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Welcome to the Luxtripper privacy notice.
Luxtripper respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
We have a legal duty to protect personal data that we collect under the Data Protection Act 1998 (and any law which replaces it, including the new UK Data Protection Bill) (the “DPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”). For the purpose of the DPA and GDPR, we (Luxtripper Limited) are the data controller (in other words, the organisation that determines how your personal information is used). Our contact details are set out in part 1 below
Please also use the Glossary in part 10 to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Luxtripper collects and processes your personal data through your use of this website (www.luxtripper.co.uk), including any data you may provide through this website when you sign up to our newsletter, submit a travel quotation enquiry, request a callback to discuss your travel requirements, or purchase a holiday package.
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 notice together with any other privacy notice or fair processing notice 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 notice supplements the other notices and is not intended to override them.
Luxtripper Limited is the controller and responsible for your personal data (collectively referred to as “Luxtripper”, "we", "us" or "our" in this privacy notice).
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Our full details are:
Full name of legal entity: Luxtripper Limited
Name or title of [DPO]: Steven Pannell
Email address: email@example.com
Postal address: Gun House, 1 Artillery Passage, London E1 7LJ
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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 23rd May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. For example, where we are providing you with a honeymoon package, and your name and address changes, you will need to notify us to update our records. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites (e.g. Tourist Boards, Government web sites for travel advice etc), plug-ins (to help us track, analyse online activity, and improve our service) 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 notice of every website you visit.
2. The data we collect about you, how we use it and our lawful basis for processing
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
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 treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect the following Special Categories of Personal Data about you: race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We may however need to request health related data that is relevant to your travel requirements at the point of purchase. We do this only with your express consent so that it can be passed to either the airline, hotel or other travel supplier to assist with either dietary needs or where you may need assistance during your trip.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. How is your personal data collected?
We will collect personal information from you when you make an enquiry. This includes your name, contact information, destinations and countries you are interested in and any additional details of your travel plans which you voluntarily give to us. We may also collect details about the best time to contact you where you request a callback as well as what prompted you to contact us, and any other requests or comments that you may make.
We will use this information so that we can provide you with information that you have requested or contact you via phone or email if you have indicated you want to hear from us. We also collect personal information from you when you make a booking
We have a legitimate interest to use your information in this way to make sure that we are able to help you find the right destination and start to plan the best holiday for you. Where we rely on our legitimate interests, we'll always ensure that your rights are protected.
If you book a holiday with us, we will ask you to provide certain details about your travel arrangements. This is likely to include details of your passports, emergency contacts, travel insurance arrangements, preferences and special requirements, frequent flier club membership, and visa requirements. This will also include details of any other friends or family who are accompanying you as part of your booking. You must obtain explicit consent from your friends and family, before providing us with their details.
We will use this information to help us organise your trip, make bookings on your behalf and ensure that you (and any other friends or family accompanying you) receive the products and services set out in your itinerary. We collect this information so we can fulfil our contract with you and provide you with the quality of service we strive to provide.
Where you are a regular customer we may retain some of this personal information so that we can use it when you next book with us as we have a legitimate interest to improve our customer journey and ensure we look after our regular customers.
If you have made an enquiry with us, or booked a trip with us, we will send you via email details of any special offers, flash sales and inspirational travel ideas from time to time
We send you this on the basis of our legitimate interests, but you always have a right to object to direct marketing (see further below) and if you do not want to receive these emails please let us know using the contact details or using the ‘unsubscribe’ link on all of our emails we send you.
Website, Marketing and Advertising
Technical Data: We will collect certain technical information about you when you visit our website. This is likely to include: the internet domain you use, your IP address or other device identifier, your browser type and version (e.g. Chrome or Internet Explorer), the operating system and platform that you are using (e.g. Windows or Mac), the screen resolution of your device, the dates and times when you access our website, the full URLs of the pages you visit and the websites or links that you use to access our website, login information, details of products or services that are viewed and the length of visits to certain pages of the website.
We do not sell, trade, or rent your personal information to others
We use this information for site management and security purposes (such as troubleshooting and testing) as well as to help us improve our website.
We collect this information so we can fulfill our legitimate interests as a business to ensure that our website is fit for purpose and promotes our services appropriately for our customers, including by displaying information that our customers are interested in. We also rely on our legitimate interest in measuring customer satisfaction and troubleshooting any website issues. Where required by law, we may also seek and rely on your consent.
Marketing Data: We may collect and use information from various sources in connection with the marketing and advertising of our services. This may include your contact details (and your marketing preferences) to contact you with certain marketing messages (e.g. marketing e-mails). We may also use data we collect from you (either directly or via our website or advertising) to help us to measure the effectiveness of our advertising and to establish what interests you and what doesn't.
