OUR DATA PROTECTION COMMITMENT
At True North Travel Limited we understand the concerns about how data may be stored, sent and used by companies. We are committed to complying with all data protection laws and want you to feel confident in the measures we are taking to uphold your data privacy rights.
HOW TO NAVIGATE THIS DOCUMENT
Privacy policies don’t need to be confusing and we don’t think you should have to read through lots of complicated paragraphs to understand how we handle your data.
We think this document highlights the most important points to be aware of. However, if you want more detail about a specific topic you can scroll down to the relevant selection.
WHAT INFORMATION MIGHT WE COLLECT ABOUT YOU?
We do our best to keep the information we collect about you to the minimum necessary.
The information we collect depends upon how you are
interacting with us. For example, if you’re booking a holiday or tour with us
we are likely to ask for more information than if you’re only requesting a
brochure or browsing our website. We may collect, use, store and transfer
different kinds of personal information about you and people in your tour party
which we have summarised in the box below.
Details about you: Your first and last name, marital status,
title, gender, e-mail address, telephone number, date of birth, your reasons for travel, meal and other travel preferences or
Payment details: Your bank details and payment card details
when making a booking with us. Details about payments to and from you and other
details of products and services you have purchased from us.
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
Details about your booking with us: Details such as where you are flying from and to,
your booking information (including anyone else on the booking), any onward
travel details if relevant, details of experiences or excursions booked through
us, baggage requirements, upgrade information, lounge visits, seat preferences,
meal preferences or requirements, details of any special assistances required
and any other relevant information so that we can provide you with the travel
or other service you have arranged with us.
Details from your interactions with us: Information about interactions or conversations
with us and our staff, including when you make enquiries, comments, complaints
or submit feedback to us. This could also include username and password and
your interests, marketing preferences and survey responses.
Your use of our systems and services: This includes how you use our website, mobile apps, trip platform, contact centres and/or social media pages, IP addresses and information
you may post on social media.
Job applications: If you apply for a job with us, your CV, work
history, educational details and the role you are applying for.
Special types of data: In some circumstances we may need to collect information from you that is deemed sensitive. For example, we might collect:
We try to limit any sensitive personal data we collect to the minimum possible. Unless we have a specific lawful reason to use this information, we will ask for your consent to collect it.
If you fail to provide personal data
Where we need to collect personal data by law, or
under the terms of a contract we have with you and you fail to provide that
data when requested, we may not be able to perform the contract we have or are
trying to enter into with you (for example, to provide you with goods or
services). In this case, we may have to cancel a product or service you have
with us but we will notify you if this is the case at the time.
HOW DO WE COLLECT YOUR INFORMATION AND WHY?
Depending upon your interactions with us, we might
collect information in the following ways:
Direct Interactions: You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone and email or otherwise, this includes personal data you provided when you:
Automated technologies or interactions
Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:
a) airlines, hotel providers or other parties we work with if you make a complaint to them;
b) analytics providers
WHAT DO WE USE YOUR INFORMATION FOR?
Under data protection laws we are allowed to use personal information only if we have a proper reason to do so such as:
Generally, we do not rely upon consent as a legal basis for processing your personal data other than in relation to sending our own or third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below 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. 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.
WHAT ABOUT OUR MARKETING PRACTICES?
When we will get in touch with you
One of the other reasons we sometimes collect your information is so that we can form a view on what we think you may want or need, or what may be of interest to you. With this information we decide which products, services and offers may be relevant for you and what marketing you may be interested in.
We keep you up to date with our latest offers, partnerships, sales, promotions, competitions that we think might be of interest/relevance to you.
We will only contact you in this way if:
What if I don’t want to receive marketing?
We never want to send our marketing to someone who isn’t interested in receiving this content. If you have decided that you no longer wish to hear from us, you can unsubscribe from marketing by clicking on the ‘unsubscribe’ link included in all of our e-mails or by contacting us.
Third parties and marketing
We do not pass your information to other parties for marketing purposes unless you agree to us doing so. We will get your express opt-in consent before we share your personal data with any company outside True North Travel Limited for marketing purposes.
Sometimes we may use 3rd parties to send the communication to you on our behalf. We use a third party provider, to deliver our brochures/monthly e-newsletters However, these companies do not have the right to send marketing to you for their own purposes.
The marketing material we send to you we may
occasionally also include information about selected business partners who
provide services closely related to our own product.
WHEN DO WE SHARE YOUR PERSONAL DATA?
In order to provide you with the services and on the lawful grounds described above, we may share your personal information with third parties such as:
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.
WHEN DO WE SEND YOUR DATA OUTSIDE THE EEA?
We will only send your data outside the European Economic Area (“EEA”) to:
Some of our external third parties are based
outside the EEA so their processing of your personal data will involve a
transfer of data outside the EEA. If we do transfer information to parties
outside of the EEA, we will make sure that it is given a similar degree of
YOUR PERSONAL DATA RIGHTS
What are your rights?
We want you to feel reassured that you have control of your personal information. With this in mind, we have explained below the rights you have in relation to the personal information we hold about you:
How can you exercise your rights?
You can exercise these rights over your data by contacting us or by checking the applicable boxes on forms where we collect your information or to tell us that you don’t want to participate in marketing. You can also unsubscribe from any marketing circulation lists you are on by scrolling to the bottom of the e-mail and clicking the ‘unsubscribe’ link.
We will comply with your requests, unless we have a
lawful reason not to do so. We may need you to provide additional details to
confirm your identity in order to process your request.
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.
HOW LONG DO WE KEEP YOUR DATA FOR?
We will only keep your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal accounting or reporting requirements.
We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time we hold it for.
By law we have to keep basic information about booking and our customers for six years for legal claims and tax purposes.
In some circumstances we may anonymise your
personal data (so that it can no longer be associated with you) for research or
statistical purposes in which case we may use this information indefinitely
without further notice to you.
HOW TO CONTACT US
We have appointed a Data Protection Manager 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.
Data Protection Manager, True North Travel Limited, Unit 10 English Business Park, English Close, Hove, East Sussex, BN3 7ET
Please contact us in the first instance if you have
any concerns. If we are unable to resolve your concern, you have the right to
make a complaint to the Information Commissioner’s Office (ICO), the UK
supervisory authority for data protection issues (https://ico.org.uk/) or the relevant data protection authority where you
OTHER PRIVACY INFORMATION
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 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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
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.