Last Updated: 28th May 2019
You have the right to make a complaint at any time to the Information Commissioner’s Office reference number ZA519717 (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. 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.
This Website is not intended for children and we do not knowingly collect data relating to children.
WHO WE ARE
We are Travel Curious Ltd. and under the General Data Protection Regulation (EU) 2016/679 (GDPR), are a data controller and responsible for your personal data.
- Our Website address is www.travelcurious.net and www.travelcurious.com
- Our full company name is Travel Curious Ltd.
- Our registered address: Winston House, 349 Regents Park Rd, Finchley, London N3 1DH
- Our data controller is Nadav Zin who can be contacted at email@example.com
We respect your right to privacy and will only process personal information about you in accordance with the Data Protection Legislation which for the purposes of this policy shall mean: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 2018 and other applicable privacy laws. If you have any questions about how we collect, store and use personal information, or if you have any other privacy-related questions, please contact us at firstname.lastname@example.org.
We take a proactive approach to user privacy and ensure the necessary steps are taken to protect the privacy of its users throughout their visiting experience.
When you use or contact our Website, you do so at your own discretion and provide any such personal details requested at your own risk. Your personal information is kept private and stored securely until a time it is no longer required or has no use, as detailed below. Every effort has been made to ensure a safe and secure form to email submission process but we advise users using such form to email processes that you do so at your own risk.
WHAT INFORMATION DO WE COLLECT
Personal data, or personal information, means any information about an individual from which a person can be identified. 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, last name, username or similar identifier and age. When you email, phone, live chat or otherwise, we may collect information such as your first name, last name, email address and phone number. We may ask for your date of birth to send you birthday offers or anniversary offers.
- Contact Data includes billing address, invoicing address, email address and telephone numbers.
- Financial Data includes bank account and payment card details. We use a third party payment provider to collect financial data and all credit card information for all transactions that go through Our Website. It follows secure encrypted processes a standard for the e-commerce industry.
- Transaction Data includes details about payments and other details of our 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, requests and bookings made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Website and Services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special Categories of Data includes information relating to disabilities or medical conditions which may affect your tour arrangements (including, for example, access to properties or activities featured in your tours).
- Interaction Data includes any information that you might provide to any discussion forums on the Website.
- Cookies Data like many websites, we use “cookies” to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them and what kind.
- Third Parties and Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or through the Services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on our Website. We work closely with third parties (including, for example, tour guides, tour providers, drivers, sub-contractors, advertising networks, analytics providers, search information providers, software suppliers) and may receive information about you from them.
We also collect some non-personally identifiable information (ourselves or using third party services) using web analytic tools. We use third-party services that use tracking technologies to capture aggregate usage and volume statistics about interactions on our Website and Services.
We may collect Special Categories of Data about you for the purposes of making a booking for a tour. You agree that we may process your Special Categories of Data that you may provide to us in order to complete your booking and that such Special Categories of Data may be transferred to our relevant hotel partners and tour guides for this purpose. The identified purposes are outlined further in the table below.
We also get information on how you use our Services, such as tracking information, to enable our Services to be used correctly, we may need to use tracking information.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- you have given consent to the processing of your personal data for one or more specific purposes;
- if processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- if processing is necessary for compliance with a legal obligation to which we are subject;
- if processing is necessary to protect the vital interests of you or of another natural person;
- if processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- if processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our financial payments, except where such interests are overridden by the fundamental rights and freedoms of the data subject, in particular where the data subject is a child.
If you choose not to provide the personal information we request, you can still visit most areas of the Website, but you may be unable to access certain options and services that involve interaction. You have the final decision on whether to proceed with any activity that requests personal information.
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 our Services). In this case, we may have to cancel a tour reservation you have with a tour guide, but we will notify you if this is the case at the time.
HOW YOUR DATA IS COLLECTED
We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your personal information by way of different methods to collect data from and about you including through direct interactions. You may give us your information by filling in forms via our Website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- present site content;
- apply (or enquire) for or about a tour booking or use any of our Services, including any services provided by the hotel partners that we work with who offer access to guide services, or the means by which you will interact with tour guides as well;
- create an account on our Website;
- subscribe to our Services or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us some feedback.
