- 1st May 2018
This Policy addresses the main obligations of Travelscoop regarding data protection. It addresses the rights of Data Subjects in respect of their Personal Data under the Data Protection Legislation.
The procedures and principles set out herein must be followed at all times by the Company and its Associates.
We are committed not only to the letter of the law, but also to the spirit of the law and we place high importance on the correct, lawful, and fair handling of all Personal Data, respecting the legal rights, privacy, and trust of all individuals with whom we deal. This Policy refers to and incorporates our Data Security Statement which is a separate document.
Last updated: 01 May 2018.
All Definitions used in this Policy can be found in a separate Definitions document, which applies across all our policies.
- The three types of user of our service;
- the information we collect about you;
- how and why we collect and use your personal information;
- why we process your personal information;
- the use of children's personal information;
- when and why we disclose your personal information;
- how you can change your permissions;
- the rights and choices you have;
- keeping your personal information secure;
- how long we will hold your information for; and
- how to contact us.
2. The three types of user
2.1 Site User
A Site user is a user who uses our Site, but does not create an account and does not sign-in to our service in any way
2.2 Registered Site User
A Registered Site User is a Site User who creates an account and signs-in to our website in order to receive a more personalised experience.
2.3 Email Subscriber
An Email Subscriber is a Registered Site User who chooses to receive our Email Newsletter service.
3. The personal information we collect
3.1 Site User
When you use our Site we collect information about your online browsing behaviour and information about the device you are using to access our Site, including your IP address.
3.2 Registered Site User and Email Subscriber
In addition to the information collected for a Site User, you must provide us with your email address in order to create an account. You may choose to also provide us with your first name, last name and gender.
4. How and why we collect your personal information
4.1 Site User
Information about our Site Users is collected on our behalf by Google Analytics, using a Google Analytics cookie. We use this information to determine how popular our Site content is, and how we can improve Site elements, such as navigation and design.
4.2 Registered Site User
Information about a Registered Site User is collected at the point of sign-up, and can be added to or amended via your Account page. Your email address forms the unique identifier for your account. Your first and last name is optional, and is only used to personalise our Site and Email. Your gender is optional, and is only used for internal reporting, insight and analysis.
4.3 Email Subscriber
Your email address is used to send our Email Newsletter. Emails are typically sent every other day. We may also send you email reminders of deals and offers that you have clicked on during the course of the day.
5 Why we process your personal information;
We only collect and use your personal information in accordance with data protection laws. Our grounds for processing your personal information are as follows:
We will only collect and process your personal information if you have consented for us to do so.
We may use and process some of your personal information where we have sensible and legitimate business grounds for doing so. Under European privacy laws there is a concept of "legitimate interests" as a justification for processing your personal information. Our legitimate interests for processing your personal information are:
- to enable you to access and use the Site;
- to communicate with you about your use of the Site as a Registered Site User (for example, when you want to change your email address we will send you an email containing a confirmation link;
- to provide Email Subscribers with the emails they have requested; and
- to improve our Site. We may use your personal information to undertake demographic segmentation and generate profiling information to help us understand what you might be interested in and for market research. We are always working to make a better Site for you and using your personal information in this way helps us to do this.?
From May 2018, you will have a right to object to our use of your personal information for these legitimate interests, including a right to object to profiling by us (see section 8 below).
6. The use of children's personal information;
We do not knowingly collect or store any personal information about children under the age of 16. If you are aged under 16 please get your parent or guardian's permission before you provide any personal information to us.
7. When and why we disclose your personal information;
We do not share or sell personal information with any third-parties except in the following cases:
7.2. If required or permitted to do so by law;
7.3. If required to do so by any court, the Financial Conduct Authority or any other applicable regulatory, compliance, governmental or law enforcement agency;
7.4. If necessary in connection with legal proceedings or potential legal proceedings;
8. How you can change your permissions
Your privacy is importance to us. All emails or other forms of communication directly from us to you will include clear instructions on how to unsubscribe. In addition to this, you can also email firstname.lastname@example.org. Section 9 below also sets out your other information rights.
9. The rights and choices you have;
You have very clear rights regarding the personal information we hold about you. These rights are:
9.1. Right to correct: the right to have your personal information rectified if it is inaccurate or incomplete;
9.2. Right to erase: the right to request that we delete or remove your personal information from our systems;
9.3. Right to restrict our use of your information: the right to 'block' us from using your personal information or limit the way in which we can use it;
9.4. Right to data portability: the right to request that we move, copy or transfer your personal information;
9.5. Right to object: the right to object to our use of your personal information including where we use it for our legitimate interests, or where we use your personal information to carry out profiling to inform our market research and user demographics. If you raise an objection we will stop processing your personal information.
We will use reasonable efforts consistent with our legal duty to provide you with your rights in accordance with data protection legislation.
If you're not satisfied with the way any complaint you make in relation to your personal information is handled by us then you may be able to refer your complaint to the relevant data protection regulator. In the UK, this is the Information Commissioner's Office.
10.3. Some third-party technology we use (eg, embedded videos, social sharing) also drop cookies to improve your experience on their sites.
11. Keeping your personal information secure
11.2 While we take reasonable precautions against possible security breaches of our website, no website or Internet transmission is completely secure and we cannot guarantee that unauthorised access, hacking, data loss, or other breaches will never occur. We urge you to take steps to keep your personal information safe (including your password) and to log out of your personal account after use. If you share your password or leave your logged-in account unattended, your personal information or privacy may be compromised. If that happens, please report it at email@example.com. You must, if possible, change your password immediately. You can do this by clicking on the 'forgotten password' link on any sign-in page and following the instructions to create a new password. We cannot be held responsible for your failure to keep your password secure.
12. How long do we keep your personal information?
13. How to contact us
If you have any queries relating to our use of your personal information or any other related data protection questions, please contact us at firstname.lastname@example.org or write to the Data Protection Officer at Travelscoop, Kemp House, 152-160 City Road, London, EC1V 2NX.
Last updated and effective as of 1 May 2018.