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Privacy Policy

PRIVACY POLICY

 PROCESSING ACTIVITY

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  • Direct marketing activities including tracking, profiling, segmentation, and communication across multiple channels, see section 8.8

  • Record keeping and reporting, see section 8.6

  • Statistical analysis of customer data, see sections 8.7 & 8.9

  • Provision of customer data to insurance providers, border authorities & other law enforcement agencies, see sections 11.4 & 11.7

  • Processing of guest preferences and other information volunteered by the guest prior to a trip, see section 8.3

  • Processing of customer data as part of prize draws, competitions, sweepstakes, and surveys, see sections 6.4 & 6.5

  • Processing of customer data in the course of administration and maintenance of our websites and systems, see sections 6.8 & 8.7
     

BASIS FOR LEGITIMATE INTEREST

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  • Legitimate interest in promoting relevant services and products based on your relationship and interaction with us

  • Legitimate interest in understanding and improving our business

  • Legitimate interest in understanding and responding to customer behaviour and preferences

  • Legitimate interest in protecting and maintaining the safety of our guests and employees; legitimate interest in taking appropriate legal action in case of disputes

  • Legitimate interest in personalizing and improving the delivery of our services and products

  • Legitimate interest in engaging with our customers and promoting our products

  • Legitimate interest in running our business and improving our systems

  • There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.

  • For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.

  • We will adopt an aggregate data model that allows us to derive aggregated data from your personal information. Aggregated data is not considered personal data by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.

  • However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.

  • We will not repurpose sensitive or special category data without a lawful basis for doing so and where we rely on Legitimate Interest; will ensure we conduct legitimate interest assessments (see section 3) and data protection impact assessments DPIA, prior to carrying out the proposed processing activity.

  • booking or enquiring about booking travel services with or through us; or

  • the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); or

  • customers or potential customers or recipients of travel services that can be booked with or through us.

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We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

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5.2 Examples of who this policy covers

We include in this privacy policy personal data we process relating to:

(1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);

(2) individuals in respect of whom any enquiry or booking is made with us by an agent;

(3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;

(4) individuals whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

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5.3 When we are data processor only

Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data on their instructions.

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5.4 Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, and any such individual whose personal data we process from time to time.

When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:

(1) all such products and services which we supply or operate ourselves (including where we sub-contract); and

(2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

6.1 Data concerning you as an individual

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We may collect the following:

  • name,

  • age,

  • gender,

  • address,

  • telephone,

  • mobile,

  • fax,

  • e-mail,

  • Social networking contact details, your social posts about any of our trips and travel experiences.

  • photographs,

  • proofs of identity and address, copies of passports, driving licences, and utility bills,

  • card and other payment details, and financial information,

  • health information relevant to your planned travel and travel insurances held,

  • results of searches carried out against you (such as to verify your identity, address, and credit status),

  • your preferences,

  • Frequent flyer or travel partner programme affiliation and member number.

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You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

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6.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you:

  • business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.),

  • your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and

  • your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

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6.3 Enquiry and Booking Information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:

  • records of enquiries and searches for holiday and travel products made by or on your behalf,

  • details of your personal interests,

  • needs and other data relevant to your enquiry;

  • details of results, quotes, proposals, estimates and other information given in response to enquiries;

  • details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about;

  • details of the passengers / holidaymakers travelling;

  • details of the provider of the travel services (e.g. tour operator);

  • dates and times of travel;

  • price;

  • payment details (including card details);

  • passport information and visa information;

  • foreign exchange requirements and arrangements; and

  • Sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.

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6.4 Survey Information

Information collected or generated out of any surveys we conduct.

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6.5 Competition Information

Information collected or generated out of any competitions or promotions we run.

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6.6 Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

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6.7 Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.

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6.8 Website Usage Information

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

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This information may include: 

  • your IP address (a unique identifier allocated to your computer for your connection to the internet);

  • your computer device details (PC, tablet, smartphone, watch etc.);

  • the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;

  • your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc);

  • your time-zone;

  • your browser plug-ins;

  • any web-page you came from, identified as the referrer web page address by your web browser;

  • cookies (as per our cookie policy);

  • identifiers assigned to you by third-party advertising providers and web beacons you interact with;

  • page response times;

  • download error;

  • pages and parts of pages you visit;

  • usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.;

  • services and products you viewed;

  • length of visit to website and pages;

  • page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

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This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

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  • This information may also include:

  • data inputted into forms and fields;

  • registrations for any accounts,

  • forum,

  • feedback mechanism,

  • social functionality,

  • -newsletters or other features of our site;

  • usernames and passwords,

  • log-in / out history, and settings;

  • actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review, or other social functionality on our website.

  • Such information will be treated as personal data and processed according to this privacy policy.

7.1 Visiting our website

By visiting and using our website you or your computer may provide personal data. This includes:  information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. This is more detailed in our cookie policy.

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7.2 Data you provide

Your personal data will include data you provide (or later amend), whether:

  • from correspondence with you;

  • -verbally to us over the phone or in person;

  • by filing in any field or form on a website;

  • by filling in any printed form we provide you with;

  • by e-mail;

  • from documents you provide us with; and

  • from updates to any information you provide to us from time to time.

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This includes when you:

  • register or subscribe for any service, account, members, or loyalty program,

  • make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise;

  • send us your comments or suggestions;

  • subscribe to any newsletter or other publication;

  • and request sales and advertising information, including brochures.

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7.3 User Generated Content (UGC)

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let Trafalgar Tours and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as: 

  • Print materials

  • on our website

  • email activities

  • social posts

  • images on our trips

  • provide images to our trade partners to use on their websites, email marketing and other marketing initiatives

  • make available in our content feeds

  • We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods

  • Any other information provided to us by or in relation to you which concerns you as an individual.

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7.4 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from:

  • providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries;

  • credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations;

  • Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

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7.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:

  • in connection with responding to and dealing with any enquiry, booking or complaint; or

  • in performing any booking or other contract with you; or

  • through the analysis of your personal data; or

  • data gained from your use of our website according to our cookie policy.

We may record telephone calls with you for training and quality purposes.

8.1 Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites.  This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

 

8.2 Provide information and respond to enquiries

To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

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8.3 Bookings and other contracts

To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

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8.4 Payments

To collect and make payments due and administer our accounts.  This is necessary for the preparation of any contract between us.

8.5 Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

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8.6 Record Keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.  This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

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8.7 Manage and improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;

  • to carry out surveys and analyse the results;

  • to run promotions and competitions;

  • undertake product or customer research/development;

  • to assist us in and help us to improve our sales;

  • to carry out other business development and improvement activities;

  • to provide training to our staff, sub-contractors and suppliers;

  • editorial, advertising, and marketing processes, including sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;

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For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.  This is done on the basis of our legitimate interests in ensuring our business runs efficiently.

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8.8 Direct marketing

To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you.  We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 10.1 for the types of products we may market to you this way.

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8.9 Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

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8.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.

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8.11 Consequences of Not Providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.

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