PRIVACY POLICY
Welcome
to our website. If you continue to browse and use this website, you are
agreeing to comply with and be bound by the following Privacy Policy of use,
which together with our website Terms and Conditions govern Travel Magic Limited’s relationship
with you in relation to this website.
Travel Magic Limited understands and respects the importance of your privacy.
This Privacy Policy
(the “Policy”) sets
out the basis
on which any personal data
we collect from
you, or that
you provide to us,
will be processed
by us, in respect of your relationship with us as a customer
or a potential customer. This information may be collected via our
websites (“Sites”), our call
centres, our networks of Sales Agents,
or our social
media channels (collectively, our “Services”). Please read the following information carefully. You are responsible for ensuring that the other members of your party
are aware of the content
of this Privacy
Policy and you have checked
with them that they agree to their personal data being passed to us too
make a booking or other purchase on their behalf.
By making
a booking/purchase or otherwise submitting your personal data
to us, we will transfer, store or process it as set out below.
We will take
all steps reasonably necessary to ensure
that your data is treated securely
and in accordance with this Privacy Policy.
What types of personal data do we collect
about you and why do we collect it:
We will collect certain personal data
about you and about any other person you include on your booking. The sort of
personal data we collect will be information that you provide to us, that we
collect from you or observe about you, or that we obtain from other sources.
Read on to find out more.
Personal data you give to us
When you
make a booking/purchase or enquiry we will ask you for your name, address,
email address, telephone number, date of birth, and personal travel
preferences. We need to collect this information in order to arrange the travel
and other services you are requesting.
When
you request to make a booking, we will ask you for personal data such as
information concerning dietary requirements, medical conditions, disabilities
and special requirements. We need to collect this information so as to be able
to consider your particular needs in relation to a booking and where those
needs can be met, we may have to share that data with our third party suppliers
and transfer it outside the European Economic Area (EEA), as described in this
Privacy Policy. If you do not want to provide this information to us, or once
you have provided us with this information you ask us or our data compliance
department to stop processing this information, it may mean we won’t be able to
provide all or parts of the services you have requested. If we have to cancel
your booking/purchase as a result, you may incur a cancellation charge.
If
you enter a competition or promotion, complete a survey, or if you report a
problem with any of our Services, we will collect your name and relevant
contact information.
We
may ask to see and retain a copy of your passport details and other
identification document if for example you are purchasing foreign currency or
completing a money transfer.
If
you contact us, we may keep a record of your email or other correspondence, and
if you call us by telephone, we may monitor and/or record phone conversations
for training and customer service reasons.
If, when
using our Services, you make a holiday enquiry with one of our travel
consultants and you enter or provide any of your personal data (including
telephone number or e-mail address), but do not make a booking/purchase, we
will retain and use the data you’ve provided for a limited time and purpose,
each mentioned below.
To help us
keep your information current, accurate and complete, please ensure you tell us
if anything needs to be changed.
Personal
data we collect and/or observe about you
Based on
how you have used our Services in the past and your activity on our website,
social media channels, we collect the following personal data about you:
Details
of the services we have provided to you in the past, including your previous
travel arrangements, such as holidays and other purchases, and matters related
to those arrangements, such as details of your previous requirements or
complaints.
Images of
you taken on our or our Sales Agents’ CCTV systems at our premises.
Personal
data obtained from Sales Agents
We might
also receive your personal data from third party sources who collect
information about you on our behalf. This includes:
If you
tell a subcontractor that you would like to receive marketing communications
from Travel Magic Limited, they will securely transfer your contact details and
marketing preferences to us.
If you
book a holiday through a Sales Agent, certain personal data (as applicable to
your booking, such as your name, date of birth or any special requirements you
have) will be passed to us to provide the services you have requested/booked.
Where
is your data stored and who it’s shared with:
Your
personal data is held on a combination of our own systems and systems of the
suppliers we use to provide our services. Read more here.
When you
provide your personal data to us, some of the personal data you provide will
need to be passed to and processed and stored by relevant third parties, such
as our technology partners to administer the services we provide, and airlines,
airports, hoteliers, insurance companies and ground handling agents, so that
they can provide you with the arrangements and assistance you require.
Some of
these third parties may be based outside of the European Economic Area (“EEA”).
Organisations that are based outside of the EEA may not be subject to the same
level of controls in regard to data protection as exist within the UK and the
EEA. We aim only to transfer your data to third parties outside of the EEA
where either:
(a) your
personal information will be subject to one or more appropriate safeguards set
out in the law. These might be the use of standard contractual clauses in a
form approved by regulators, or having our suppliers sign up to an independent
privacy scheme approved by regulators (like the US ‘Privacy Shield’ scheme); or
(b) the
transfer is necessary to enable your contract to be performed.
