Here at Travelsoon.com we pride ourselves on our customer service. This includes how we handle store and pass on your personal information. We try to be clear about how we use your information, to give you choices about how we use it, and to ensure its security.
Scope of this policy
Who are we?
We are Travelsoon.com, a trading name of Travelbugz LTD a company incorporated in England and Wales under company number 04714191 . You’ll find our registered address below
How to contact us
FAO: The Data Protection Officer
Address: 2nd Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, United Kingdom, WH10 67Z
What types of information do we collect about you?
The type of information we collect about you depends on the nature of your business and/or contact with us. Depending on the interaction, we collect any of the following:
- Your details. . Your name, email address, address, telephone number, date of birth, hotel room preferences, payment details, your reasons for travel, not limited to but including (for a wedding, birthday or anniversary), meal and dietary requirements if necessary, information about your health to the extent that it’s relevant to your fitness to travel, your itinerary or to notify airlines and suppliers to provide you with special assistance where requested/required
- Identification documents.If you are travelling on a route requiring Advance Passenger Information, your passport or identity card details including your passport number, the country in which your passport was issued and the expiry date;
- Details about the services you arrange with us.Your travel details, including details of your travel itinerary, where you are flying from and to, your booking information, any onward travel details if relevant (for example if you need our assistance for a connecting flight, if you’ve booked transportation or a tour with us), details of experiences or excursions booked through us, your baggage requirements, any upgrade information, your lounge visits, seat preferences, meal preferences or requirements, details of any special assistance you might need from us and any other information relevant to enable us to provide you with the travel or other services that you’ve arranged with us;
- Your interactions with us.Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or simply verbally to one of our agents);
- Job applications.If you apply for a job with us, your CV, work history, educational details and the role you’re applying for; and
- Your use of our website and services.Details of the way in which you use our site, call centres and/or social media pages
The Ways We Collect Information From You
- How we collect information about you will depend on how you interact / contact us. Depending on the circumstances, we collect information in any of the following ways:
- When you browse our site or call our call centre and request a quote
- When you book or search for a holiday or other service (such as a flights, car hire, cruise, hotel, transportation or special assistance) via our site or our call centre,
- When you partly fill out the booking information on our site but do not complete the booking;
- When you apply for a job with us by email or via our website
- When you contact us via our call centres, press office, social media, post, email
- When you sign up to receive email updates, participate in any of our competitions, promotions (for example via any social media channels, email or our site), surveys or market research
- When you provide us with information about an accident, illness or incident that occurred in connection with your holiday
- When you make a complaint via a third party (such as an airline, hotel or one of our advertising platforms)
UNDER WHICH CIRCUMSTANCES DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?
In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:
- Information about your health (if you ask us to request for you special assistance during your holiday, or to determine your fitness to travel, or if you specify a meal preference that indicates a medical condition such as celiac disease); and/or
- Information about your religion (if you request/specify a meal preference that indicates a particular religion such as a kosher or halal meal).
We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it
HOW DO WE USE YOUR PERSONAL INFORMATION
For what purposes do we use your information?
We’ll use your information for a variety of different purposes, some of which will depend on the services that you purchase from us. This includes:
- To manage your booking with us. We will use your information to provide you with any services that you request or purchase from us. This includes booking your flight, hotel, arranging a tour, transportation/transfers or car hire, and issuing you with tickets (on the basis of performing our contract with you), and providing you with any special assistance (where you provide your consent);
- To send you service communications and support services. . We will use your information to send you any communications relevant to the services you’ve requested or purchased from us. This includes sending you an email to notify you of changes to your itinerary, or providing you with a voucher, ticket or e-ticket. We will also provide you with customer service and support, deal with your enquiries, scheduling changes, complaints, comments or observations shared with us (on the basis of performing our contract with you or on the basis of our legitimate interests to provide you with customer service);
- To send you marketing communications. We will use your information to keep you up to date with the latest news, events, offers, sales, brochures, promotions and competitions that we think might be of interest or relevant to you (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so)
- To provide assistance with online bookings. . We collect your information when you fill in the required fields on our online booking forms but do not complete your booking or transaction in order to offer our assistance in case you are experiencing difficulties with our website (where we have your consent to do so)
- To personalise your customer experience. We use your information to provide you with a more personalised service. For example tailoring the communications that we send to you with your preferred destinations, serving you only with advertising that we think you might like and/or enhancing your holiday experience (on the basis of our legitimate interests to present you with the right kinds of products and services)
- To Protect Both Us And You. We reserve the right to record calls to our call centre and/or monitor calls for the purposes of security to protect the interests of either ourselves or you.
