1. Who we are
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. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
2. What data do we collect
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:
- Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
- Financial Data
This include data relating to your means and methods of payment, such as your bank account and payment card details.
- 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.
- 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.
- Profile Data
This includes the data that we receive when you create a profile on our website and make use of that policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data
This includes information about how you use our website, products and services.
- Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
Special Categories of Personal Data
We may collect the following special categories of personal data about you.
Details about your:
- dietary requirements which may disclose your religious or philosophical beliefs;
- race or ethnicity;
- biometric data.
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 date, 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’ in accordance with 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.
3. How do we collect your personal data
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- make a booking for travel arrangements;
- create an account on our website;
- subscribe to our newsletter or other publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey;
- use our mobile enabled website or app;
- give us some feedback;
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
We may receive personal data about you from various third parties as set out below:
- Technical Data from the following parties:
(i) analytics providers such as Google based outside the EU;
Identity and Contact Data from publicly available sources such as Companies House and the
Electoral Register based inside the EU.
4. 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 legal basis 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 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|
|Provide the Service: Arrange Travel, Provide Reporting and Analysis, Duty of Care||Performance of a contract with you.
Necessary for our legitimate interests (For Quality and Training Purposes, and Logging and Auditing)
|Manage Payments||Necessary for our legitimate interests (to recover debts due to us).|
|To manage our relationship with you which will include:||(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) 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.||(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) 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.|
|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)|
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 form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your personal data with any company outside the Review Travel Group for marketing purposes.
We do not sell, rent or lease customer lists to third parties. We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, we may share data with trusted partners to help us perform affiliate marketing, statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to us, and they are required to maintain the confidentiality of your information.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at DPO@reviewtravel.co.uk
Where you opt out of receiving these marketing messages, 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.
IP Address and Cookies
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
You can view more information on cookies and a list of cookies that are used on this website by visiting our Cookie Page. You can accept or decline cookies at any time by accessing the preference panels from your browser’s main menu (usually found under ‘Edit’, ‘Tools’ or ‘Options’). However, if you choose to remove cookies parts of the site may not work properly or your use of the site may be impaired.
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.
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.
5. How we disclose 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.
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- Specific third parties
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.
6. International transfers of your data
As a travel company we may send your details outside the European Economic Area (EEA). Due to the global nature of the infrastructure of the internet please be aware that controls on data protection outside the EEA may not be as strict as in the UK.
Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. 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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfersoutside-eu/adequacy-protection-personal-data-non-eu-countries_en
- 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 https://ec.europa.eu/info/law/law-topic/data-protection/data-transfersoutside-eu/model-contracts-transfer-personal-data-third-countries_en
- 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 https://ec.europa.eu/info/law/lawtopic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en</li>
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. How we secure your data
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.
8. Retention Period
How long will you use my personal data for?
We will only retain your personal data for a period of two years to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to 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.
Once this retention period has been met, all personal information shall be anonymised or securely disposed of.
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.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
- Right to lodge a complaint with the Information Commissioners Office.
If you wish to exercise any of the rights set out above, please contact us at DPO@reviewtravel.co.uk OR write to our Data Protection Officer at our contact address.
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.
- 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.
- Internal Third Parties Other companies in the Review Travel Group acting as joint controllers or processors and who are based in the UK or US and provide IT and system administration services and undertake leadership reporting.
- External Third Parties
I. Suppliers of travel services acting as processors based in the EU and the US who provide the travel services that make up any booking of travel services that you make with us.
II. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
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.
- Right to lodge a complaint with the Information Commissioners Office https://ico.org.uk/make a-complaint/