you go back and forwards. Information gathered from them help improve your experience of the site. For example, they help us to identify and resolve errors that can sometimes occur on websites. They are not computer programs and cannot read other information saved on your hard drive. They cannot be used to disseminate viruses, or get user’s e-mail addresses etc. We’re giving you this information because we want to be honest and upfront about your privacy when using our website, as part of our initiative to comply with recent EU legislation.

Third Party Links

Our websites do contain links to and from other websites. These other websites are outside our control and not covered by this Privacy Policy. If you access other sites using the links provided, the operators of those sites may collect information from you which will be used by them in accordance with their privacy policy, which may be different to ours. We encourage you to read the privacy policies of the other websites you link to or from our website or otherwise visit.