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

Necessary for our legitimate interests (to develop our products and 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 send marketing material to you. The data we hold may be used to form a view on what we think you may want or need, or what may be of interest to you and to avoid redundant information.

You will receive email and text marketing communications from us if you have requested information from us or purchased services from us in the past and, in each case, you have not opted out of receiving that marketing. We may choose to opt out of receiving any marketing material by emailing gdpr@skylordtravel.com. All marketing material that we send will also have information on how you can easily opt out of receiving future marketing his material.

Third-party marketing

We will never share your data with any third-party company outside of Skylord Travel unless we have clear opt-in consent from you.

Opting out

You can ask us to stop sending you marketing communications at any time by following the unsubscribe or opt-out links on any marketing emails sent to you or by contacting us at any time.

If you to choose to opt out of receiving these marketing communications, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.

Cookies

Most modern browsers can be set to refuse all or some cookies by default. Thy can also be set to alert you when websites set or access cookies. We try to minimise our use of cookies, but parts of our site may not function properly or may not be accessible at all if you choose to refuse or disable cookies in your browser. Please see our cookie policy on our website for more information.

Change of purpose
We will only use your personal data for the purposes for which it was 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.
Disclosures of Your Personal Data

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

External Thirds Parties such us: -

·      Travel Service Providers
Airlines, hotels and transport providers who act as processors. Some are based within the EEA and some are based outside the EEA

·      Technology Service Providers
IT services, reservation systems, call centre and system administrator providers acting as processors within and outside of the EEA.

·      Government and Regulatory Bodies
HM Revenue and Customs, ATOL, ABTA, IATA and other regulators who act as both processors or joint controllers and are in based in the UK.

·      Our Professional Advisors
Lawyers, bankers, auditors and insurance companies who act for Skylord Travel plc. These are based in the UK and act us both processor and joint controllers.

·      International Transfer of Your Data
Some of our third-party service providers are based outside the EEA so some of your data maybe be transferred and processed outside of the EEA.

If you have requested and booked travel arrangements outside of the EEA, your personal data will have to be transferred to our suppliers outside of the EEA to be able to fulfil your travel arrangements.

Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.

For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
Data Security

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
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.

By law we must keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for legal and tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Glossary of Terms

Lawful Basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are listed below: -

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
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 continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

·      if you want us to establish the data's accuracy;
·      where our use of the data is unlawful but you do not want us to erase it;
·      where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
·      you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required
There will be no fee payable to exercise any of your rights in regard to your personal data. However, if we deem your request to be unreasonable, unfounded, repetitive or excessive we may charge a fee to compensate us for the costs involved in processing your request. In these cases, we may also refuse to comply with your request.

What we may need from you
Before processing a request, we will need to confirm your identity and may request specific information from you. This is a security measure to make sure we do not disclose your personal data to a third party who does not have a right to receive it.

Time limit to respond

We try to respond to all legitimate requests within 30 days. On some occasions it may take us longer than this, especially if your request is particularly complex or you have made multiple requests. In cases like this we will keep you informed of any delays.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer.

(a) Identity;
(b) Contact.

Performance of a contract with you.

To process and deliver your booking including: (a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.

(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications.

(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to leave a review or take a survey.

(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 and to study how customers use our products/services).

To enable you to partake in a prize draw, 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
(e) Marketing and Communications
(f) Technical

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)

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

Necessary for our legitimate interests (to develop our products and services and grow our business)

Top Destination

Top Flights

Beat My Quote

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer.

(a) Identity; (b) Contact.

Performance of a contract with you.

To process and deliver your booking including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us.

(a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications.

(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey.

(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 and to study how customers use our products/services).

To enable you to partake in a prize draw, 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 (e) Marketing and Communications (f) Technical

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)

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

Necessary for our legitimate interests (to develop our products and services and grow our business)

Top Destination

Top Flights

(a) Identity;
(b) Contact.

To process and deliver your booking including: (a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.

(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications.

(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which will include: (a) Notifying you about changes to our terms or privacy policy;
(b) Asking you to leave a review or take a survey.

(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 and to study how customers use our products/services).

(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).

(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.

(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical

(a) Technical
(b) Usage

(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile