Skylord Travel Privacy Policy - GDPR Skylord Travel Privacy Notice This version was
last updated on 10 Jan 2019. Skylord Travel respects your
privacy and is committed to protecting your personal data. This privacy notice
will inform you as to how we look after your personal data when you visit our
website (regardless of where you visit it from) or when you otherwise provide
personal data to us via other means (such as over the telephone) in order to
purchase any travel arrangements from us, and tell you about your privacy
rights and how the law protects you. Please also refer to the Glossary
that we have set out at the end of the Policy, if there is any terminology used
in this privacy notice that you are unfamiliar with or that you don’t fully
understand. Important
Information and Who We Are Purpose of this
privacy notice This privacy notice aims to give
you information on how Skylord Travel collects and processes your personal
data, including any data you may provide through this website or via any other
means (such as over the telephone or in person when you visit one of our shops)
when you book travel arrangements with us, when you sign up to our newsletter,
when you take part in a competition, fill out an online customer service
request form, use our online Live Chat function or contact us via social media channels, etc. This website is not intended for
children and we do not collect data in relation to children. It is important that you read this
privacy notice together with any other privacy notice or fair processing notice
we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using
your data. This privacy notice supplements the other notices and is not
intended to override them. Controller Skylord Travel Plc, a company
registered in England & Wales with company registration number 02321377 and
registered office address of 208 Field End Road, Eastcote, Middlesex, HA5 1RD trading as "Skylord
Travel", "SkyRes", "Cheapest2” and "Skylord Business
Travel", is the data controller and
responsible for your personal data (collectively referred to as "Skylord
Travel" "we", "us" or "our" in this privacy
notice). We have appointed a data privacy
manager who is responsible for overseeing questions in relation to this privacy
notice. If you have any questions about this privacy notice, including any
requests to exercise your legal rights,
please contact the data privacy manager using the details set out below. Contact Details Full name of legal entity: Skylord
Travel
Name of data privacy manager: Ujjwal Sehgal
Email address: gdpr@skylordtravel.com
Postal address: 208 Field End Road. Eastcote. Middlesex. HA5 1RD. You have the right to make a
complaint at any time to the Information Commissioner's Office (ICO), the UK
supervisory authority for data protection issues. Their website is ico.org.uk and contact details can be found here. Should you have a complaint or
queries we would appreciate the opportunity to deal with any of your concerns
before you approach the Information Commissioner's Office so please contact us
using the contact details above. We will acknowledge your query with 24 hours
aim to reply to your query within 14 days. Your duty to inform
us of changes It is important that the personal
data we hold about you is accurate and up to date. We would request you to keep
us informed if any of the details you provide to us should change, during your
relationship with us. You can do this by emailing gdpr@skylordrravel.com. Third-party links This website may include links to
third-party websites, plug-ins and applications. By clicking on those links or
enabling those connections may allow third parties to collect or share data
about you. We do not control these third-party websites and are not responsible
for their privacy statements. If you do leave our website, we advise you to
read the privacy notice of every website you visit. The Data We Collect About You 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 follows: (A) Identity Data
This includes data relating specifically to your identity, such as your first
name, last name, marital status, title, date of birth and gender. (B) Contact Data
This includes data relating to how we my contact you, such as your address, payment
billing address, email address and contact numbers (mobile and landline). (C) Financial Data
We do not store any credit card data or bank account information. When a
payment is made online the credit card information entered is passed directly
and securely to the merchant facilities provider (Braintree Payments www.braintreepayments.com). We do not store bank account information,
but this information may be visible and stored by our bank (Barclays Bank Plc)
when a transfer is made in to our account (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) Usage Data
This includes information about how you use our website, products and services. (G) Marketing and
Communications Data
This includes your preferences in relation to whether 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. Special Categories
of Personal Data We may collect the following
special categories of personal data about you and pass these on to an airline
supplier, hotel supplier, hotel or tour operator Details about your: - · Dietary requirements which may disclose your
religious or philosophical beliefs; · Health information may be required for any special
requests with an airline or supplier · Passport information may be required to complete a
booking with an airline We collect and process the above
data only where it is strictly necessary to do so in order to deliver the
travel arrangements that you have purchased. Furthermore, we will only collect
and process the above special categories of sensitive personal data where you
have provided us with your explicit consent to do so. You are not under any obligation
to consent to us processing your sensitive personal data. However, without your
consent, we won’t be able to make the necessary arrangements to provide the
travel arrangements that you have booked or are attempting to book. As a
result, if you do not provide your consent, we will be unable to proceed with
your booking. If you are happy to consent to our
use of your sensitive personal data, you will also be able to withdraw your
consent at any time. However, as this will prevent us from providing the travel
arrangements you have booked, we will be required to treat any withdrawal of
consent as a cancellation of your booking and the cancellation charges in the
