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.
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.
Full name of legal entity: Skylord Travel
Name of data privacy manager: Ujjwal Sehgal
Email address: firstname.lastname@example.org
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 email@example.com.
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.
(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 firstname.lastname@example.org 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.
||Type of data
||Lawful basis for processing including basis of legitimate interest
To register you as a new customer.
Performance of a contract with you.
To process and deliver your booking including:
- Manage payments, fees and charges;
- Collect and recover money owed to us.
- Marketing and Communications.
- Performance of a contract with you;
- Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include:
- Asking you to leave a review or take a survey.
- Marketing and Communications.
- Performance of a contract with you;
- Necessary to comply with a legal obligation;
- 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.
- Marketing and Communications.
- Performance of a contract with you;
- 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).
- 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);
- 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
- Marketing and Communications.
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
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
Necessary for our legitimate interests (to develop our products and services and grow our business)
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 email@example.com. All marketing material that we send will also have information on how you can easily opt out of receiving future marketing his material.
We will never share your data with any third-party company outside of Skylord Travel unless we have clear opt-in consent from you.
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.
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.
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.
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
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.