PRIVACY POLICY

 

INTRODUCTION  

 

Welcome to Advantage Holidays’ privacy policy. Advantage Holidays respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you book our holidays and tell you about your privacy rights and how the law protects you.

 

This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can download a pdf version of the policy here. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

 

  1. THE DATA WE COLLECT ABOUT YOU AND HOW IT IS COLLECTED

  

  1. HOW WE USE YOUR PERSONAL DATA

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

 

  1. DATA SECURITY

 

  1. DATA RETENTION

 

  1. YOUR LEGAL RIGHTS

 

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

 

Purpose of this Policy

 

This privacy policy aims to give you information on how Advantage Holidays collects and processes your personal data when you purchase our holidays through one of our Advantage Travel Partnership agents.

 

This website is not intended for children and we do not knowingly collect data relating to children.

 

It is important that you read this privacy policy 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 policy supplements the other notices and is not intended to override them.

 

Controller

 

Advantage 4 Travel Limited trading as Advantage Holidays is the controller and responsible for your personal data (referred to as ”Advantage”, “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

                                                                   

Our full details are:

 

The Data Protection Team

 

Advantage Travel Centres Ltd.

 

21 Provost Street

 

London

 

N1 7NW

 

Phone: (020) 7324 3972

 

Or by email to: GDPR@advantagetravelpartnership.com

 

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 (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Changes to the privacy notice and your duty to inform us of changes  

 

This version was last updated on the date at the bottom of this Policy and historic versions can be obtained by contacting us.

  

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links  

 

This website may include links to third-party websites, plug-ins and applications. 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.

 

 

  1. THE DATA WE COLLECT ABOUT YOUAND HOW WE COLLECT IT 

 

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).

 

When you make your booking with us through one of our Advantage Travel Partnership Agents (i.e. members of Advantage Travel Centres Limited), you will be asked to provide the following kinds of personal data about you which your Agent will pass to us in order to process your booking:

 

  • Identity Data includes first name, last name, marital status, title and date of birth.
  • Contact Data includes emergency telephone numbers for contacting you during your holiday in the event of an emergency only.
  • Health and Mobility Data includes information that you provide to your Advantage Travel Partnership Agent about your health including any medical conditions and any restrictions on your mobility as we are required to do in order to provide you with a safe holiday that is appropriate to your needs. As information about your health and any restrictions on your mobility comprise special category data under the applicable data protection laws, your Agent will ensure that your explicit consent is obtained to collect health and mobility information from you.

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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

 

If you fail to provide personal data  

Where we need to collect personal data by law, or under the terms of a holiday contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract. In this case, we may have to contract you have with us but we will notify you if this is the case at the time.

 

  1. HOW WE USE YOUR PERSONAL DATA

 

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Where we need to perform the contract 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.

  

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 lawful bases we rely on to do so (see below the table for full explanations of the different types of lawful bases). 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 using the details provided at the beginning of this policy if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

 

Purpose/Activity

 

Type of data

 

Lawful basis for processing including basis of legitimate interest

 

To process your booking and fulfil your holiday including:

(a)making arrangements with our suppliers

(b) arranging financial protection for any package holidays

(c) arranging supplier failure insurance for your holiday as applicable

 

(a) Identity

(b) Contact

 

Performance of a contract with you

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our Booking Conditions or privacy policy

 

(a) Identity

(b) Contact

 

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to ensure our customers are aware of our terms)

 

To enable you to partake in a prize draw, competition or complete a survey

 

(a) Identity

(b) Contact

 

(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 (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

(a) Identity

(b) Contact

 

(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

 

 

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product 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 using the details provided at the beginning of this policy.

 

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.

 

Change of purpose  

 

We will only use your personal data for the purposes for which we 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 using the details provided at the beginning of this policy.

 

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.

 

 

  1. 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 Section 3 above:

 

  1. Internal third parties: other companies in the Advantage group including Advantage Travel Centres Limited and Advantage Financial Services Limited acting as joint controllers or processors and who are based in the United Kingdom.
  2. External third parties such as:

 

  • Suppliers who provide the various components forming part of your holiday. These are based worldwide wherever our holidays are located.
  • Service providers acting as processors who provide customers services, administration and IT and system administration services;
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.  Whenever we transfer your personal data out of 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.
  • 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.
  • 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.

Please Contact us (using the details provided at the beginning of this policy) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

 

  1. 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.

 

 

6  DATA RETENTION  

 

How long will you use my personal data for?  

 

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. Details of our data retention policy are available on request.

 

Passport details and emergency contacts details are held for the purpose of performing your booking contract only and accordingly are deleted within 28 days of travel.

 

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. 

 

 

  1. YOUR LEGAL RIGHTS

 

Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:

 

  • 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 particular 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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 using the details provided at the beginning of this policy.

 

 

No fee usually required  

 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you  

 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond  

 

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

 

Policy Version: 24th May 2018