What personal data we collect and why we collect it

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(A) Identity Data

This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, family relationships to our other clients and gender.

(B) Contact Data

This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

(C) Financial Data

This include data relating to your means and methods of payment, such as your bank account and payment card details.

(D) Transaction Data

This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

(E) Technical Data

This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login 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 this website.

(F) Profile Data

This includes the data that we receive when you create a profile on our website and make use of that profile, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(G) Preference Data

This includes the data that we receive from you relating to your travel preferences, such as preferences as to food and drink choice, accommodation style, activities, security arrangements and general likes and dislikes in respect of your travel.

(H) Usage Data

This includes information about how you use our website, products and services.

(I) Marketing and Communications Data

This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.If you leave a comment on our site you may opt-in to saving your name, email address and website in cookies. These are for your convenience so that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

If you visit our login page, we will set a temporary cookie to determine if your browser accepts cookies. This cookie contains no personal data and is discarded when you close your browser.

When you log in, we will also set up several cookies to save your login information and your screen display choices. Login cookies last for two days, and screen options cookies last for a year. If you select “Remember Me”, your login will persist for two weeks. If you log out of your account, the login cookies will be removed.

If you edit or publish an article, an additional cookie will be saved in your browser. This cookie includes no personal data and simply indicates the post ID of the article you just edited. It expires after 1 day.

Special category data:

Health/mobility data: When you make an enquiry for a travel booking with us, we will ask you to/you may disclose any medical conditions/health issues or any restrictions on your mobility. This is to enable us (and the operators/suppliers of your holiday) to provide for your health, safety and welfare during your trip, which is our legal responsibility.  Any information of this type that you provide to us constitutes special category data under applicable data protection laws and so when you provide it to us, you give your consent to us using such information for the purpose of making your travel arrangements including our sharing of your information with the suppliers of your trip for this purpose (see section 5 Disclosure of your Personal Data).

If you choose not to disclose this information to us or your consent to use it for the outlined purposes, we may not be able to provide the services you have requested due to our legal responsibility to provide you with a safe holiday.

Religious beliefs: We will also ask you to disclose to us any dietary requirements that you have and you may also choose to disclose to us your religious beliefs if this informs your particular travel itinerary choices/interests. Religious beliefs constitute special category data. Accordingly, when you provide this information you confirm your consent to us using such information for the purpose of making your travel arrangements, including our sharing of your information with the suppliers of your trip for this purpose.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

How your personal data is collected

We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact, Financial, Sensitive and Transaction Data by filling in forms or by corresponding with us online or by post, phone, email or otherwise. This includes personal data you provide when you: apply to purchase our products and services; enquire about our goods and services; subscribe to our services or publications; request marketing to be sent to you; enquire about our community involvement; enter a competition, promotion or survey; or give us some feedback. Automated technologies or interactions. As you interact with our website, we may automatically collect Profile and Usage Data. We will also collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy (Include Link) for further details. Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below: Identity, Contact and Sensitive Data from schools or other organisations making a party booking on your behalf and carers or other healthcare providers in relation to your booking. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from data brokers or aggregators. Identity and Contact Data from publicly available sources such as social media. Technical Data from the following parties: analytics providers; advertising networks; and search information providers. 

How Your Personal Data Is used

It’s important that you understand what we’ll do with the data that we hold about you. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances: Where we need to perform the contract we are about to enter into or have entered into with you. Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Where we need to comply with a legal or regulatory obligation. Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to the collection and use of Sensitive Data and sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us. Purposes for which we will use your personal information We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest To carry out our obligations arising in connection with any contracts entered into between you and us, or between you and a third party supplier, including: (a) To communicate with you regarding your booking or other purchase (b) Manage payments, fees and charge (c) Collect and recover money owed to us (d) Resolve complaints and deal with disputes (a) Identity (b) Contact (c) Sensitive (d) Financial (e) Transaction (f) Marketing and Communications (a) Performance of a contract with you, including the use of data relating to criminal convictions and offences which may be required for VISA requirements or, for example, to secure car hire (b) Compliance with a legal obligation, including compliance with anti-money laundering legislation relating to foreign currency transactions (c) Necessary for our legitimate interests (to recover debts due to us) (d) The provision of preventative medicine and health care in relation to data relating to your health, (e) Consent in relation to the processing of Sensitive Data such as your religious or philosophical beliefs To manage our relationship with you which will include: (a) Notifying you about changes to our service, terms or privacy policy (b) Asking you to leave a review or take a survey (c) Recording telephone conversations (a) Identity (b) Contact (c) Profile (d) Marketing and Communications (a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services and for colleague training and customer service) To enable you to subscribe for our newsletter, take part in a prize draw, promotion or competition or complete a survey (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (a) Performance of a contract with you (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity (b) Contact (c) Technical (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you (a) Identity (b) Contact (c) Profile (d) Usage Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) (e) Marketing and Communications (f) Technical To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical (b) Usage Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications Necessary for our legitimate interests (to develop our products/services and grow our business) Marketing We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Promotional offers from us We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion. Third-party marketing We will get your express opt-in consent before we share your personal data with any internal or external third parties for marketing purposes. Opting out We won’t use your personal data for marketing purposes at all if you’ve told us not to. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Cookies You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy (Insert Link to your policy). Change of purpose We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 

Disclosure of your personal data 

We may have to share your personal data with the parties set out below for the purposes set out in section 4.

(A) Internal Third Parties as set out in the Glossary.

(B) External Third Parties as set out in the Glossary.

(C) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Keeping your personal data secure 

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

How long will you use my personal data for? We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us. YOUR RIGHTS Under certain circumstances, by law you have the right to: Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it. Request the transfer of your personal information to another party. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Data Protection Manager. No fee usually required You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances. What we may need from you We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it. Time limit to respond We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. 

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