1 ABOUT WOTTON TRAVEL LIMITED
1.2 www.wtlholidays.com and www.wtlbusinesstravel.com (the “Websites”) are owned by Wotton Travel Limited ("Company", "we" or "us"), a company registered in England and Wales under company number 01973158 whose registered office is at New Mills, Wotton Under Edge, Gloucestershire, GL12 8JR .
1.4 The data controller (as defined under European Data Protection Legislation) for Company is Wotton Travel Limited. We are registered as a data controller with the Information Commissioner's Office and our registration number is Z7000102.
2.2 We process your personal data on the basis that you have provided your consent for us to do so for the purposes set out below when you submitted your personal data to us. You may withdraw your consent to this processing at any time by contacting us at 01453 525 200 or email@example.com. If you do withdraw your consent, we may still be able to process some of the data that you have provided to us on other grounds and will notify you of these at such time.
2.3 If you consent to us contacting you, we will always aim to be respectful, relevant and appropriate. If at any time you do not think that we have complied with this, please contact us straight away to let us know.
3 INFORMATION WE MAY COLLECT ABOUT YOU
3.1 We may collect and process the following data:
(a) Information you give to us. You may give us information about you by filling in forms (e.g. on our ‘Contact Us' page), by contacting us by phone, email, in person or otherwise. The information you give to us may include:
(i) Enquiry: your name and title, contact information, including telephone number and email address, details of your interests and communication preferences;
(iii) Enquiries and complaints: personal details, contact information, enquiry or complaint details
(iv) Health and welfare: medical, dietary and mobility details provided to us in order to arrange the booking; and
(v) Employment: if you apply for a job with us, your employment details, e.g. date of birth, employment history, qualifications.
(b) Information we collect about you. Your interactions with us may result in personal data being collected and stored by us. Examples include:
(i) Booking party details, reference numbers, travel itineraries, flight bookings, visa details;
(ii) web usage information (e.g. IP address), your login information, browser type and version, time zone setting, operating system and platform; and
(iii) information about your visit, including the full Uniform Resource Locators (URLs) clickstream to, through and from the Websites (including date and time); time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs).
(c) Information we receive from other sources.
We also work closely with third parties (e.g. airlines and insurers) and may receive information about you from them.
5 HOW WE WILL USE YOUR INFORMATION
5.1 We may use your information for the following purposes:
(a) to respond to any query that you may submit to us;
(b) where it is necessary for us to do so to enable us to provide you with the service that you requested from us e.g. to manage your booking with us. This includes booking your flight, cruise or hotel, arranging a tour, transportation or car hire, and issuing you with your tickets (on the basis of performing our contract with you), and providing you with any special assistance (where you provide your consent);
(c) 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 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);
(d) we may, from time to time, be asked to process personal data relating to criminal history of individuals, for example, some countries require this information as part of their visa process;
(e) to ensure that our Websites' content is presented in the most effective manner for you and your computer;
(f) to send promotional material about new products, special offers or other information which we think you may find interesting, but only if you have given us your consent to do so;
(g) to administer the Websites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey responses;
(h) as part of our efforts to keep the Websites safe and secure;
(i) to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
(j) to comply with the law; and
(k) as we feel is necessary to prevent illegal activity or to further our legitimate interests.
6 DISCLOSURE OF YOUR INFORMATION
6.1 We may share your personal information with any member of Company group, which means our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
6.2 If we share your information with third parties they will process your information as either a data controller or as our data processor and this will depend on the purposes of our sharing your personal data. We will only share your personal data in compliance with the applicable data protection legislation.
6.3 We may disclose your information to third parties when:
(a) we need to provide your booking and other services to you;
(b) you book services, excursions and other activities;
(c) we perform certain activities on your behalf, for example processing payments, sending postal mail and-email communications;
(d) you specifically request this;
(e) other Company products and services may interest you;
(f) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
(g) if the Company or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets; or
(h) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation or to protect the rights, property or safety of the Company, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6.4 The third parties include:
(a) airports, immigration/border control and/or other government authorities;
(b) airlines, hotels, tour operators, transport companies, excursion providers, airport authorities, insurance companies, car hire companies and cruise companies;
(c) business partners, clients, suppliers and sub-contractors for the performance of any contract we enter into with them or you; and
(d) analytics and search engine providers that assist us in the improvement and optimisation of the Websites.
6.5 We may share some broader statistics and customer profiling information with third parties and other companies, but the data is anonymised, so you would not be identifiable from that data. We will not rent or sell our users' details to any other organisation or individual.
7 STORAGE OF YOUR PERSONAL DATA
7.2 We follow strict security procedures as to how your personal information is stored and used, and who sees it, to help stop any unauthorised person getting hold of it. All personal information you register on our Websites will be located behind a firewall. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure and although we do our best to protect your personal data, we cannot guarantee the security of your data. So we cannot accept any liability for the loss, theft or misuse of the personal information which you have registered on our Websites if there is a security breach.
7.3 We will keep your information stored on our systems for as long as it takes to provide the services to you and for a limited period afterwards for legal and tax purposes. The third parties we engage to provide services on our behalf will keep your data stored on their systems for as long as is necessary to provide the services to you. We will not store your information for longer than is reasonably necessary or required by law.
8 YOUR RIGHTS
8.1 Even if you have accepted the processing of your personal data for marketing purposes, you have the right to ask us to stop processing your personal data for such purposes. You can exercise this right at any time by contacting us at 01453 525 200 or firstname.lastname@example.org.
8.2 The Websites may, from time to time, contain links to and from the websites of advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
8.3 You are entitled to receive the personal data that you have provided to us in a structured, commonly used and machine-readable format, and to transmit that data to another data controller. The types of data that can be provided are those set out at paragraph 3.1 above. You can exercise this right by contacting us at 01453 525 200 or email@example.com.
9 ACCESS TO INFORMATION
9.1 European Data Protection Legislation gives you the right to access information held about you. You are entitled to be told by us whether we or someone else on our behalf is processing your personal information; what personal information we hold; details of the purposes for the processing of your personal information; and details of any third party with whom your personal information has been shared. In the event that an access request is unfounded, excessive or especially repetitive, we may charge a ‘reasonable fee' for meeting that request. Similarly, we may charge a reasonable fee to comply with requests for further copies of the same information (that fee will be based upon the administrative costs of providing the information). Sometimes you may be asked to provide proof of identity before we show you your personal information - that's so we can prevent unauthorised access. Your rights to access, rectify such information, object or cancel the information we hold about you can be exercised at any time by contacting us at 01453 525 200 or firstname.lastname@example.org.
Name: The Director of Wotton Travel Limited
Address: 4 High Street
Email address: email@example.com
Telephone number: 01453 525 200
Alternatively, you can contact us through the “Contact Us” section of the Websites.