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Privacy Policy

Privacy Notice                                                                                       Last Updated Feb 2021

We control all of the data that we obtain from and about you. We understand and respect the importance of your privacy and we are committed to the fair and transparent processing and safeguarding of your personal data. In providing our services to you, we must collect personal data from you and make subsequent use of it as detailed below.

 

This Privacy Notice covers all platforms through which we offer travel-related services, this includes our Website, and where you interact with us on social media such as Facebook (in which case you should also refer to those social media sites' privacy notices).

 

Our website is hosted by Vibe and Vibe data is held in the UK and during Vibe's internal processing of information, data does not leave the UK.

 

We will only collect, process, use, share and store your personal data where we are satisfied that we have an appropriate legal basis to do this. In most cases this is because we need to perform your holiday contract or take steps to engage in that contract with you; but it could also be where you have given us your specific consent to the use of your data to comply with a relevant legal or regulatory obligation that we have, or for our legitimate commercial interests as a commercial organisation. The policy below sets out the legal basis for our use of your personal data in each relevant situation. 

 

What Data will we collect?

When you book a holiday with us, you will be required to provide us with certain data, including your name, address, e-mail address and phone number and payment information. 

If you start to fill in a booking form but don’t complete and submit it, we will use your data (which we will have collected using cookies) to check in with you as to whether you need any assistance and whether you would like to complete your booking. For more information about how we do this (and how to prevent this if you wish to do so), please see our Cookie Statement, here

There are also other instances when you will provide us with data, for example if you submit our Contact US form, sign up for alerts and/or updates, register to use our Website or enter one of our competitions or complete a survey. 

 

Personal Data you give us about others

When you are travelling with others or booking a holiday for someone else, you will need to give us personal data about them when making the booking, for example their name and age. The responsibility is yours to ensure that anyone / everyone who you have provided personal data about is fully aware and happy for you to do so and is aware of how we use and process their data. 

 

 

Personal Data we collect automatically

When you visit our Website, even if you do not complete the process of making a booking, we will automatically collect certain data, such as your IP address, the date and time you accessed the Website, the hardware, software, or internet browser you use and data about your visit, including pages you viewed and interaction data. 

If you are using a mobile device, we may collect data that identifies your mobile device, location details and any specific settings. 

For more information, please see our Cookie Statement, here

 

What do we do with your Data?

Once we have collected the data about you, it will be used for the following purposes:

  • Bookings: we will use your personal data to provide you with the services that we sell, which may include flights, hotels, transport, and other ancillary products. For this we need certain data about you, so we can fulfil our obligations contained in the contract that you enter into with us when you make a booking and to pass on to the providers of the services of your travel arrangements. 
  • Engagement with you in relation to your holiday: We will use the contact data you have previously shared with us to engage with you in relation to your holiday and to provide you with data relevant to said holiday. For example, any additional helpful data about the destination to which you are travelling, security alerts, administrative messages about your holiday and emails to remind you to fill in your any holiday pre travel paperwork.

  • User Accounts: The data that you provide when you interact on our website will allow us to provide you with services including the ability to manage your bookings, personal settings, and access to special offers.

  • Personalisation: We will use data we hold about you, such as the products and services you have purchased from us in the past, to enable us to show you the products and services we think you will like on our website and share these with you, such as the recommended deals and special offers we put to you. For example, we will save your searches to tailor future searches you make to your needs.

  • Customer Services: You are free to contact us about our services at any time, whether this is a general query, a question about your booking or to report a problem on our website. This can be done on our Website, submitting our Contact Us form, by telephone or via social media. We will use the data that you have provided to help us address your query and any questions and respond to you. If you contact us by telephone, your call may be recorded for quality control and training purposes, but we will always ask for your consent before recording communications for these purposes.

  • Marketing: Where you have interacted with us and you have not opted out (or in any other case, if you have opted in to receive marketing by e-mail or text message), we may contact you by e-mail or text message with data about other goods and services that we offer that are similar to those that you have already purchased or enquired about and we think may be of interest to you based on the data we hold about you. We may also use your contact details to contact you by phone or post with details of products and services that we think may be of interest to you (unless you have told us you don't want to receive these communications, or you are registered with the Telephone Preference Service).

  • Promotional: If you participate in our promotions (such as surveys or competitions) we will use the data you provide to administer these activities.

  • Corporate transaction: We may use your data in connection with a corporate transaction such as the sale of a subsidiary or a division, merger, consolidation, or asset sale.

  • Improving our services: There may be times when we will use your data to help us improve the services we offer. These may include:

    • analysing your recent visits to our website and how you move around different sections of our website for analytics purposes, so we can understand how people use our website, and there make it more intuitive.

    • sometimes we may send data about our website and users in aggregate, anonymised or pseudonymised form to third parties for them to provide these services to us – this is explained in more detail under "When do we share your data with third parties?" below.

    • troubleshooting, data analysis, testing, research and for statistical and survey purposes by us, all of which helps us to provide the best service that we can.

 

The data controller of the personal data referred to in this Privacy Notice is Travel Seen, trading as The New Travel Group, a limited liability company registered at The Salt Warehouse | Sowerby Bridge | West Yorkshire | HX6 2AG

 

Legal basis for processing personal data

Our legal basis for collecting and processing the personal data described above will depend on the personal data concerned and the specific context in which we collect it.

We will normally collect personal data from you under the following legal bases:

  • Performance of a contract: If we have obligations under a contract with you, we will use your data to perform our obligations to you. For example, when you make an online booking on our Website, we will use the data provided by you when making the booking, to complete and process the reservations with the relevant third-party suppliers.

