1- Ariana Travel t/a Corporate Travel Concierge is committed to respecting your privacy and protecting your personal information. This privacy notice sets out:
- When we collect personal information about you.
- What types of personal information we collect.
- Our legal basis for using your personal information.
- How we keep it safe.
- Who we share personal information with.
- Marketing communications.
- Data retention.
- Your rights and choices about the personal information that we hold;
- Contact us and
- Making a complaint
2- This privacy notice has been updated to reflect GDPR (the General Data ProtectionRegulation) which came into effect on the 25 th of May 2018.
When we collect personal information about you
3- We collect personal information about you whenever you make a booking or otherwise interactwith in person or via telephone, our websites, email or other contact methods (whether directly
with us or through agents acting on our behalf).
The types of personal data we collect and why we collect it
4- Personal data, or personal information, means any information about an individual from whichthat 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:
(A) 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, gender and passport
details.
(B) Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery
address, email address and telephone numbers, emergency contact details and next of kin
contact details.
(C) Financial Data
This includes data relating to your means and methods of payment, such as your bank account
details to set up direct debits.
(D) 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.
(E) 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.
(F) Profile Data
This includes the data that we receive when you create a profile on our website and make use of
that profile, such as your username and password, purchases or orders made by you, your
interests, preferences, feedback and survey responses.
(G) Usage Data
This includes information about how you use our website, products and services.
(H) Marketing and Communications Data
This includes your preferences in relation to whether or not you want to receive marketing
information from us and our third parties and also your communication preferences.
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. 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 will treat the combined data as personal data
which will be used in accordance with this Privacy Policy.
Special Categories of Personal Data
We collect the following special categories of personal data about you. Details about your:
- dietary requirements which may disclose your religious or philosophical beliefs;
- health;
- nationality which may disclose your race or ethnicity
We collect and process the above data only where it is strictly necessary to do so in order todeliver the travel service 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 services 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
service you have booked, we will be required to treat any withdrawal of consent as a cancellation
of your booking and the cancellation charges referred to in clause 18.2] of our Terms and
Conditions will become payable.
You may give us your Identity, Contact and Financial Data by filling in forms or by correspondingwith us by post, phone, email or otherwise. This includes personal data you provide when you:
- make a booking of travel services;
- 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;
- leave us a review or give us some feedback;
- submit a web enquiry
Purpose/Activity Type of data Lawful basis for processing including basis of
legitimate interest
To register you as a new
customer.
(a) Identity;
(b) Contact. Performance of a contract with you.
To process and deliver your
booking including:
(a) Manage payments, fees
and charges;
(b) Collect and recover
money owed to us.
(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and
Communications.
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to
recover debts due to us).
To manage our relationship
with you which will include:
(a) Notifying you about
changes to our terms or
Privacy Policy;
(b) Asking you to leave a
review or take a survey.
(a) Identity;
(b) Contact;
(c) Profile;
(d) Marketing and
Communications.
(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) Identity;
(b) Contact;
(c) Profile;
(d) Usage;
(e) Marketing and
Communications.
(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 and this website
(including troubleshooting,
data analysis, testing, system
maintenance, support,
reporting and hosting of
data).
(a) Technical
(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 re-organisation or group restructuring
exercise)
(b) Necessary to comply with a legal obligation.
To deliver relevant website
content and advertisements
to you and measure or
(a) Identity;
(b) Contact;
(c) Profile;
Necessary for our legitimate interests (to study
how customers use our products/services, to
develop them, to grow our business and to
understand the effectiveness
of the advertising we serve to
you
(d) Usage;
(e) Marketing and
Communications;
(f) Technical.
inform our marketing strategy)
To use data analytics to
improve our website,
products/services, marketing,
customer relationships and
experiences
(a) Technical;
(b) Usage.
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)
To make suggestions and
recommendations to you
about goods or services that
may be of interest to you.
(a) Identity;
(b) Contact;
(c) Technical;
(d) Usage;
(e) Profile;
(f) Marketing and
Communications.