- To process your job applications. We will use your information to process any job applications that you submit to us, whether directly or via an agent (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new staff)
- To ensure security and protect our business interests.In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development
- To conduct research. We use your information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you choose to participate in customer surveys, consumer focus groups and research (on the basis of our legitimate interests to improve our products, services and customer service);
- To comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or requests from the relevant authorities (on the basis of our legitimate interests to comply with a legal obligation).
On what grounds will we process your information?
We will use your information for the purposes listed above, either:
- For the performance of your contract with us and the provision of our services to you;
- To comply with a legal obligation, we have
- For our legitimate interests;
- To protect your vital interests;
- With your consent by opting in to marketing material
- For establishing, exercising or defending legal claims; and
- For reasons of substantial public interest.
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties, but this is provided your interests and fundamental rights do not override those interests. By "legitimate interests" we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers. This includes
- Using your information to protect you against fraud when you transact on our site, and to ensure that our systems and sites are secure;
- Determining the effectiveness of our site / tools / services and improving the security and optimisation of our network, sites and services;
- Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;
- Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing and serving you with advertising that is relevant and likely to be of interest to you; and/or
- Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business.
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours, and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as when we have your consent, or we have a legal obligation to use your information in that way). If you have any concerns about our processing please contact us using the details within this policy
From the 25th May 2018 you will have the right to object to us using your information for our legitimate interests. However your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.
WHO DO YOU SHARE MY INFORMATION WITH?
In connection with the purposes and on the lawful grounds described above, we share your personal information with the following third parties:
- Third party suppliers that we work with to provide your booking and our other services to you. We may share your information with third party suppliers suppliers that provide us with services in connection the provision of our services to you. This includes for example: airlines, hotels, tour operators, transport companies, excursion providers, airport authorities, car hire companies, ground handling agencies, cruise companies and transfer operators;
- Other third party suppliers that we work with in connection with our business. We share your information with third party suppliers that provide us with services in connection with our business and the provision of our services to you. This includes for example: marketing agencies and/or companies that run our marketing campaigns, IT developers, service providers and hosting providers, third parties that manage promotions or competitions that we may run, third party software companies that provide us with applications on a white label basis, advertising providers and networks, ground agents, site analytics providers, medical service providers and credit card screening companies;
- Airports, immigration / border control and/or other government authorities. Some destinations require airlines, cruise lines and tour operators to provide "Advance Passenger Information" about you to the border/immigration authorities of the country of your travel destination. Advance Passenger Information comprises the basic information contained in your passport that you would be required to present on your arrival. In addition, laws in certain destinations such as the USA and other countries require airlines to provide certain additional advance information about you and your travel arrangements. We will provide this information where we are required to do so.
- Third parties for marketing. We share your information with selected third parties when we have your consent for marketing purposes
- Courts or advisors. We share your information with other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law
Where we do share your information with third parties, we will require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).
When you’ll hear from us
We will keep you up to date with our latest offers, sales, promotions and competitions that we think might be of interest to you if you have indicated that you are happy to receive marketing communications from us – that is, if you have:
- Purchased services such as a holiday from us and have not told us that you don’t want to hear from us; or
- Signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.
Opting out of or withdrawing your consent in relation to marketing
If you no longer want to hear from us, you can opt out or unsubscribe by:
- Following the "unsubscribe" link contained in any marketing communications that you receive from us;
- By Email to: email@example.com
Third parties and marketing
We might rely on third parties to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.
What we collect when you interact with our sites
As you may already know, most sites and apps collect certain information automatically in log files about the way in which you interact with them. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, unique device identifiers) browser type, referral source, length of visit to the site or app, number of page views, the search queries you make, and similar information.
This information will be collected by us or by a third party site analytics service provider and will be collected using cookies.