· We sometimes rely on your consent to contact you directly about our offering. In other scenarios in carrying out efficient and appropriate marketing and advertising for our services, we will rely on our legitimate interests, whilst always ensuring that your rights are protected. You can withdraw your consent or opt out of our direct marketing at any time through the 'unsubscribe' link in any marketing email or by contacting us direct.
We may collect your contact details when you enter into competitions or promotions, or complete surveys.
· We will rely on your consent or on our legitimate interests (depending on whether we are marketing or carrying out market research), whilst always ensuring that your rights are protected.
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 a holiday quotation from us or made a travel booking with 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.
Social Media: We may collect details about you, such as your user name, when you engage with us on social media (by mentioning or tagging us in a post or contacting us directly) this is so that we can respond to any comments and queries you have.
· We rely on our legitimate interests to do this as we want to ensure our customers have the best possible experience, whilst always ensuring your rights are protected.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources, as set out below.
(a) analytics providers such as Google analytics software based outside the EU];
(b) advertising networks such as Google, Facebook, Instagram, Twitter etc based inside or outside the EU; and
(c) search information providers such as Google and Bing based inside or outside the EU.
· Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Experian based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
· Where we need to perform the contract we are about to enter into or have entered into with you.
· Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· Where we need to comply with a legal or regulatory obligation.
There are several grounds on which Luxtripper will store and use your personal data. As follows:
· Consent: for certain types of processing (e.g. marketing activities), we rely on your consent to use your data. You may withdraw your consent at any time by contacting firstname.lastname@example.org.
· Contract: much of the time, our use of your personal data will be because of the contract between us – that is, in relation to your holiday booking. We will usually retain relevant data for up to seven years from the date the contract completes – e.g. the last day of your holiday.
· Legal obligations: we are under certain binding legal obligations, such as accounting to the government for tax and making financial records available for audit. In such cases, we are typically obliged to retain data for up to seven years from the date of transaction.
· Legitimate interests: we use data to manage our operations and to make business process improvements. Our legitimate interests will not override your right to privacy.
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 (email@example.com).
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal 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 for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us (firstname.lastname@example.org) 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.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your enquiry or booking including:
(a) Create and provide a travel itinerary
(b) Manage payments, fees and charges
(c) Collect and recover money owed to us
(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:
(b) Asking you to leave a review or take a survey
(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
(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) 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
(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
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
Necessary for our legitimate interests (to develop our products/services and grow our business)
You can ask us to stop sending you marketing messages by following the opt-out links on any marketing email sent to you or by contacting us (email@example.com) at any time.
Where you opt out of receiving these marketing emails, this will not apply to personal data provided to us as a result of an enquiry or holiday purchase, or other related transaction.
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 (firstname.lastname@example.org).
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
· External Third Parties as set out in the Glossary.
· Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. International transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, where we don’t have we will ensure:
· That we have your explicit consent to do so; or
· The transfer is necessary for the performance of our contract with you; or
· The country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection; or
· The personal data is transferred to a United States company which has signed up to the Privacy Shield; or
· The personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have; or
· We are obliged to provide the personal data to a government / public authority in order to provide your holiday. We will not, however, pass any information on to any person who is not responsible for part of your travel arrangements unless we are legally obliged to do.
7. 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 disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal data. This means that the retention periods will vary according to the type of personal data we are processing. For example, some transaction information will be kept for a number of years in order to comply with various finance and tax related obligations. If you need more information on this, please contact: email@example.com
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Those rights may include, a right to:
· 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 us (firstname.lastname@example.org).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/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 in respect of specific activities by contacting us (email@example.com).
Performance of Contract means processing your data where it is necessary for the performance of a contract e.g. where you make a purchase for a holiday to which you are a party or to take steps at your request before entering into such a contract e.g. where you request a holiday quotation from us.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
External Third Parties
· Service providers acting as processors who provide IT infrastructure and hosting services Inside and outside the EEA and in such cases have been verified as GDPR compliant.
· Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
· HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
· Travel suppliers for flights, hotels, transfers and any other ancillary services associated with the customer quotation or booking which may reside inside or outside the European Economic Area (EEA)
· Any other third parties if necessary to comply with legal obligations, or to perform a contract, for example, we are required to provide airlines with a passenger mobile phone number and email contact details under IATA Resolution 830d for the airline to inform the passenger of any operational difficulties.
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 erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
· Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
· Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
· Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
· Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Changes to our privacy notice
We keep our privacy notice under regular review and updates will be available on our web page. This privacy notice was last updated on 20 May 2018.