In order
for you to travel overseas, we may be required to disclose certain of your
personal data to government bodies or other authorities in the UK and in other
countries, such as those responsible for immigration, border control, security
and anti-terrorism. Even if it is not mandatory for us to provide information
to such authorities, we may exercise our discretion to assist them where
appropriate in the interests of detecting and preventing criminal activity.
Travel
Magic Limited is part of the TTA. We may
disclose your personal information to TTA for business purposes (those business
purposes include holding your data on central/shared systems for administering
bookings and supporting customers in destination countries).
We may
pass your data to relevant third parties for the purpose of detecting and
preventing fraudulent payments or bookings.
How do
we use your information when providing our services to you:
In
order to provide our services to you, we use the information we hold in a
number of different ways. We process your information either because it is
necessary for us to do so as part of a contract you enter into, or because we
have a legitimate business reasons for doing so. Read more here.
The
following activities are carried out by us using your personal data because it
is necessary in relation to a contract which you have entered into or
because you have asked for something to be done so you can enter into a
contract:
Administering
your booking internally and communicating your booking externally with our
suppliers, to ensure the services you have requested are arranged;
To
communicate with you regarding your booking or any other purchase, including
sending booking confirmation and travel documents;
We may use
and process your personal information as set out below where it is necessary
for us to carry out activities for which it is in our legitimate interests as a
business to do so:
To improve
the customer experience:
To
allow you to participate in interactive features of our Sites when you choose
to do so;
To
ensure that content from our Sites is presented in the most effective manner
for you and for your computer; and
To notify
you about changes to our service.
To protect
our business against financial loss:
For
debt collection or credit vetting; and
For
payment card and booking verification.
To
maintain a safe and secure environment and prevent and detect criminal
activity.
Using CCTV
in our premises.
To promote
our business and improve our products and services:
To
send marketing correspondence about products and services similar to those you
have previously bought from us. You can opt out and object to our sending you
electronic marketing information and this option will be included in every
marketing message we send you. See the section ‘When and how do we use your information
for marketing for more information’;
For
internal research/analysis to improve the quality of our Services, the products
we offer and new products we are developing by:
Inviting
customers to take part in surveys or customer/business discussion groups; and
Using
aggregated customer data to make informed decisions based on analysis of
customer booking/purchase trends and behaviours.
To support
any potential company sale or acquisition:
In the
event that we sell or buy any business or assets, we may disclose your personal
data to the prospective seller or buyer of such business or assets.
We may use
and process your personal information as set out below where we consider that
it is in your vital interests that we do:
To assist
you or arrange for assistance to be provided to you by third parties either in
the event of an incident or emergency.
We may use
and process your personal information as set out below where we have your consent
to do so:
To
assist you or arrange for assistance to be provided to you by third parties
where you have special requirements in relation to medical, health or diet; and
To send
marketing correspondence about our products and services where we have asked
for your permission to do so. See the section ‘When and how do we use your
information for marketing for more information’.
We may use
and process your personal information as set out below where there is a legal
requirement for us to do so:
For
resolving complaints, dealing with disputes and legal proceedings. This might
include contacting you proactively if we need to resolve any issues you may be
experiencing or have experienced with a booking/purchase.
When
and how do we use your information for marketing:
To find
out more about our marketing communications, including when and how we may
contact you and how you can opt out of marketing, please read more here.
If you
have made an enquiry on one of our Sites or through a Sales Agent, your
personal data may be used by Travel Magic Limited and our Sales Agents in the
ways the law allows, to contact you by post, electronic means (e-mail or text
message) and/or by phone with information and offers relating to products or
services that you can book/purchase from Travel Magic Limited. Travel Magic
Limited and our Sales Agents will only do this if you did not opt out of such
marketing at the point where we collected your contact details.
If you
have not made an enquiry or purchase, Travel Magic Limited and the Sales Agents
will only send to you information and offers by email or text message only if
you sign up (opt in) to receive such marketing, either directly through us or
by telling a third party that you would like to receive marketing from us.
Travel and
travel related services, insurance and gift cards are the types of products and
services that can be booked/purchased through Travle Magic Limited. You will
only receive marketing communications about those which we think are relevant
to you.
We will not
pass your contact details to a third party for them to send to you
marketing communications unless you have expressly agreed that we may do so.