As we’ve described above, we use this information to save your settings, such as the last holiday you searched for so you can find it easily the second time, give you access to more great features on our website, help improve our functionality and services, run diagnostics, analyse trends, track visitor movements, gather broad demographic information and personalise our services.
What do we mean by "cookies"?
Cookies are small amounts of information in the form of text files that we store on the device you use to access our site or our marketing communications. Cookies allow us to monitor your use of our services and improve them. For example, a temporary cookie is also used to keep track of your "session". Without that temporary cookie you will not be able to purchase holidays or other services via our site.
If you don’t want cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings, please consult the "Help" section of your internet browser or visit http://www.aboutcookies.org. Please note that if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the site.
Overview of your rights
You have certain rights in respect of the personal information that we hold about you, including:
The right to ask us not to process your information for marketing purposes;
The right to request access to the information that we hold about you;
The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
In certain circumstances, the right to ask us to stop using information about you; and
The right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.
Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.
Upcoming new rights…
From 25 May 2018, you will have certain additional rights in respect of the information that we hold about you, including:
- The right to withdraw consent that you have provided to us to use your personal information;
- The right to object to our using of your information on the basis of our legitimate interests (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;
- The right to receive a copy of any information we hold about you
- The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.
How to exercise your rights
- Contacting us. You can exercise your rights by contacting us using the details in the About Us section on our website, or by checking the applicable boxes on forms that we use to collect your information, or to tell us that you don’t want to participate in marketing. Or by E-Mailing GDPR@travelsoon.com
- Updating your own details. Alternatively, if you’d prefer not to contact us, you may be able to do it yourself depending on the nature of your request. For example:
- You can update the details we hold about you by logging into your booking via the "Manage your booking" tab on our site and following the instructions to edit your details, or contact us to change details of your booking; and
- If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.
- We will comply with your requests unless we have a lawful reason not to do so and you will be informed when this has been done.
What we need from you to process your requests
Please be aware that we may need you to provide additional information such as to confirm your identity and/or to confirm what information you wish to access in order to process your SAR request.
WHERE DO WE STORE YOUR INFORMATION?
Our service providers and suppliers
A list of the countries outside of the EEA to which we may transfer your personal information is available
As we outline above, in certain circumstances, we are required to share information about you with immigration or other government authorities of your destination.
HOW DO WE LOOK AFTER YOUR INFORMATION?
Our security measures
We strive to constantly keep our security practices under review to make sure that we’re keeping your information as safe as possible. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. We
- Ensure the physical security of our offices and any other sites;
- Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions;
- Ensure appropriate access controls so that access to your information is only granted to those of our staff that need to use it in the course of their work
- Carry out regular penetration testing of our systems and third party reviews of our software
- Maintain internal policies and deliver data protection and confidentiality awareness to make sure our staff also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.
How you can help ensure the security of your information
You can play a part in helping to keep your information safe. Here are a few useful starting points:
- Choose strong passwords compromising of UPPER, lowercase and $pecial characters and change them regularly
- Keep your booking reference confidential, and avoid sharing with anyone else or using your password for multiple accounts
- Log out of "Manage my booking" after each session if you are using a shared computer
- Keep your devices protected by ensuring that you’re using the latest version of your operating system and have suitable anti-virus software/security software if applicable
- Be alert to any fraudulent emails that may appear to be from us, but aren’t. Any emails that we send will come from @travelsoon.com
Links to other sites and resources
How Long Is My Information Kept For
We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for the purposes of exercising our legal rights or defending ourselves against potential claims. We operate a data retention policy For example:
- We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis unless we are required to retain it for evidential or legal purposes
- We retain a list of individuals who no longer wish to be contacted by us. We need to keep this information to comply with their wishes not to contact them indefinitely
- We retain any unsuccessful CV’s or job applications that we receive for a period of up to 1 year in case you might be suited to another opportunity that becomes available in the future. If you send your CV by post and do not hear from us within 48 hours your CV with be shredded inline with new privacy laws.
However, if you’d still like to make a formal complaint or have concerns regarding the ways in which we use your information, you can contact the Information Commissioner’s Office (also known as the "ICO"). The ICO is an independent authority and the UK’s supervisory authority for information rights.
You can register your concerns on the ICO site by clicking here.