relevant Booking Terms & Conditions will become payable. 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. In other words, where we require
details from you in order to provide you with your chosen travel arrangements,
if you do not provide us with the necessary details then we will not be able to
provide the services you have booked or are attempting to book. In this case, depending upon when
you fail to provide the necessary data, we may either not be able to process
your booking or we may have to cancel your booking, in which case we will treat
this as a cancellation by you and it will be subject to the relevant Booking
Terms & Conditions. We will notify you if we are unable to process a
booking or are required to cancel a booking for this reason. How Your Personal Data is
Collected We use different methods to
collect data from and about you, including through: (A) Direct
interactions
The following types of data may be collected from you when corresponding with
us. This includes Identity, Contact and Financial Data. When you fill online
forms, speak to us in our office, emails us, send post to us or call us on the
phone. This also includes personal data you provide to us when you: · make a flight, hotel or holiday booking · request a quote or make a general enquiry · request to subscribe to our newsletter · request brochure or marketing material to be sent
you · enter a competition quiz or fill in a questionnaire · provide feedback on us (B) Automated
technologies or interactions
As you interact with our website, we may automatically collect Technical Data
about your computer equipment, browsing actions and any browsing patterns.
We collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other
websites employing our cookies. Please see our cookie policy, available on our
website for further information. (C) Third parties
We may receive personal data about you from various third parties as set out
below: Technical Data from the following
parties: analytics providers such as Google
Analytics based outside the EU; advertising networks such as
Facebook based inside the EU; and search information providers such
as Google, Yahoo and Bing based outside the EU; Contact, Financial and Transaction
Data from providers of technical, payment and delivery services such as Braintree
Payments and Barclaycard based inside the EU HOW WE USE YOUR PERSONAL DATA Your personal data is only use when
and in way that the law allows us to. Most commonly, we will use your personal
data in the following circumstances: Where we need to perform the contract
that 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 sending direct marketing communications to you via email or text
message. You have the right to withdraw consent to marketing at any time by contacting by email gdpr@skylordtravel.com or unsubscribing from
any marketing emails. Purposes for which
we will use your personal data 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. Please contact
us if you need details about the specific legal grounds we are relying
on to process your personal data where more than one ground has been set out in
the table below.
Purpose/Activity
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Type of data
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Lawful basis for processing including
basis of legitimate interest
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To register you as a new
customer.
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(a) Identity;
(b) Contact.
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Performance of a contract with
you.
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To process and deliver your
booking including: (a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
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(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications.
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(a) Performance of a contract
with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
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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.
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(a) Identity;
(b) Contact;
(c) Profile;
(d) Marketing and Communications.
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(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).
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To enable you to partake in a
prize draw, competition or complete a survey.
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(a) Identity;
(b) Contact;
(c) Profile;
(d) Usage;
(e) Marketing and Communications.
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(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).
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To administer and protect our
business and this website (including troubleshooting, data analysis, testing,
system maintenance, support, reporting and hosting of data).
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(a) Identity;
(b) Contact;
(c) Technical.
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(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.
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To deliver relevant website
content and advertisements to you and measure or understand the effectiveness
of the advertising we serve to you
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(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
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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)
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To use data analytics to improve
our website, products/services, marketing, customer relationships and
experiences
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(a) Technical
(b) Usage
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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)
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To make suggestions and
recommendations to you about goods or services that may be of interest to you
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(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
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Necessary for our legitimate
interests (to develop our products and services and grow our business)
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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.
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