This policy also tells you about some of the key rights which you have under data protection laws. Until 25 May 2018, the key data protection law is the UK Data Protection Act 1998. From 25 May 2018 onwards, you and your personal data will be protected by the EU General Data Protection Regulation (which is otherwise known as GDPR) and a new UK Data Protection Act. In this privacy notice, we refer to this legislation as data protection laws.
What is our role in relation to your personal data?
For the purposes of data protection laws, we, Sommet, are a data controller in respect of the personal data you provide us with.
What personal data will we collect from you and how will we do this?
In order to respond to an enquiry, process and fulfil your booking or send you promotional material, we need to collect personal data from you. When we refer to personal data, we mean any information which relates to an identified or identifiable individual.
You may provide personal data to us in various ways. This may be provided over the telephone, on-line through our website or in emails to us.
Depending on what’s required, the personal data we collect may include names and contact details (such as telephone numbers, postal and e-mail addresses) and credit/ debit card or other payment information. It may also include information relating to any disability or medical condition which may affect travel arrangements and dietary restrictions which may disclose your religious beliefs. This sort of information is regarded as sensitive personal data. All references in this privacy notice to personal data include sensitive personal data unless otherwise stated.
Examples of when and how we may collect your personal information include the following:
- If you wish to receive a newsletter we will ask for your name, address and e-mail address. This is so we can effectively e-mail the requested items.
- If you submit a holiday enquiry form we will ask for your name, telephone number and e-mail address. This is so we can effectively respond to your request.
- If you want to make a booking with us, we will ask for the personal information of all persons travelling. This is likely to include the personal data set out above. This is required so that we can make and provide your holiday arrangements.
- If you submit feedback to us, we will ask for your name and email address in order to effectively respond to your feedback.
Is there any other personal information you may collect about me?
The information collected by cookies and web beacons is not personally identifiable, it includes general information about your computer settings, your connection to the internet e.g. operating system and platforms, IP address, your browsing patterns and timings of browsing on our website and your geographical location.
Who will we provide your personal data to?
Where you make a booking or booking enquiry, appropriate personal data might be passed on to the relevant suppliers (such as hotels, car hire companies etc) and any other third party (such as banks and/or credit card companies) who need this information so that your chosen arrangements can be booked and provided or your booking enquiry answered. Once your booking has been made, your personal data may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law. Certain information may also be passed on to security or credit checking companies.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purpose of providing their services and does not collect any personal data from you in the course of performing their services. If we cannot pass personal data to the relevant suppliers or any other third party as applicable, whether in the EEA or not, we will be unable to fulfil your booking. In making your booking, you consent to your personal data being passed on to the relevant suppliers and other third parties.
Where will we process your personal data?
Your personal data may be stored, used and otherwise processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein. We may also store, use or otherwise process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a United States company which has signed up to the Safe Harbour scheme or (3) 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 (4) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Can we use your personal data to send you information about our holidays or other services in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so. You may provide your consent by opting to receive marketing material either on-line or by telephone.
Can you withdraw your consent to our processing your personal data?
Yes, you can withdraw your consent to receiving marketing material or other communications from us, either generally or in any particular way, at any time by e-mailing us at email@example.com. Alternatively you can telephone us.
How can you find out what information we are holding about you?
You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within one month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further two months.
What should you do if the personal data we are holding is inaccurate, out of date or incomplete?
If you believe this is the case, please tell us by letter or e-mail as soon as possible. We will rectify the problem within one month or within three months if the rectification request is complex.
How long can we retain and process your personal data?
We will not keep and use your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
Where you have provided your personal data to enable us to provide the holiday arrangements or other services you have contracted, we are entitled to retain this information for a period of ten years after the end of those arrangements. In certain limited circumstances, we may be able to retain it for a longer period.
Can you ask us to delete your personal data?
Yes, you can ask us to remove your personal data in certain circumstances for example where you have withdrawn your consent to our further using this for marketing purposes. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.
What should I do if I have a complaint about the processing of my personal data?
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to firstname.lastname@example.org. We will investigate and respond to you as soon as we reasonably can. If you remain dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see www.ico.org.