Last Updated: September 21, 2018
Your privacy matters to us. When you use our services, you are placing your trust in us to ensure the privacy of your personal data and we are committed to protecting it.
Information we collect
Personal data you provide us
The sort of personal data we collect will be information such as name, address, email address, telephone number, date of birth, and personal travel arrangements. In addition, we may also be required to obtain your passport details. We will need to collect this information to arrange the travel and other services you are requesting.
In some cases, we may also need to collect more sensitive personal data such as information concerning medical conditions, disabilities and special requirements such as dietary requests, which may disclose your religious beliefs, so that we can consider your particular needs in relation to a booking.
Personal data we collect for legal, compliance, regulatory and crime detection and prevention purposes
We process your personal data so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order, and to protect our property, rights and interests as well as the property, rights and interests of other persons.
We also process your personal data for crime prevention and detection purposes, including the prevention of fraud for online payments, for identity verification, for credit checking and credit scoring purposes and accounting or audit purposes.
Personal data we collect from third parties
We collect personal data from third parties who you have authorised to provide your personal data to us (for example, this may be your travel agent or another person making a booking on your behalf, your travel companion, your travel coordinator, our promotion partners, social media and other digital website). We also collect personal data from individuals who may refer you as a friend to our products or services. We ask these individuals to confirm that you are happy to hear from us.
Sensitive personal data we collect
We do not generally collect sensitive personal data from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it and handle it with extra care. We also share this information with third parties (who help manage our business and deliver services such as those parties who provide wheelchairs at airports) and other companies (who help manage your booking or journey), and we transfer it globally.
Where you (or any passenger travelling) provides us with sensitive personal data you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which it was collected.
Personal data we collect automatically
When you use our services, we automatically collect certain information, including personal data, concerning the services you use and the way you use them.
Geo-location data, about your approximate location, as determined through data such as your IP address;
Usage and log data, such as the date and time you accessed our services, the duration of your session, data about clicks, the internet browser you use and which pages have been shown to you;
Data about your computer’s operating system, like application versions and language settings;
If you’re using a mobile device, we might also collect data about the type of device you are using and data such as the mobile network your device is using to access our services.
How we use your information
We use, store, and process information, including personal data, about you to create tailor-made travel itineraries, for marketing purposes, for data analytics, data profiling and to improve the quality of our service.
To create tailor-made travel itineraries
When putting together tailor-made travel itineraries, we may use your personal data to:
- Fulfil our contract with you and/or deal with your booking or intended booking, including processing your booking, sending you your itinerary or other details relating to your booking;
- Update you on changes to your travel itinerary (for example, if there is a change to your booking pre-travel; if a flight is delayed or cancelled);
- Manage your wider travel or services requirements (for example, liaising with and transferring your data to airlines, service providers and/or travel facilitators so that they can facilitate your booking and/or your travel arrangements so any disruption can be minimised), this includes when you book a tailor-made itinerary, hotel, car or another service which may be provided by us or third parties with us;
- Process payments for your booking, fulfil requests for refunds and for accounting or audit purposes;
- Personalise the service and offers you receive (for example, by being aware of previous travel experiences, transactions or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile);
- Communicate and interact with you at different times throughout your journey;
- Communicate with airlines, accommodation providers and other parties that are part of your journey regarding your experience, preferences, compliments or complaints.
For marketing purposes
We may use personal data to let you know about our products and services that we think may be of interest to you. This may be based on your preferences, derived from Cookies, inferred from your interactions with us, including on our social media accounts or market research. We may also let you know about our corporate services which we believe may be relevant to you in a professional capacity.
We also work with social media and other digital websites to provide you with advertisements within those websites. We provide them with your name and contact details (such as your email address or phone numbers). If these social media and digital websites match profile information provided by us with your profile information held by them then they will serve you our advertisements. The social media websites will not identify you or share other personal data in your social media account with us.
We will only send you direct marketing, whether about us, carefully selected third parties or partners, products or services, in accordance with your marketing preferences. We may contact you by email, SMS/text, social media, or through other communication channels that we think you may find helpful. If at any time you would like us to stop sending you marketing material, please contact us or choose the relevant “unsubscribe” option.
For profiling purposes
We use personal data such as your date of birth, gender, country of residence, transactions (for example, payments made with us and flights taken), information derived from Cookies and your preferences and behaviours for profiling. Some of the legitimate purposes we profile personal data include:
- To obtain a better understanding of what you would like to see from us and how we can continue to improve our services for you;
- To provide you with tailored content online and optimise your experience of our Website;
- To provide you with tailored advertisements on other websites you visit, such as social media websites;
- To share marketing material we believe may be of interest to you, including from our third-party partners;
- To help us operate our services more efficiently.
We will take steps to ensure that prior to profiling your personal data for a legitimate interest that our legitimate interest is not overridden by your own interests or fundamental rights and freedoms.
For data analytics
We aggregate personal data and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse website use, to improve our content and products and services, to customize our website’ content, layout, products and services, and to support our business operations and we may appoint third parties to do this on our behalf.
We gather certain usage information like the number and frequency of visitors to our website. This information includes which website you were redirected from, which web pages you visit during your session, what browser you are using, your device ID and your IP address. This collective data helps us to determine how our customers use parts of our website and do research on our users’ demographics, interests, and behaviour to better understand them. One of the ways we do this is by installing and using Cookies on your browser or device.
To improve the quality of our service
In our efforts to improve the quality of service we offer you, we may use your personal data to:
Improve the products and services we offer or help us to create new ones;
Conduct customer satisfaction surveys so that we can obtain a better understanding of how we can continue to improve the products and services we offer or help us to create new ones. During these surveys we may collect personal data from you relating to your thoughts/comments about your experience with us;
Improve our internal systems, for systems testing, IT maintenance or development training, benchmarking and performance measurement.
Legal basis for using your information
We will only collect, process, use, share and store your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
We need to use your personal data to perform a contract or take steps to enter into a contract with you. For example, to manage your enquiry, to manage your booking with us, to take payment for your booking, or to complete your travel arrangements;
We need to use your personal data for our legitimate interest as a commercial organisation. For example, we may record the calls of our travel consultants so that we can review how we handle calls. We may also capture your interactions with our website and booking journey via tools on our website in order to identify errors or issues and ensure your customer experience meets expectations. In all such cases, we will look after your information at all times in a way that is proportionate and that respects your privacy rights.
We need to use your personal data to comply with a relevant legal or regulatory obligation that we have; and
We have your consent to use your personal data for a particular activity. For example, where you consent to us sharing special offers with you which, we think, may be of interest.
How we protect and store your information
Protection of your personal data
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal data that you share with us and safeguard the privacy of such information. For example, the measures we take include:
Placing confidentiality requirements on our staff members and service providers;
Destroying or permanently anonymising personal data if it is no longer needed for the purposes for which it was collected; and
Following security procedures in the storage and disclosure of your personal data to prevent unauthorised access to it; and
Using secure communication channels on our website such as SSL (“secure sockets layer”) for transmitting data that is sent to us. SSL is the industry standard encryption protocol used to protect online transaction channels.