How do
we personalise our marketing to you:
We may use
your personal information to try to ensure any marketing communications we send
to you are offering products or services likely to be of interest to you.
What
you need to do if you don’t want our marketing communications:
We
understand you might not want to hear from us and that’s ok. It is easy to
opt-out or unsubscribe, please read more here.
You have
the right at any time to ask us not to process your personal data for marketing
purposes. You can exercise your right to prevent such processing by selecting
the ‘no marketing’ option on the forms we use to collect your data. You can
also unsubscribe from marketing communication by using the link on any email
marketing you receive or by advising the Sales Agent that you booked through,
or otherwise exercise this right at any subsequent time by sending an
unsubscribe request to: Marketing, Travel Magic Limited, 144 Ewell Road,
Surbiton, Surrey, KT66HE.
Your
rights in relation to any personal data we hold about you:
You
have a number of rights in relation to your personal information under data
protection law. To find out more, please read here.
Your
Right to Access Your Personal Information
You have
the right to make a Data Subject Access Request in many circumstances. That is
a request for access to the personal information that we hold about you. If we
agree that we have to provide personal information to you (or someone else on
your behalf), we’ll provide it to you or them free of charge. We may ask for proof
of identity and sufficient information about your interactions with us that we
can locate your personal information. That may include information about your
previous booking(s) or other purchases. We will ask you to provide this before
providing a copy of any of your personal information we may be holding to you
or another person on your behalf. We may not provide you with a copy of your
personal information if this concerns other individuals or we have another
lawful reason to withhold that information.
Please see
the section titled ‘How to Contact Us’ if you need to make a Data Subject
Access Request.
Correcting
and updating your personal information
The
accuracy of your information is important to us and we are working on ways to
make it easier for you to review and correct the information that we hold about
you.
In the
meantime, if you change your name or address/email address, or you discover
that any of the other information we hold is inaccurate or out of date, please
let us know by contacting our customer experience team.
Withdrawing
your consent
Where we
rely on your consent as the legal basis for processing your personal
information, as set out in section above titled ‘How do we use your
information when providing our services to you’, you may withdraw your
consent at any time. If you would like to withdraw your consent to receiving
any direct marketing to which you previously opted-in, please see the section
titled “What you need to do if you don’t want our marketing communications’ for
further details. If you would like to withdraw your consent to us processing
any information concerning dietary requirements, medical conditions,
disabilities and special requirements, please contact our customer experience
team. Please note if you ask us to stop processing this information, it may
mean we won’t be able to provide all or parts of the services you have
requested. If we have to cancel your booking/purchase as a result, you may
incur a cancellation charge.
If you
withdraw your consent, our use of your personal information before you withdraw
is still lawful.
Objecting
to our use of your personal information and automated decisions made about you
Where we
rely on your legitimate business interests as the legal basis for processing
your personal information for any purpose(s), you may object to us using your
personal information for these purposes by emailing or writing to us at the
address provided at the end of this policy. Except for the purposes for which
we are sure we can continue to process your personal information, we will
temporarily stop processing your personal information in line with your
objection until we have investigated the matter. If we agree that your
objection is justified in accordance with your rights under data protection
laws, we will permanently stop using your data for those purposes. Otherwise we
will provide you with our justification as to why we need to continue using
your data.
Erasing
your personal information or restricting its processing
In certain
circumstances, you may ask for your personal information to be removed from our
systems by emailing or writing to us at the address at the end of this policy.
Provided we do not have any continuing lawful reason to continue processing or
holding your personal information, we will make reasonable efforts to comply
with your request.
You may
also ask us to restrict processing your personal information where you believe
it is unlawful for us to do so, you have objected to its use and our
investigation is pending or you require us to keep it in connection with legal
proceedings. We may only process your personal information whilst its
processing is restricted if we have your consent or are legally permitted to do
so, for example for storage purposes, to protect the rights of another
individual or company or in connection with legal proceedings.
Transferring
your personal information in a structured data file
Where we
rely on your consent as the legal basis for processing your personal
information or need to process it in connection with your contract, as set out
in section titled ‘How do we use your information when providing our
services to you’, you may ask us to provide you with a copy of that
information in a structured data file.
You can
ask us to send your personal information directly to another service provider,
and we will do so if this is technically possible. We may not provide you with
a copy of your personal information if this concerns other individuals or we
have another lawful reason to withhold that information.
How to
contact us:
Any
subject access request can be made in writing to:
Travel
Magic Limited
144 Ewell
Road,
Surbiton,
Surrey,
KT66HE
