We are committed to safeguarding the privacy of our website
visitors and service users; in this policy we explain how we
will handle your personal data. By using our website and
agreeing to this policy, you consent to our use of cookies in
accordance with the terms of this policy.
Our website incorporates privacy controls which affect how we
will process your personal data. By using the privacy
controls, you can specify whether you would like to receive
direct marketing communications and limit the publication of
your information. You can access the privacy controls by
contacting our Marketing Team.
1. HOW WE USE YOUR PERSONAL DATA
In this Section we have set out;
-
the general categories of personal data that we may process;
-
in the case of personal data that we did not obtain directly
from you, the source and specific categories of that data;
-
the purposes for which we may process personal data; and
- the legal bases of the processing.
We may process data by way of recording our telephone calls
both inbound and outbound. The data on these calls may be
processed for quality and training purposes and/or to assist
in any dispute resolution. The legal basis for this processing
is our legitimate interest, namely monitoring and improving
our services and the protection and assertion of our legal
rights, your legal rights and the legal rights of others in
accordance with the Limitations Act 1980.
We may process data about your use of our website and services
("usage data"). The usage data may include your IP address,
geographical location, browser type and version, operating
system, referral source, length of visit, page views and
website navigation paths, as well as information about the
timing, frequency and pattern of your service use. The source
of the usage data is our analytics tracking system. This usage
data may be processed for the purposes of analyzing the use of
the website and services. The legal basis for this processing
is our legitimate interests, namely monitoring and improving
our website and services.
We may process your account data ("account data"). The account
data may include your name and email address. The source of
the account data is you. The account data may be processed for
the purposes of operating our website, providing our services,
ensuring the security of our website and services, maintaining
back-ups of our databases and communicating with you. The
legal basis for this processing is consent.
We may process your information included in your personal
profile on our website ("profile data"). The profile data may
include your name, address, telephone number, email address,
profile pictures, gender, date of birth, relationship status,
interests and hobbies, educational details and employment
details. The profile data may be processed for the purposes of
enabling and monitoring your use of our website and services.
The legal basis for this processing is consent, namely the
performance of a contract between you and us and/or taking
steps, at your request, to enter into such a contract.
We may process information contained in any enquiry you submit
to us regarding products and/or services ("enquiry data"). The
enquiry data may be processed for the purposes of offering,
marketing and selling relevant products and/or services to
you. The legal basis for this processing is the consent
received from you.
We may process information relating to transactions, including
purchases of goods and services, that you enter with us and/or
through our website ("transaction data"). The transaction data
may include your contact details and the transaction details.
The transaction data may be processed for the purpose of
supplying the purchased goods and services and keeping proper
records of those transactions. The legal basis for this
processing is the performance of a contract between you and us
and/or taking steps, at your request, to enter into such a
contract with a supplier and also our legitimate interests,
namely our interest in the proper administration of our
website and business.
We may process information that you provide to us for the
purpose of subscribing to our email notifications and/or
newsletters ("notification data"). The notification data may
be processed for the purposes of sending you the relevant
notifications and/or newsletters. The legal basis for this
processing is consent and the performance of a contract
between you and us and/or taking steps, at your request, to
enter into such a contract.
We may process information contained in or relating to any
communication that you send to us ("correspondence data"). The
correspondence data may include the communication content and
metadata associated with the communication. Our website will
generate the metadata associated with communications made
using the website contact forms. The correspondence data may
be processed for the purposes of communicating with you and
record-keeping. The legal basis for this processing is our
legitimate interests, namely the proper administration of our
website and business and communications with users.
We may process any of your personal data identified in the
other provisions of this policy where necessary for the
establishment, exercise or defense of legal claims, whether in
court proceedings or in an administrative or out-of-court
procedure. The legal basis for this processing is our
legitimate interests, namely the protection and assertion of
our legal rights, your legal rights and the legal rights of
others in accordance with the Limitations Act 1980.
In addition to the specific purposes for which we may process
your personal data set out in this section, we may also
process any of your personal data where such processing is
necessary for compliance with a legal obligation to which we
are subject.
Please do not supply any other person's personal data to us,
unless we prompt you to do so.
2. WHEN WE PROVIDE YOUR PERSONAL DATA TO OTHERS
We may disclose your personal data to any member of our group
of companies this means our subsidiaries, our ultimate holding
company and all its subsidiaries insofar as reasonably
necessary for the purposes set out in this policy.
We may disclose your personal data to our insurers and/or
professional advisers insofar as reasonably necessary for the
purposes of obtaining and maintaining insurance coverage,
managing risks, obtaining professional advice and managing
legal disputes.
We may disclose your passenger names, ages and booking
itinerary to suppliers or subcontractors insofar as reasonably
necessary for the fulfilment of the holiday contract.
Financial transactions relating to our website and services
are handled by our payment services providers, Worldpay and
Barclaycard Merchant Services. We will share transaction data
with our payment services providers only to the extent
necessary for the purposes of processing your payments,
refunding such payments and dealing with complaints and
queries relating to such payments and refunds. Click to find
information about Barclaycard Merchant
Services privacy policies and practices.