In addition to the above, we may use the information in the following ways:
- To personalise your Website experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- Processing your tour reservations.
- To allow us to better service you in responding to your customer service requests.
- To administer a contest, promotion, survey or other site feature.
- If you have opted-in to receive our e-mail newsletter, we may send you periodic e-mails. If you would no longer like to receive promotional e-mail from us, please refer to the “How can you opt-out, remove or modify information you have provided to us?” section below. If you have not opted-in to receive e-mail newsletters, you will not receive these e-mails. Visitors who register or participate in other site features such as marketing programs and ‘members-only’ content will be given a choice whether they would like to be on our e-mail list and receive e-mail communications from us.
- Present site content effectively to you.
- Provide information, and services that you request, or (with your consent) which we think may interest you.
- Carry out our contracts with you.
- Provide the relevant Services to you
- Tell you about charges.
Automated technologies or interactions. As you interact with our Website, we may 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.
Third parties or publicly available sources. We shall contract with third parties to supply our Services to you on our behalf. These include our tour partners for reservations, payment processing, search engine facilities, advertising and marketing, including to tour guides for the purposes of the tour guide providing your tour and the hotel and relevant staff (including the concierge or front desk). In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law. To request a list of current third parties who we contract with (as joint controllers or processors) please contact email@example.com.
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. The term “outside parties” does not include any of our group companies. It also does not include our website hosting partners, subcontractors and other third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
We are also allowed to disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer
- We can disclose it to other businesses in our group
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
We do not allow our third-party service providers to use your personal data for their own purposes (unless you give them permission to do this yourself) and only permit them to process your personal data for specified purposes and in accordance with our instructions. If you are already our customer, we will only contact you electronically about things similar to those tour reservations previously provided to you. If you are a new customer, you will only be contacted if you agree to it. We may keep a record of those links which are used the most to enable us to provide the most helpful information but we agree to keep such information confidential and you will not be identified from this information.
HOW DO WE USE YOUR 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.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to 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 at firstname.lastname@example.org and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide the best possible services to you.
As already indicated above, with your permission and/or where permitted by law, we may also use your data for marketing purposes which may include contacting you by email and or by telephone with information, news and offers on our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the Data Protection Legislation.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA?
We have set out below, in a table format, a description of the ways we use your personal data, and which of the relevant lawful basis that we rely on to do so, including where your personal data is passed to the relevant third party hotel partners and tour guides, for the purposes of providing our Services to you and access to the tour guide services that you may wish to book. 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|
|Details on our Website, to register new customers, including completing registration forms or to submit an enquiry with us.||(a) Identity
(c) Special Category of Data
|(a) Performance of a contract with you
(b) Consent (for use of Special Category of Data)
|Information to process tour bookings including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(c) Process bookings and passing your personal data to our relevant hotel partners and tour guides for confirming a booking and for the tour guide to provide its tours to you, as booked
(d) Undertake tour reviews
(e) Marketing and Communications
(f) Special Category of Data
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Consent (for use of Special Category of Data)
|Information to manage our relationship with our customers, or prospective customers which will include: (a) Notifying about changes to our terms
(b) Asking to leave a review or take a survey
(d) For internal administrative purposes
(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 customers and prospective customers to partake in a prize draw, promotional activity, loyalty membership, competition or complete a survey||(a) Identity
(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) Identity
|(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 deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.||(a) Identity
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products / services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products / services, marketing, customer relationships and experiences||(a) Technical
|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
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop our products / services and grow our business)|
|Monitoring and preventing unlawful acts||All categories||Necessary for the purposes of the prevention or detection of an unlawful act, and must be carried out without the consent of the data subject so as not to prejudice those purposes, and is necessary for reasons of substantial public interest.|
Where we use providers based in the US, we or our relevant hotel partners or tour guides 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 the European Commission: EU-US Privacy Shield.
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).
You will receive marketing communications from us if you have requested information from us or made tour reservations from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
As already indicated you can ask us 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 email@example.com
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a tour reservation or any other obligation under a contract which still needs to be fulfilled.
