PERSONAL DATA PROTECTION
With the entry of the EU General Regulation regarding Data Protection - GDPR, on the 25th of May 2018, your data will be more protected and secure.
CATEGORIES OF PERSONAL DATA WE COLLECT
1. The categories of personal data about you that we may collect, use, store, share and transfer are:
1.1.1 Information Technology Data. This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website;
1.1.2 Individual Data. This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, marital status, title, date of birth, place of birth, passport number and gender;
1.1.3 Account and Profile Data. This includes personal data which relates to your account or profile on our website, such as your username and password, proposals and bookings made by you, your interests, preferences, feedback and survey responses;
1.1.4 Usage and Operational Data. This includes personal data which relates to your usage and operation of our website, such as information about how you use our website, products and services;
1.1.5 Economic and Financial Data. This includes personal data required for us to process your booking;
1.1.6 Enquiry and Sales Data. This includes personal data which relates to the transactions you have conducted with us, such as details about payments to and from you, details of subscriptions to our services or publications and other details of products and services you have purchased from us;
1.1.7 Market Research Data. This includes personal data which is gathered for the purposes of market research, such as price comparison information;
1.1.8 Health Data. This includes personal data which is gathered for health and safety purposes including any accident report or claim log or any information you provide about allergies or other medical conditions during the booking process or in one of our locations;
1.1.9 Communication Data. This includes personal data which relates to a method of communication such as your billing address, delivery address, email address and telephone numbers.
1.2 We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of key details of the conversation so that we can take steps to address the complaint.
1.3 We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Operation Data to calculate the percentage of users accessing a specific feature on our website. However, if we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.
2. THE SOURCES FROM WHICH WE OBTAIN YOUR PERSONAL DATA
2.1 We obtain your personal data from the following sources:
2.1.1 Directly from you, either in person (at our location or otherwise), via our website, via email or by telephone. This could include personal data which you provide when you:
(a) book an appointment;
(b) contact our travel agents;
(c) browse on our website;
(d) request marketing to be sent to you;
(e) saving a proposal;
(f) entering details at an event;
(g) send an email to us.
2.1.2 Automated technologies, such as call recording, cookies, server logs and other similar technologies.
2.1.3 Third parties, such as:
(a) providers of technical, payment and delivery services;
(b) data brokers or aggregators;
(c) partnerships;
(d) travel agents.
3. HOW WE USE YOUR PERSONAL DATA & OUR BASIS FOR USING IT
3.1 Where we are relying on a basis other than consent
We may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data and the relevant legal basis upon which we will rely (this is what the law allows us to do):
3.1.1 For managing your booking we will use information provided by you to deliver our products and services. This includes booking holidays, tours, transportation, car hire and the issuing of tickets. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