In addition to the specific disclosures of personal data set
out in this Section 3, we may also disclose your personal data
where such disclosure is necessary for compliance with a legal
obligation to which we are subject, or in order to protect
your vital interests or the vital interests of another natural
person.
3. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
In this Section we provide information about the circumstances
in which your personal data may be transferred to countries
outside the European Economic Area (EEA)].
The hosting facilities for our website are situated in the
United Kingdom and are thus within the EEA and subject to GDPR
EU 2016/679.
Accommodation, Tours and transfer suppliers are situated in
the USA, Africa, Australia, Egypt and Asia. Countries
outside of the European Economic Area (EEA) do not
always offer the same levels of protection to your personal
data, so European law has prohibited transfers of personal
data outside of the EEA unless the transfer meets certain
criteria.
Some of our third parties service providers are based outside
the European Economic Area (EEA) so their processing
of your personal data will involve a transfer of data outside
the EEA.
Whenever we transfer your personal data out of the EEA, we do
our best to ensure a similar degree of security of data by
ensuring at least one of the following safeguards is in place:
We will only transfer your personal data to countries that the
European Commission have approved as providing an adequate
level of protection for personal data by; or
Where we use certain service providers, we may use specific
contracts or codes of conduct or certification mechanisms
approved by the European Commission which give personal data
the same protection it has in Europe; or
If we use US-based providers that are part of EU-US Privacy
Shield, we may transfer data to them, as they have equivalent
safeguards in place.
If none of the above safeguards is available, we may request
your explicit consent to the specific transfer. You will have
the right to withdraw this consent at any time.
4. RETAINING AND DELETING PERSONAL DATA
This Section 5 sets out our data retention policies and
procedure, which are designed to help ensure that we comply
with our legal obligations in relation to the retention and
deletion of personal data.
Personal data that we process for any purpose or purposes
shall not be kept for longer than is necessary for that
purpose or those purposes.
We will retain and delete your personal data as follows:
(a) All information taken at the time of booking will be
retained for 36 months following your trip return date, at the
end of which period it will be deleted from our in-house
system, unless you have any future reservations made with
us. In these cases the information will be deleted 36
months after your final trip with us.
Notwithstanding the other provisions of this Section 5, we may
retain your personal data where such retention is necessary
for compliance with a legal obligation to which we are
subject, or in order to protect your vital interests or the
vital interests of another natural person.
5. AMENDMENTS
We may update this policy from time to time by publishing a
new version on our website.
You should check this page occasionally to ensure you are
happy with any changes to this policy.
6. YOUR GENERAL RIGHTS
You may instruct us to provide you with any personal
information we hold about you; provision of such information
will be subject to:
(a) the supply of appropriate evidence of your identity for
this purpose, we will usually accept an email from the lead
passenger via the email address provided at the time of
booking or a posted letter.
We may withhold personal information that you request to the
extent permitted by law.
You may instruct us at any time not to process your personal
information for marketing purposes.
In practice, you will usually either expressly agree in
advance to our use of your personal information for marketing
purposes, or we will provide you with an opportunity to opt
out of the use of your personal information for marketing
purposes.
7. YOUR LEGAL RIGHTS
In this Section we have summarized the rights that you have
under data protection law. Some of the rights are complex, and
not all of the details have been included in our summaries.
Accordingly, you should read the relevant laws and guidance
from the regulatory authorities for a full explanation of
these rights.
Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
You have the right to confirmation as to whether or not we
process your personal data and, where we do, access to the
personal data, together with certain additional information.
That additional information includes details of the purposes
of the processing, the categories of personal data concerned
and the recipients of the personal data. Providing the rights
and freedoms of others are not affected, we will supply to you
a copy of your personal data. We will not charge for subject
access requests unless they are ‘excessive’ (e.g.
repetitive). You should receive a response to your request
within 30 days of our receiving it. You can access your
personal data by emailing our Data Privacy Manager.
You have the right to have any inaccurate personal data about
you rectified and, taking into account the purposes of the
processing, to have any incomplete personal data about you
completed.
In some circumstances you have the right to the erasure of
your personal data without undue delay. Those circumstances
include: the personal data are no longer necessary in relation
to the purposes for which they were collected or otherwise
processed; you withdraw consent to consent-based processing;
the processing is for direct marketing purposes; and the
personal data have been unlawfully processed. However, there
are certain general exclusions of the right to erasure. Those
general exclusions include where processing is necessary: for
exercising the right of freedom of expression and information;
for compliance with a legal obligation; or for the
establishment, exercise or defence of legal claims.
In some circumstances you have the right to restrict the
processing of your personal data. Those circumstances are: you
contest the accuracy of the personal data; processing is
unlawful but you oppose erasure; we no longer need the
personal data for the purposes of our processing, but you
require personal data for the establishment, exercise or
defence of legal claims; and you have objected to processing,
pending the verification of that objection. Where processing
has been restricted on this basis, we may continue to store
your personal data. However, we will only otherwise process
it: with your consent; for the establishment, exercise or
defense of legal claims; for the protection of the rights of
another natural or legal person; or for reasons of important
public interest.
