INTRODUCTION

Welcome to InteleTravel’s privacy policy.

InteleTravel 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 and tell you about your privacy rights and how the law protects you.

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

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED?
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how InteleTravel collects and processes your personal data through your use of our website and/or in your interaction with our independent travel agents, including any data you may provide through this website, when you sign up to our marketing communications, request or purchase a product or service, make an enquiry or otherwise interact with us.

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 policy or fair processing policy 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 other notices and privacy policies and is not intended to override them.

CONTROLLER

The InteleTravel Group of companies is made up of different legal entities, details of which can be found at www.InteleTravel.uk and www.InteleTravel.com. This privacy policy is issued on behalf of the InteleTravel Group so when we mention “InteleTravel Group”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the InteleTravel Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. InteleTravel UK Limited is the controller and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

If you have any questions about this privacy policy or our privacy practices, please contact our DPO in the following ways:

Full name of legal entity: InteleTravel UK Limited

Email address: DataOfficer@InteleTravel.com

Postal address: 25 Cabot Square, Canary Wharf, London E14 4QZ, UK

Phone: 0330 808 4419

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.

CHANGED TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We keep our privacy policy under regular review. This version was last updated in August 2018.

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.

We may make changes to this privacy policy from time to time and/or as required by law. We reserve the right to make any revised policy effective for personal data we already hold about you as well as any information we receive in the future. We will post a copy of the updated privacy policy on our website prior to any changes taking effect. If we make any significant changes we will also notify you of any such changes by email in advance. Your continued use of the website and/or our services following any changes to the privacy policy (of which you will be notified as described above) signifies your acceptance of those changes.

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 policy of every website you visit.

THE DATA WE COLLECT ABOUT YOU

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 as follows:

• IDENTITY DATA includes first name, maiden name, last name, username or similar identifier, marital status, title, assistance requirements, dietary requirements, passport information, date of birth and gender.
• CONTACT DATA includes billing address, home/office address, email address and telephone numbers.
• FINANCIAL DATA includes bank account and payment card details.
• TRANSACTION DATA includes details about payments to and from you and other details of products and services you have purchased from us.
• TECHNICAL DATA includes 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 includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• USAGE DATA includes information about how you use our website, products and services.
• MARKETING AND COMMUNICATIONS DATA includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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.
We may sometimes collect information relating to your passport information, dietary, assistance requirements and medical conditions. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service we would otherwise provide to you, but we will notify you if this is the case at the time.

HOW IS YOUR PERSONAL DATA COLLECTED

We use different methods to collect data from and about you including through:

DIRECT INTERACTIONS. This is where you interact with or request services from our independent travel agents. 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:

• create an account or personal profile on our website;
• subscribe to our marketing communications;
• request and/or purchase our products or services (via our website, email, telephone or other method);
• enter a competition or promotion; or
• make an enquiry, give us feedback or contact us.

AUTOMATED TECHNOLOGIES OR INTERACTIONS. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy in the Privacy Policy link at www.InteleTravel.uk for further details.

THIRD PARTIES OR PUBLICLY AVAILABLE SOURCES. We will receive personal data about you from various third parties as set out below:

TECHNICAL DATA FROM THE FOLLOWING PARTIES:

• analytics providers (such as Google based both inside and outside the EU);
• advertising networks (such as Cohorts based outside the EU); and
• search information providers (such as Hubspot based outside the EU).

CONTACT, FINANCIAL AND TRANSACTION DATA FROM PROVIDERS OF TECHNICAL, PAYMENT, AND DELIVERY SERVICES (such as Chase Paymentech based outside the EU and Santander based inside the EU).

IDENTITY AND CONTACT DATA FROM PUBLICALY AVAILABLE SOURCES (such as Companies House and the Electoral Register based inside the EU).

IDENTITY DATA FROM TRAVEL SUPPLIER PARTNERS AND TECHNOLOGY PARTNERS such as Travelutionary and Odysseus.

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.

See the GLOSSARY in Section 10 below to find out more about the types of lawful bases that we will rely on to process your personal data.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us or selecting the unsubscribe link in any of our emails, or texting STOP in response to any of our text messages.

PURPOSES FOR WHICH WE WILL YOU 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 bases 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 based upon 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.

MARKETING

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 do this to ensure you always receive an excellent service which is tailored to your preferences. However, if you would prefer we do not use these types of profiling techniques, you can opt-out by emailing DataOfficer@InteleTravel.com. If you opt-out, you may find that your communications from us become less relevant to you.

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

If you are not already an existing user or customer, you can sign up to receive marketing communications from us by opting-in via our website.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

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 any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

COOKIES

When you visit our website, we place a “cookie” on your personal computer. A cookie is a small data file that is transmitted between computers to help us recognise you when you return to our Website. Any information stored in the cookie is encrypted, so no one can view the data it contains through unauthorised access to your computer. Most Internet browsers automatically accept cookies. You can, however, instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from any site you may visit.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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.

DISCLOSURES OF YOUR PERSONAL DATA

WE MAY SHARE YOUR PERSONAL DATA WITH ANY MEMBER OF THE INTELETRAVEL GROUP AND OTHER:

5.1 third-party processors for the purposes set out in the table at section 4 above;

5.1 our business partners, suppliers and subcontractors for the performance of any contract we enter into with you;

5.2 where we outsource any of our business functions under which we collect or store your data;

5.3 where we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

5.4 if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Terms and Conditions and other agreements; or to protect our rights, property, or safety of our employees, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

For a full list of all our third-party processors please see THIRD PARTY PROCESSORS TABLE below.

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.

We will never sell your data to third parties for the purposes of marketing.

INTERNATIONAL TRANSFERS

We share your personal data within the InteleTravel Group. This will involve transferring your data outside the European Economic Area (EEA). The data we collect may be transferred to, and stored at, a destination outside the EEA. All our data is stored on our server based in Flexential’s worldwide network of data centres. It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services.

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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-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 European Commission: Model contracts for the transfer of personal data to third countries https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/eu-us-privacy-shield_en.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

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 wrongfully 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 also 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.

DATA RETENTION

HOW LONG WILL YOU RETAIN MY PERSONAL DATA?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data. See your legal rights below for further information.

In some circumstances we will 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.

YOUR LEGAL RIGHTS

You have various legal rights under data protection laws in relation to your personal data. Please see the portion of Section 10 below entitled YOUR LEGAL RIGHTS to find out more about each of these rights:

• 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.

If you wish to exercise any of the rights set out above, please contact DataOfficer@InteleTravel.com.

NO FEE USUALLY REQUIRED

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

GLOSSARY

LAWFUL BASIS

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 with respect to 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 OBLIGATION means processing your personal data where it is necessary for compliance with a legal obligation to which we are subject.

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 of which you will be notified, 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:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• 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.
• You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

REQUEST TO TRANSFER of your personal data to you or to a third party. We will provide to you, or a third party you have chosen and authorised, 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.