Scope of this policy
Who are we?
We are Success Tours Limited, a company incorporated in England and Wales under company number 1476847. Registered Office: 14 New Hythe Lane, Larkfield, Aylesford, Kent, ME20 6AB
Who is the Data Controller?
How to contact us
By email: firstname.lastname@example.org
By phone: 00 44 (0)1225 764205
By post: Oak House, Epsom Square, White Horse Business Park, Trowbridge, BS14 0XG
Success Tours Limited comply with UK & EU Data Protection Legislation – The General Data Protection Regulation, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
The Information Commissioner’s Office (also known as the “ICO”). The ICO is an independent body and the UK’s supervisory authority for information rights.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
What types of information do we collect about you?
The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we collect any of the following:
Details about you:
- Your name, email address, address, telephone number, date of birth.
- Your hotel room preferences, meal and other travel preferences or dietary requirements and, if necessary, information about your health to the extent that it’s relevant to your fitness to fly, your holiday itinerary or to provide you with special assistance.
- Identification documents/information.
- Travel insurance details.
- Payment details.
Details about the services you arrange with us:
- Your travel details, including details of your travel itinerary, where you are travelling from and to, your booking information and any onward travel details if relevant.
- Any upgrade information.
- Travel insurance details.
- Details of any special assistance you might need from us and any other information relevant to enable us to provide you with the services that you’ve arranged with us.
Financial & transactional:
- If you book services we will require your payment details, which may include billing addresses, credit/debit card details and/or bank account details. Rest assured that no credit/debit card details are retained by Success Tours.
- We will collect information related to your transactions with us, including the date and time, the amounts charged and other related transaction details
Your interactions with us:
- Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or our website, over the phone, or simply verbally to our people), when you get in touch via social media or when you attend any events we host.
Please note: Should you provide us with personal information for someone other than yourself, should this be a travel companion or your next of kin, you are responsible for obtaining their consent prior to sharing this personal information with us.
Please note: Parental consent is required for us to process personal details for any individual who is under 18 years of age, you are responsible for obtaining this consent prior to sharing this personal information with us.
HOW WE USE YOUR INFORMATION
For what purposes do we use your information?
We’ll use your information for a variety of different purposes, some of which will depend on the services that you engage us for. These include:
- To manage your booking with us. We will use your information to provide you with any services that you request or purchase from us on the basis of performing our contract with you) and to provide you with any special assistance (where you provide your consent).
- To send you service communications and support services. We will use your information to send you any communications relevant to the services you’ve requested or purchased from us. We will also provide you with customer service and support, deal with your enquiries, scheduling changes, complaints, comments or observations shared with us (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with customer service).
- To send you marketing communications. We will use your information to keep you up to date with the latest news, events, offers, sales, brochures, promotions and competitions that we think might be of interest or relevant to you (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so). Please see the “MARKETING” section below for more information.
- To improve our customer service (on the basis of our legitimate interest in improving our customer service)
- To ensure security and protect our business interests. In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so).
- To process and facilitate transactions with us. We will use your information to process transactions and payments for bookings or purchases and to collect and recover money owed to us (on the basis of performing our contract with you and on the basis of our legitimate interest to recover debts due)
- To enable us to interact with you on social media platforms. These include Facebook, LinkedIn, Twitter, Instagram and YouTube, for example, posting status updates, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (on the basis of our legitimate interest in promoting our brand and communicating with interested individuals);
- To comply with our legal obligations, policies and procedures. In certain circumstances, we will need to use your information to enable us to comply with our policies, procedures and legal obligations (for example to comply with any court orders or subpoenas), to enforce our legal rights, and to protect the rights, property and safety of staff, customers and others. This includes sharing your information with our lawyers, auditors, technical advisors, law enforcement and other regulatory bodies where necessary (on the basis of our legitimate interests or to comply with a legal obligation).
On what grounds will we process your information?
We will use your information for the purposes listed above, either:
- For the performance of your contract with us and the provision of our services to you.
- To comply with any legal obligations.
- For our legitimate interests (we explain what we mean by this below).
- To protect your vital interests.
- With your consent.