You have the right to object to our processing of your
personal data on grounds relating to your particular
situation, but only to the extent that the legal basis for the
processing is that the processing is necessary for: the
performance of a task carried out in the public interest or in
the exercise of any official authority vested in us; or the
purposes of the legitimate interests pursued by us or by a
third party. If you make such an objection, we will cease to
process the personal information unless we can demonstrate
compelling legitimate grounds for the processing which
override your interests, rights and freedoms, or the
processing is for the establishment, exercise, or defense of
legal claims.
You have the right to object to our processing of your
personal data for direct marketing purposes (including
profiling for direct marketing purposes). If you make such an
objection, we will cease to process your personal data for
this purpose.
To the extent that the legal basis for our processing of your
personal data is consent, and such processing is carried out
by automated means, you have the right to receive your
personal data from us in a structured, commonly used and
machine-readable format. However, this right does not apply
where it would adversely affect the rights and freedoms of
others.
If you consider that our processing of your personal
information infringes data protection laws, you have a legal
right to lodge a complaint with the ICO as supervisory
authority responsible for data protection in the UK.
To the extent that the legal basis for our processing of your
personal information is consent, you have the right to
withdraw that consent at any time. Withdrawal will not affect
the lawfulness of processing before the withdrawal.
You may exercise any of your rights in relation to your
personal data by written notice to us.
8. ABOUT COOKIES
A cookie is a file containing an identifier (a string of
letters and numbers) that is sent by a web server to a web
browser and is stored by the browser. The identifier is then
sent back to the server each time the browser requests a page
from the server.
Cookies may be either "persistent" cookies or "session"
cookies: a persistent cookie will be stored by a web browser
and will remain valid until its set expiry date, unless
deleted by the user before the expiry date; a session cookie,
on the other hand, will expire at the end of the user session,
when the web browser is closed.
Cookies do not typically contain any information that
personally identifies a user, but personal information that we
store about you may be linked to the information stored in and
obtained from cookies.
9. COOKIES THAT WE USE
We use cookies for the following purposes:
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Authentication - we use cookies to identify you when you
visit our website and as you navigate our website.
-
Status - we use cookies to help us to determine if you are
logged into our website.
-
Personalization - we use cookies to store information about
your preferences and to personalize the website for you.
-
Security - we use cookies as an element of the security
measures used to protect user accounts, including preventing
fraudulent use of login credentials, and to protect our
website and services generally.
-
Analysis - we use cookies to help us to analyze the use and
performance of our website and services.
-
Cookie consent - we use cookies to store your preferences in
relation to the use of cookies more generally.
10. COOKIES USED BY OUR SERVICE PROVIDERS
Our service providers use cookies and those cookies may be
stored on your computer when you visit our website.
We use Google Analytics to analyze the use of our website.
Google Analytics gathers information about website use by
means of cookies. The information gathered relating to our
website is used to create reports about the use of our
website. For more information on Google Analytics
cookies, see the official Google Analytics page.
We publish Google AdSense advertisements on our website. To
determine your interests, Google will track your behavior on
our website and on other websites across the web using
cookies. This behavior tracking allows Google to tailor the
advertisements that you see on other websites to reflect your
interests (but we do not publish interest-based advertisements
on our website). You can view, delete or add interest
categories associated with your browser by visiting: https://adssettings.google.com. You can also opt out of the
AdSense partner network cookie
using those settings or using the Network Advertising
Initiative's multi-cookie opt-out mechanism at: http://optout.networkadvertising.org. However, these
opt-out mechanisms themselves use cookies,
and if you clear the cookies from your browser your opt-out
will not be maintained. To ensure that an opt-out is
maintained in respect of a particular browser, you may wish to
consider using the Google browser plug-ins available
at: https://support.google.com/ads/answer/7395996.
- MANAGING COOKIES
Most browsers allow you to refuse to accept cookies and to
delete cookies. The methods for doing so vary from browser to
browser, and from version to version. You can however obtain
up-to-date information about blocking and deleting cookies via
these links:
-
Chrome;
-
Firefox;
-
Opera;
-
Internet
Explorer;
-
Safari
Mac Users; Safari iPhone/iPad
Users;
-
Edge.
Blocking all cookies will have a negative impact upon the
usability of many websites.
If you block cookies, you will not be able to use all the
features on our website.
12. OUR DETAILS
We are registered in England and Wales under registration
number 11123428 and our registered office is at 24 Middleton
Road, Morden, Surrey, SM4 6RW
Our principal place of business is at 24 Middleton Road,
Morden, Surrey, SM4 6RW.
You can contact us:
- by post, using the postal address given above
- using our website contact form;
-
by telephone, on the contact number published on our
website.
-
by email, using the email address published on our website.
13. DATA PRIVACY MANAGER
Our data privacy manager’s contact details are: [email protected]
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