What is our role in relation to your personal data?
For the purposes of GDPR & DPA laws, we, Eden Luxury Travel, are a data controller (in other words, the organisation that determines how your personal information is used).
What is my personal data and what does ‘process’ mean?
When we refer to personal data, we mean any information which relates to an identified or identifiable individual. Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties, and erasing it.
What personal data will we collect from you and why?
To enable us to respond to an enquiry, administer and fulfil your booking, or send you a brochure or other promotional material, we may need to collect personal information from you. This personal data may be obtained from you directly or through any travel agency with whom you make your booking or booking enquiry.
If you book holidays with us, we will ask you to provide certain personal data and this is likely to include:
- names and passport information for all passengers
- contact details (such as telephone number, postal and e-mail addresses) of the person making the booking
- preferences and frequent flyer club memberships
- emergency contact details
- credit / debit card or other payment information for the person making the booking
- information in respect of sensitive personal information, namely any medical conditions, disabilities, access requirements, or special dietary requirements which may affect you or anyone travelling with you – this comes within special categories of personal data (see below)
For an enquiry, the personal data we will need to process is likely to include the name and contact details of the person making the enquiry.
For a booking or booking enquiry, we will process your personal data (other than any data which comes within special categories of personal data – see below) on the basis that this is necessary for us to can fulfil our contract with you and provide you with the quality of service we strive to provide, or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject, or in order to protect your vital interests (for example, in an emergency situation).
Where you are a regular customer we may retain some of this personal information so that we can use it when you next book with us, as we have a legitimate interest to ensure our customers have the best possible experience while still ensuring your rights are protected.
If you wish to receive brochures or other marketing material from us, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address.
What are special categories of personal data?
Personal data which concerns your health or which reveals your racial or ethnic origin or your sexual orientation are special categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the booking and provision of travel arrangements.
Accordingly, information concerning any disability, medical condition or restricted mobility which may affect your travel arrangements (and related requirements) as well as dietary restrictions which may disclose your religious beliefs are special categories of personal data. We will ask for your consent to process this information at the time you make your booking or your booking enquiry.
How we share personal information
In order to make sure we run our business efficiently, comply with legal obligations, or enforce agreements, and to make sure that you get the service you expect, we will need to share your personal information as necessary.
Suppliers and other selected trusted third party business partners are likely to include the following, depending on the arrangements booked:
- transfer operators
- hotels and the providers of other forms of accommodation
- overseas ground agents
- tour managers, guides, excursion and activity operators
- credit card companies / banks in respect of payments
- service providers (such as Travelport)
The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.
We may also make personal data available to other companies who provide services on our behalf, such as mailing brochures and marketing material. We will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services, and does not collect any personal data from you in the course of performing their services.
We do not share your personal information with third parties for them to use for the purposes of sending you marketing information, or for those third parties to use your information for their own purposes.
Where will we process your personal data?
Your personal data may be processed within the UK and / or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein.
We may also process personal data outside the EEA where local laws may not provide legal protection for your information in the same way as it is applicable in the EEA. We will only send (or permit a third party to send) your personal data outside of the EEA if the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection, or the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions, and to maintain appropriate security to protect the personal data which we are satisfied they have, or we are obliged to provide the personal data to a government/public authority in order to provide your holiday.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction, or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Can we use your personal data to send you information about our holidays or other services in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to this. We will send you this information as this is necessary for the purposes of our legitimate interests in ensuring our clients have the best possible experience, whilst always ensuring that your rights are protected.
We may send you e-mail marketing where we comply with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR). PECR permits us to e-mail you information about the travel services we offer where you have previously provided us with your e-mail address in the course of entering into a contract with us for travel arrangements or enquiries for such arrangements and we wish to e-mail you marketing material about our similar services or products. You can opt out of receiving such e-mail marketing through the ‘unsubscribe’ button when we send you any e-mail marketing or by emailing firstname.lastname@example.org.
Where you have previously requested or agreed to receive information about our travel services from us by post, we may continue to send you such information in the same way until you ask us not to (which you can do by telephone, post or e-mail email@example.com or post).
You may provide your consent to receiving marketing information from us by opting to receive marketing material either on-line or by telephone. You may also choose the ways in which you are happy to receive communications from us, for example receiving information and offers by post and e-mail, but not by telephone.
How can you find out what information we are holding about you?
You are entitled to ask us (by letter or e-mail at firstname.lastname@example.org) what personal data of yours is being held or processed, for what purpose, and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information.
We promise to respond to your request without delay, and in any event within one month unless the request is complex or you have made numerous requests, in which case we may be able to extend our response time by a further two months.
What should you do if the personal data we are holding is inaccurate, out of date or incomplete?
If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within one month, or three months if the rectification request is complex.
How long can we retain and process your personal data?
We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal information.
Where your personal data has been provided for the purpose of the holiday arrangements or other services you have contracted, we are entitled to retain this data for a period of six years after those arrangements have been completed. In certain limited circumstances, we may be able to retain it for a longer period.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
Can you ask us to delete your personal data?
Yes, we can erase your personal information without undue delay where there is no good reason for us to continue to use it. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.
What should I do if I have a complaint about the processing of my personal data?
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail at email@example.com, and we will investigate and respond to you as soon as possible. If you remain dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see www.ico.org.uk.