  • Consent: You will be asked to consent to us providing you with marketing data and if you give us this consent, we will rely on this when contacting you with marketing data by e-mail and text message (although please note that in limited circumstances we are allowed to send marketing data to you without your consent). You can opt-out of receiving marketing communications from us at any time by contacting us using the details at the end of this policy.

  • Legitimate interests: We will use your data for our own legitimate interests, for example, to provide you with the best suitable content on our Website, to improve and promote our services and for our own administrative purposes, including creating and maintaining our records of our relationship with you.

  • Legal requirements/vital interests: In some cases, we will have a legal obligation to collect personal data from you (for example, for us to comply with tax laws which require us to collect and retain records of products and services that we sell) or where we need the personal data to protect your vital interests or those of another person (for example, if you are involved in an emergency and we need to provide the details which we hold about you to the emergency services).

 

How will your Data be processed?

Any data that we hold about you will be stored on our secure servers and all payment transactions are encrypted. Only authorised personnel are permitted to access personal data in line with business requirement. We will always do our best to protect your personal data, however, no data transferred over the internet can be guaranteed to be completely secure and you provide your data at your own risk.

Your credit card details are required as part of the booking process and we will only store the last 4 digits and an authorisation token. In the case of some of the low-cost airlines, we will use the payment details you provide to purchase the flight seats on your behalf.

The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"), including (in some instances) where we transfer your data to our suppliers so that they can assist us with providing our services to you. Where your data is transferred outside of the EEA, we will take steps to ensure that the data receives the same level of protection as if it remained within the EEA, including by entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification schemes such as the EU-US Privacy Shield. You have the right to details of the mechanism under which your data is transferred outside of the EEA – for this data, please contact us using the details set out under "How can you contact us?" below.

When do we share your data with third parties?

There will be certain circumstances where we will share your personal data with parties outside of Travel Seen. The third parties who we share your personal data with include:

  • Our supplier partners: If you make a booking with us, it is necessary for us to share your reservation information with relevant third parties, such as hoteliers, airlines, insurers, and ground-handling agents, to complete your booking. Such information may include your name, contact details, payment details, the names and ages of any guests travelling with you, along with any preferences or special circumstances you have shared with us when you made your booking. If you contact us with a query about your booking, we may have to pass this on to our supplier partners, as they may be better placed to help and support you.
     
  • Our group companies: Your details may be shared with sister companies in our travel group who process data for purposes that are described in this Privacy Notice for analytical purposes or to support the services that we provide to you.
     
  • Third party service providers: This includes anyone who provides services or functions on our behalf, and includes credit card processing, business analytics, advertising, administration of competitions and promotions, collection of customer feedback and customer service. We use these service providers to process your data on our behalf, this may be to send out marketing material or to collate data that can be analysed to improve our service. They have access to and may collect data only as needed to perform their functions and are not permitted to share or use data for any other purpose. Where we provide data to third party service providers for them to provide data analysis or statistical services for us, we will only ever send them aggregated, anonymised or pseudonymised data.
     
  • Payment Providers and other financial institutions: If you request a chargeback for your booking, it may be necessary for us to share certain reservation details with the payment service provider and the relevant financial institution so they can handle the chargeback. This may include a copy of your booking confirmation or the IP address that was used to make your reservation.
     
  • Any competent law enforcement body, regulator, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights (including to investigate any suspected fraudulent or other criminal activity), or (iii) to protect your vital interests or those of any other person.
     
  • Potential Buyer (and its agents and advisers) in connection with any proposed purchase, merger, or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice.
     
  • Any other person (with your consent to the disclosure).

 

Any data that is collected from you directly by hotels or other suppliers or which you share through social media platforms such as Facebook is not covered under this Privacy Notice and we would urge to check their own privacy policies before handing over any of your personal data.

Data protection and insolvency

In the event of our insolvency we, or any appointed insolvency practitioner, may disclose your personal data to the CAA so that they can assess the status of your booking and advise you on the appropriate course of action under any scheme of financial protection. The CAA’s General Privacy Notice is at https://www.caa.co.uk/Our-work/About-us/General-privacy-notice/.

Retention of your personal data

When we have no ongoing legitimate business need to process your personal data (for example, to provide products or services to you or to retain records to manage any claims which you or we may have in respect of the products and services we provide to you), we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.

Your rights in relation to your personal data under GDPR (General Data Protection Regulation)

Your rights are enhanced under GDPR. GDPR came into force on 25th May 2018.

Your other rights under GDPR are to:

  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continue to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your 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 Data for direct marketing purposes.

  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

  • Request the transfer of your Personal Data to another party.

If you want to request erasure of your Personal Data, object to the processing of your personal data, or request that we transfer a copy of your Personal Data to another party, please contact us by emailing contactus@travelseen.co.uk

 

How do we treat personal data of children?

Our Website is not intended to be used by children under 18 years of age. We only process data about children with the consent of the parents or legal guardians.

Changes to our Privacy Notice

We may at any time be required to update this Privacy Notice in response to changing legal, technical, or business developments. When that is the case and we update our Privacy Notice, we will take all considered measures to inform you, in line with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

How to contact us?

If you have any questions about this Privacy Notice or wish to exercise any of your data protection rights, please contact us: contactus@travelseen.co.uk

Post: Should be sent for the attention of the Data Protection Officer to:

Travel Seen

The Salt Warehouse

Sowerby Bridge

West Yorkshire

HX6 2AG