Necessary for our legitimate interests (to
develop our products/services and grow our
business)
To monitor our
communications with you in
order to check any
instructions given to us, for
training purposes, for crime
prevention, to improve the
quality of our customer
service and to defend legal
claims.
(a) Identity;
(b) Contact;
(c) Technical.
(a) Necessary for our legitimate interests (to
assist us in training our employees and defend
our business in the event of a claim);
(b) Necessary to comply with a legal obligation;
To sign you up as a member
and to receive our emails.
(a) Identity;
(b) Contact;
(c) Marketing and
Communications.
(a) To send you e-mails;
(b) To let you know about our latest offers,
news and promotions;
(c) To notify you of interesting news, money
saving deals and cruise holidays you which you
may be interested in;
(d) Necessary for our legitimate interests (to
keep our website updated and relevant, to
develop our business and to inform our
marketing strategy)
To follow up your web
enquiry.
(a) Identity;
(b) Contact;
(c) Marketing and
Communications.
(a) To send you news, exclusive offers and
products;
(b) Necessary for our legitimate interests (to
keep our website updated and relevant, to
develop our business and to inform our
marketing strategy)
Our legal basis for using your personal information
5- We will only process your personal information where we have a legal basis to do so.Depending on the circumstances, the legal basis will almost always be one or more of the
following:
- so that we can make and fulfil your booking or otherwise perform our contract with you;
- because it is in our legitimate interests to use your personal information to operate and improve
our business as a travel agency;
- to comply with a legal obligation;
- to protect the vital interests of you or another person; or
- because you have consented to our using your information for a particular purpose.
How do we keep your personal information safe?
6- Protecting the confidentiality and integrity of your personal data is a responsibility that we takeseriously at all times. We use appropriate technical and organisational measures to help to keep
personal data secure against unauthorised or unlawful processing, and against accidental loss,
destruction, or damage.
Who do we share your personal information with?
7- With suppliers - in order to provide products or services requested by you we share personaldata with suppliers of your travel arrangements, including airlines, hotels and insurance
providers. In many cases such suppliers will themselves separately be controllers of your
personal data.
9- Payment processing companies to process your payment.
10- With regulatory authorities - it may be necessary to disclose personal data for immigration,border control, security and anti-terrorism purposes, or any other purposes required by regulatory
authorities.
11- It is often necessary for us to send your personal information outside the European EconomicArea to fulfil your travel arrangements. This is because the suppliers providing your travel
services are located around the world. Also, your personal information may need to be
transferred to border control and immigration outside of the EEA. This may involve sending your
data to countries where under their local laws you may have fewer legal rights.
12- With third party service providers which help us understand our customer behaviour or help
improve our website, our products and services.
Marketing communications
13- When you book or register with us, we will ask if you would like to receive marketingcommunications. If you have previously agreed to receive marketing communications, we may
send you relevant offers and news about our products.
14- You can change your marketing preferences by contacting us in any way or by using the‘unsubscribe’ link in our marketing emails or by replying STOP to our marketing text messages.
15- We will respect your choice as to what communications you wish to receive and the methodsby which you are sent them.
Data retention
16- We will keep your personal data for only as long as it is necessary for the purposes set out inthis privacy notice. For example, after travel we will keep the information related to your booking
so that we can respond to any complaints and fulfil our record keeping obligations. After this
time, we will securely erase or anonymise personal data.
Your rights and choices about the personal information that we hold
17- You can ask us for a copy of the information that we hold about you.
18- You can also ask us to correct any information which you don’t think is correct or to deletethe information we hold about you.
19- To comply with these requests we may need you to confirm your identity by providingdocuments or additional information.
Contact us
20- If you have any concerns about our use of your personal information, you can make acomplaint to us at:
Data Protection Manager
Ariana Travel Limited
136 The Broadway
Southall
Middlesex
UB1 QB
You can also email info@Arianatravel.co.uk or call us on 020 8843 0011.
(Standard call charges apply. If you are unsure, please check with your network provider).
Making a complaint
21- You can also complain to the ICO if you are unhappy with how we have used your data.The ICO’s address is:
Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk
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