3.1.2 To make suggestions and recommendations to you about our products and services that may be of interest to you.
We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
3.1.3 To deal with your enquiries, to send you information you have requested or to provide you with important-real time information about our products and service you have ordered from us (e.g. a change of time or location due to unforeseen circumstances). We will rely on the following legal bases to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
(b) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
3.1.4 For the development, delivery and improvement of our products and services, marketing, customer relationships and experiences in the provision of products and services to our customers. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
3.1.5 To protect our rights or property (including our website), administer and improve our IT services and network security, prevent fraud and facilitate any business reorganisation or group restructuring exercise. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
3.1.6 In order to use your personal data in life or death situations where there is no time to gain your consent (e.g. in the event of an accident and we have to give personal details to medical personnel). We will rely on the following legal basis to process this personal data:
(a) the processing is necessary in order to protect the vital interests of the data subject or of another natural person;
3.2 Special Categories of Data
In addition, we may lawfully process Special Categories of Data in certain ways. We set out below the purposes for which we may process Special Categories of Data along with the legal bases on which we process these Special Categories of Data (this is what the law allows us to do):
3.2.1 we may need to process your health information (for example to enable us to make arrangements for special assistance and any dietary preferences or requirements or for determining your fitness to fly). In relation to the processing of such Special Categories of Data:
(a) We rely on the following legal basis to process such Special Categories of Data:
(i) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
(ii) the processing is necessary in order to protect the vital interests of the data subject or of another natural person;
3.2.2 We may need to disclose any Special Categories of Data we hold on you, where to do so is in the substantial public interest (for example your health information in order to prevent an epidemic, in the event of illness or injury or some other related emergency, to record any accident or injury or other incident you may suffer when visiting any of our locations or to arrange for you to receive medical assistance), provided that when we do so we provide suitable measures to protect your rights. In relation to the processing of such Special Categories of Data:
(a) We rely on the following legal basis to process such Special Categories of Data:
(i) The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
(b) Additionally, we can only process such Special Categories of Data where:
4. WHO RECEIVES YOUR PERSONAL DATA
4.1 We may disclose your personal data to:
4.1.1 our third party suppliers or sub-contractors who may process data on our behalf to enable us to provide you with our services. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;
4.1.2 Legal and other regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;
4.1.3 external professional advisers such as accountants, bankers, insurances, auditors and lawyers;
4.1.4 law enforcement agencies, courts, immigration authorities, customs and excise authorities or other relevant party, to the extent necessary for the establishment, exercise or defence of legal rights;
4.1.5 third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
4.1.6 third parties which are considering or have decided to buy some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);
5. PERSONAL DATA ABOUT OTHER PEOPLE WHICH YOU PROVIDE TO US
5.1 If you provide personal data to us about someone else you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.
5.2 You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.
6. ACCURACY OF YOUR PERSONAL INFORMATION
6.1 It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us either by logging onto your account on the website or by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
7. HOW LONG WE WILL STORE YOUR PERSONAL DATA FOR
We ensure that we only keep your personal data for the minimum period as is necessary for us to abide by our relevant legal obligations and we will act in accordance with any group data retention policy mandated by our parent company which is place from time to time. In relation to personal data relating to your bookings with us, we will store your personal data for 8 years from your departure date. In relation to personal data relating to marketing, we will store your personal data for 8 years from your last interaction with us. We keep the length of time that we hold your personal data under review. These reviews take place annually.
8. CONTRACTUAL OR STATUTORY REQUIREMENTS ON YOU TO PROVIDE PERSONAL DATA
8.1 In certain circumstances the provision of personal data by you is a requirement:
8.1.1 to comply with the law or a contract; or
8.1.2 necessary to enter into a contract.
8.2 You are required to provide personal data which is necessary to comply with the law and the consequences of failing to provide your personal data are the inability for us to fulfill your product or service request.
8.3 It is your choice as to whether you provide us with your personal data necessary to enter into a contract or as part of a contractual requirement. If you do not provide your personal data then the consequences of failing to provide your personal data are that we may not be able to perform to the level you expect under our contract with you. An example of this would be where we are unable to provide you with certain products or services as we do not have your full details, or where we cannot perform our contract with you at all because we rely on the personal data you provide in order to do so.
9. YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
9.1 Subject to applicable law including relevant data protection laws, in addition to your ability to withdraw any consent you have given to our processing your personal data, you may have a number of rights in connection with the processing of your personal data, including:
9.1.1 the right to request access to your personal data that we process or control;
9.1.2 the right to request rectification of any inaccuracies in your personal data or, taking into account the purposes of our processing, to request that incomplete data is completed;
9.1.3 the right to request, on legitimate grounds as specified in law:
(a) erasure of your personal data that we process or control; or
(b) restriction of processing of your personal data that we process or control;
9.1.4 the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
9.1.5 the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, to the extent applicable in law; and
9.1.6 the right to lodge complaints regarding the processing of your personal data with any supervisory body.
If you would like to exercise any of the rights set out above, please contact us using the contact details set out in section 2.
10. LINKS TO OTHER WEBSITES
10.1 This policy only applies to us. If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.