Privacy Policy

2 PERSONAL DATA WE COLLECT

2.1 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, loyalty membership details, frequent flyer membership details, payment details, your reasons for travel (such as for a wedding, birthday or anniversary), 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. If you are travelling on a route requiring Advance Passenger Information, your passport or identity card details including your passport number, the country in which your passport was issued and the expiry date;
• Details about the services you arrange with us. Your travel details, including details of your travel itinerary, where you are flying from and to, your booking information including the hotel accommodation, any onward travel details if relevant (for example if you need our assistance for a connecting flight, if you’ve booked transportation or a tour with us), details of experiences or excursions booked through us, your baggage requirements, any upgrade information, your lounge visits, seat preferences, meal preferences or requirements, details of any special assistance you might need from us and any other information relevant to enable us to provide you with the travel or other services that you’ve arranged with us;
• 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 simply verbally to our people);
• Job applications. If you apply for a job with us, your CV, work history, educational details and the role you’re applying for; and
• Your use of our systems and services. Details of the way in which you use our site, app, retail stores, call centres and/or social media pages (please see the “OUR SITE, AND COOKIES” section below for further details).

How we collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we collect information in any of the following ways:

• When you browse our site or make a telephone enquiry
• When you book or search for a holiday or other service (such as a flight, cruise, hotel lounge access, transportation or special assistance) via our website.
• When you fill in part of the booking information on our site but do not complete the booking;
• When you apply for a job with us by email or via the site;
• When you contact us via our call centre, social media, post, email or instant messenger;
• When you request a brochure, sign up to receive email updates, participate in any of our competitions, promotions (for example via any social media channels, email or our site), surveys or market research;

In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:

• Information about your health (for example if you ask us to provide you with special assistance during your holiday, or to determine your fitness to fly, or if you specify a meal preference that indicates a medical condition such as celiac disease); and/or
• Information about your religion (for example if you specify a meal preference that indicates a particular religion such as a kosher or halal meal).

3 USING YOUR PERSONAL DATA

3.1 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 a legal obligation we have;
• For our legitimate interests (we explain what we mean by this below);
• To protect your vital interests;
• With your consent (please see your rights in relation to consent that you provide to us);
• For establishing, exercising or defending legal claims; and
• For reasons of substantial public interest.

3.2 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. This includes:

• To manage your booking with us. We will use your information to provide you with any services that you request or purchase from us. This includes booking your flight, cruise or hotel, arranging a tour, transportation or car hire, and issuing you with your tickets (on the basis of performing our contract with you), and providing 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. This includes sending you an email to notify you of changes to your itinerary, or providing you with a voucher, ticket or e-ticket. 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 personalise your customer experience. We use your information to provide you with a more personalised service. For example tailoring the communications that we send to you with your preferred destinations, serving you only with advertising that we think you might like and/or enhancing your holiday experience (on the basis of our legitimate interests to present you with the right kinds of products and services);
• To improve our customer service. We record calls to our call centre and/or monitor calls for the purposes of improving our customer service, ensure quality assurance, training, security and for general business purposes (on the basis of our legitimate interest in improving our customer service);
• To process your job applications. We will use your information to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);
• To optimise our site. If you use our website, we will use your information to ensure that the content from our website is presented in an effective manner for you and your device, to provide you with access to our site in a manner that is effective, convenient and optimal, and to provide you with content that is relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users);
• 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 comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or subpoenas (on the basis of our legitimate interests to comply with a legal obligation).

3.3 What do we mean by “legitimate 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 involves:

• Using your information to protect you against fraud when you transact on our site, and to ensure that our systems and sites are secure;
• Determining the effectiveness of our site / tools / services and improving the security and optimisation of our network, sites and services;
• Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;
• 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; and/or
• 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 details of “YOUR RIGHTS” section below.

As we outline in “YOUR RIGHTS” section below, from 25 May 2018 you will 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.

4 PROTECTING YOUR PERSONAL DATA

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;
• Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection 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 and awareness to make sure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.

5 DATA RETENTION

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;
• 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;
• We retain any unsuccessful CV’s or job applications that we receive for a period of up to 2 years in case we think you might be suited to another opportunity that becomes available in the near future;

6 YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA

6.1 Overview of your rights

You have certain rights in respect of the personal information that we hold about you, including:

• The right to be informed of the ways in which we use your information, as we seek to do in this Privacy Policy;
• 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; and
• The right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) 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.

6.2 Some upcoming new rights…

From 25 May 2018, you will have certain additional rights in respect of the information that we hold about you, including:

• The right to withdraw consent that you have provided to us to use your personal information (refer to paragraph 6 to see when we are relying on your consent and for further information on your rights connected with consent.
• The right to object to our using your information on the basis of our legitimate interests (see paragraph 6 above to see when we are relying on our legitimate interests) (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; and
• 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; and
• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

6.3 How to exercise your rights

• Contacting us. You can exercise your rights by contacting us using the details in the “ABOUT US” section above, or by checking the applicable boxes on forms that we use to collect your information, or to tell us that you don’t want to participate in marketing.
• You can update or change the details we hold about you by contacting us by telephone or email and,
• If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.
• We will comply with your requests unless we have a lawful reason not to do so.

6.4 What we need from you to process your requests

Please be aware that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request.

7 CONTACT

If you have any questions about this privacy policy or our treatment of your personal information, please write to us by email to privacy@luxuryholidays.co.uk or by post to:

DPO

Luxury Holidays To Ltd

Southbridge House

Southbridge Place

Croydon

Surrey

CR0 4HA