HOW DO WE STORE YOUR DATA AND SECURITY
We will only retain your personal data for as long as reasonably necessary to fulfill 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.
In any event, we will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy.
Data security is of great importance to us and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. 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.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure. Any payments made will be encrypted via our third party provider and we will not hold any payment card data of yours.
We have implemented security measures such as a firewall to protect any data and maintain a high level of security. Notwithstanding the security measures that we take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to us data via the internet and you take the risk that any sending of that data turns out to be not secure despite our efforts. If we give you a password upon registration on our Website, you must keep it confidential. Please don’t share it.
HOW DO WE PROTECT VISITOR INFORMATION?
We implement a variety of security measures to protect and maintain the safety of your personal information including encrypted software. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.
DO WE USE “COOKIES”?
What are Cookies?
Cookies are small files, which include a unique reference code, sent from a website & stored on a user’s device (computer or mobile), they enable a website to recognise a user’s browser and capture and remember certain information. Find out more information about cookies on http://www.whatarecookies.com/
We may contract with third-party service providers to assist us in better understanding our Website visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business as authorised by us.
All Cookies used by and on our Website are used in accordance with applicable laws.
A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Website and will last for longer.
Other cookies may be stored by external vendors when this Website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.
Our cookies will be used for:
Essential session management:
- creating a specific log-in session for a user of the site in order that the Website remembers that a user is logged in and that their page requests are delivered in an effective, secure and consistent manner;
- recognising when a user of the Website has visited before to offer bespoke benefits, allowing us to identify the number of unique users who visit to the Website and make sure we have enough hosting capacity for the number of users who visit;
- recognising if a visitor to the Website is registered with us in any way;
- we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our Website.
- customising elements of the promotional layout and/or content of the pages of the Website.
Performance and measurement
- collecting statistical information about how our users use the Website so that we can improve the Website and learn which parts are most popular to users.
How to turn off cookies?
Most computer and some mobile web browsers automatically accept cookies. You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your security settings. Each browser is a little different, so look at your browser help menu to learn the correct way to modify your cookies.
If you turn cookies off, you won’t have access to many features that make your Website experience more efficient and some of our services may not function properly. However, you can still place tour reservations over the telephone by contacting our booking team.
WE CAN EXCHANGE INFORMATION WITH OTHERS TO PROTECT AGAINST FRAUD OR CREDIT RISKS.
As part of the Services provided, we operate tracking software and tracking information via a third party provider (Google Analytics) but we ensure that they have sufficient measures in place to look after the data and information on your behalf and this will only be used as authorised by us. This organisation will not be able to use the information for its own benefit. Our company is registered in England and Wales, but we also provide our Services to other countries within the European Union and internationally, you also agree that we may disclose your personal data to other persons if this is required by law or where a legitimate interest is served.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
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 that 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.
When you submit information via our Website, you may be given options to restrict our use of your data. We aim to give you strong controls on our use of your data (including the ability to opt-out of receiving emails from us, which you may do by unsubscribing using the links provided above in this Policy. Under the GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes.
You can therefore ask us not to use your data by ticking the relevant boxes on our forms, or by contacting us at any time at firstname.lastname@example.org.
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 could refuse to comply with your request in these circumstances.
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.
AUTOMATED DECISION MAKING AND PROFILING
In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us. The right described in in this section does not apply in the following circumstances: a) the decision is necessary for the entry into, or performance of, a contract between you and us; b) the decision is authorised by law; or c) you have given your explicit consent. Where we use your personal data for profiling purposes, the following shall apply: a) Clear information explaining the profiling will be provided, including its significance and the likely consequences; b) Appropriate mathematical or statistical procedures will be used; c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
We take our responsibilities seriously where we collect any personal data relating to children. Where we collect any personal data in the course of our business and to enable us to provide our Services by collecting such data on a lawful basis, we shall ensure that we have your express consent as the parent of that child, and shall only collect the following data from you directly: Children’s age.
Where this data is required for the a purpose of tour reservations, we will take all reasonable steps to ensure that the data will be handled safely, securely, and in accordance with the child’s rights, our obligations, and the obligations of the third party under GDPR and the law.
ONLINE POLICY ONLY