- For establishing, exercising or defending legal claims.
- For reasons of substantial public interest.
What do we mean by “legitimate interests”?
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers. This includes but is not limited to:
- Providing you with customer service.
- Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing and serving you with advertising that is relevant and likely to be of interest to you.
- Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours, and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as when we have your consent, or we have a legal obligation to use your information in that way). If you have any concerns about our processing please refer to the “YOUR RIGHTS” section below.
As we outline in “YOUR RIGHTS” section below, you have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above and provide you with the level of service that we pride ourselves on.
WHO WE SHARE YOUR INFORMATION WITH
In connection with the purposes and on the lawful grounds described above, we share your personal information with the following third parties:
- Travel service suppliers that we work with to provide your booking and our other services to you. These will be detailed on your booking itinerary and full contact details are available on request. On occasion these suppliers may be located outside of the EEA.
- Group Leaders, when tour bookings are made directly with Success Tours rather than with the Group Leader.
- The Albatross Group of Companies. Success Tours Limited are part of the Albatross Group of Companies and as such are supported by the Group IT and Accounts teams.
- Airports, immigration / border control and/or other government authorities, we will provide this information only where we are required to do so.
- Regulators and governmental bodies. We share your information with HM Revenue & Customs, regulators, governmental bodies and other authorities who require reporting of processing activities in certain circumstances.
- Courts or advisors. We share your information with other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
Where we do share your information with third parties, we will require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).
When you’ll hear from us:
We will keep you up to date with our latest tours, offers, partnerships, sales, promotions, competitions that we think might be of interest / relevant to you if you have indicated that you are happy to receive marketing communications from us – that is, if you have signed up (opted-in) to receive marketing communications from us and have not later told us that you don’t want to hear from us.
If you no longer want to receive marketing from us you can opt out or unsubscribe at any time by:
- Following the “unsubscribe” link contained in any marketing communications that you receive from us.
- By contacting us using the details in the “Contact Us” section above.
Success Tours distribute electronic marketing through the online marketing platform MailChimp.
Overview of your rights:
You have certain rights in respect of the personal information that we hold about you, including:
- The right to ask us not to process your information for marketing purposes.
- The right to request access to the information that we hold about you.
- The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect.
- In certain circumstances, the right to ask us to stop using information about you.
- The right to withdraw consent that you have provided to us to use your personal information.
- The right to object to our using your information on the basis of our legitimate interests (see above to see when we are relying on our legitimate interests) and there is something about your particular situation which makes you want to object to processing on this ground.
- The right to receive a copy of any information we hold about you (or request that we transfer this information to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances.
- The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
- The right to lodge a complaint about us to the UK Information Commissioner’s Office or the relevant authority in your country of work or residence.
Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.
To exercise any of these rights please contact Success Tours as detailed above.
WHERE IS YOUR INFORMATION?
The personal information that you share with us is only retained for as long as we have a legitimate business need to do so or for as long as is required to comply with any legal obligations.
Your personal information is stored:
- Securely on the secure Albatross Group servers.
- On the TopicPlus+ booking system operated by TAS Solutions, The Attic, South Suite, Fullbridge Mill, Maldon, Essex, CM9 4LE.
HOW WE LOOK AFTER YOUR INFORMATION
Our security measures
We strive to constantly keep our security practices under review to make sure that we’re keeping your information as safe as possible. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. For example, we:
- Ensure the physical security of our offices, warehouses and other sites.
- Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions.
- Are a “PCI DSS” compliant company, meaning that we apply certain high standards of security in respect of your payment information.
- Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work.
- Maintain internal policies and deliver data protection and confidentiality training to make sure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.
HOW LONG WE KEEP YOUR INFORMATION FOR
We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims.
We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example:
- We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis unless we are required to retain it for evidential or legal purposes.
- By archiving and deleting information that is no longer required on a regular basis.
- We retain a suppression list of individuals who no longer wish to be contacted by us indefinitely. We need to keep this information to comply with their wishes not to contact them.
However, if you’d still like to make a formal complaint or have concerns regarding the ways in which we use your information, you can contact the Information Commissioner’s Office.