GB TOURS Data Privacy Policy

1. POLICY OVERVIEW

1.1 Scope of this policy

This Privacy Policy concerns all the information that we collect, use and otherwise process about you as a customer, potential customer or just enquirer (whether as a direct booker, site visitor, enquirer to our booking office in person or by telephone, job applicants or otherwise).

We've approached our Privacy Policy with clarity in mind. We haven't provided lengthy detail of all aspects of our collection and use of your information and any specific examples we provide aren't intended to be comprehensive lists. We're happy to provide any additional information or explanation needed and/or answer any questions you may have (please refer to the "ABOUT US" section below).

1.2 Policy updates

We keep this Privacy Policy under regular review to make sure we're being transparent about how we use your personal information. Any changes to our Privacy Policy will be reflected at https://www.gbtours.com/privacy.

2. ABOUT US

2.1 Who are we?

We are GB Tours. A coach holiday company, based in Birkenhead, Merseyside, England, United Kingdom.

2.2 Who’s the Data Controller?

For the purposes of data protection laws, we are the “Data Controller” of all personal information that we collect, use and/or otherwise process about you under this Privacy Policy.

2.3 How to contact us

If you have any questions about this Privacy Policy or the ways in which we handle your personal information, please contact us as follows:

FAO:	Data Protection Department
Address:	GB Tours, 254-260 Borough Road, Birkenhead, Merseyside CH41 2RB
Email:	dataprotection@gbtours.com

3. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

3.1 What types of information do we collect about you?

The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we collect any of the following:

• Details about you. Your name, email address, address, telephone number, date of birth, your hotel room preferences, payment details, your reasons for travel (such as for a wedding, birthday or anniversary), meal and other travel preferences or dietary requirements and, if necessary, information about your health to the extent that it’s relevant to your fitness to travel, your holiday itinerary or to provide you with special assistance;
• 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 expiry date;
• Details about the services you arrange with us. Your travel details, including details of your travel itinerary, where you are travelling from and to, your booking information, details of excursions booked through us, your luggage requirements, any upgrade information, seat preferences, meal preferences or requirements, details of any special assistance you might need from us and any other information relevant to enable us to provide you with the travel or other services that you’ve arranged with us;
• Your interactions with us. Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or simply verbally to our people);
• Job applications. If you apply for a job with us, your CV, work history, educational details and the role you’re applying for; and

4. HOW WE COLLECT INFORMATION ABOUT YOU

• How we collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we collect information in any of the following ways:
• When you book a holiday via our site, booking office or telephone service;
• When you apply for a job with us by email or post;
• When you contact us via our booking office, telephone service, social media, post or email;
• When you request a brochure, sign up to receive email updates, participate in our prize draw, surveys or market research;
• When you provide us with information about an accident, illness or incident that occurred in connection with your holiday;
• When you make a complaint to us via email or post in connection with your holiday;

5. IN WHAT CIRCUMSTANCES DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?

In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:

• Information about your health (for example if you ask us to provide you with special assistance during your holiday, or to determine your fitness to travel, or if you specify a meal preference that indicates a medical condition such as celiac disease); and/or
• Information about your religion (for example if you specify a meal preference that indicates a particular religion such as a kosher or halal meal).

We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it.

6. HOW WE USE YOUR INFORMATION

6.1 For what purposes do we use your information?

We’ll use your information for a variety of different purposes, some of which will depend on the services that you engage us for. This includes:

• To manage your booking with us. We will use your information to provide you with any services that you request or purchase from us. This includes booking your coach seats, cruise or hotel, arranging a visit or excursion and issuing you with your tickets/Confirmation of booking (on the basis of performing our contract with you), and providing you with any special assistance (where you provide your consent);
• 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 or letter by post to notify you of changes to your itinerary, or providing you with a voucher, ticket or booking Confirmation. 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);
• To send you marketing communications. We will use your information to keep you up to date with the latest news, events, offers, sales, brochures and promotions that we think might be of interest or relevant to you (either on the basis of your consent where we have requested it, or our legitimate interests to provide you with marketing communications where we may lawfully do so) (please see the “MARKETING” section below for more information);
• To personalise your customer experience. We use your information to provide you with a more personalised service. For example tailoring the communications that we send to you with your preferred destinations, serving you only with advertising that we think you might like and/or enhancing your holiday experience (on the basis of our legitimate interests to present you with the right kinds of products and services);
• To improve our customer service. We may record calls to our booking office Reservations Team and/or monitor calls for the purposes of improving our customer service, ensure quality assurance, training, security and for general business purposes (on the basis of our legitimate interest in improving our customer service);
• To process your job applications. We will use your information to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);
• To ensure security and protect our business interests. In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
• To conduct research. We use your information to carry out research about our services - if you choose to participate in customer surveys (on the basis of our legitimate interests to improve our products, services and customer service); and
• To comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or subpoenas (on the basis of our legitimate interests to comply with a legal obligation).

6.2 On what grounds will we process your information?

We will use your information for the purposes listed above, either:

• For the performance of your contract with us and the provision of our services to you;
• To comply with a legal obligation we have;
• For our legitimate interests (we explain what we mean by this below);
• To protect your vital interests;
• With your consent (see paragraph 8 for how to withdraw your consent);
• For establishing, exercising or defending legal claims; and
• For reasons of substantial public interest.

6.3 What do we mean by “legitimate interests”?

As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers. This involves:

• Using your information to protect you against fraud when you transact on our site, and to ensure that our systems and sites are secure;
• Determining the effectiveness of our site / tools / services and improving the security and optimisation of our network, sites and services;
• Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;
• Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing and serving you with advertising that is relevant and likely to be of interest to you; and/or
• Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours, and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as when we have your consent, or we have a legal obligation to use your information in that way). If you have any concerns about our processing please refer to details of “YOUR RIGHTS” section below.

As we outline in “YOUR RIGHTS” section below, from 25 May 2018 you will have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.

7. WHO WE SHARE YOUR INFORMATION WITH

7.1 In connection with the purposes and on the lawful grounds described above, we share your personal information with the following third parties:

• Third party suppliers that we work with to provide your booking and our other services to you. We may share your information with third party suppliers that provide us with services in connection the provision of our services to you. This includes for example: airlines, hotels, transport companies, excursion providers, airport authorities, insurance companies, ground handling agencies and cruise companies;
• Other third party suppliers that we work with in connection with our business. We share your information with third party suppliers that provide us with services in connection with our business and the provision of our services to you. This includes for example: IT developers, service providers and hosting providers, third party software companies that provide us with applications, ground agents, site analytics providers, medical service providers and credit card screening companies;
• Airports, immigration / border control and/or other government authorities. Some destinations require airlines, cruise lines and tour operators to provide “Advance Passenger Information” about you to the border/immigration authorities of the country of your travel destination. Advance Passenger Information comprises the basic information contained in your passport that you would be required to present on your arrival. In addition, laws in certain destinations such as the USA and other countries require airlines to provide certain additional advance information about you and your travel arrangements. We will provide this information where we are required to do so.
• Courts or advisors. We share your information with other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law; and
• Third parties which are successors of the business. Your information may be disclosed to any successors of our business, in the event of a re-organisation, merger or sale, for them to use for the purposes as set out in this Privacy Policy.

Where we do share your information with third parties, we will require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).

8. MARKETING

8.1 When you’ll hear from us

We will keep you up to date with our latest routes, offers, sales, promotions, that we think might be of interest / relevant to you if you have indicated that you are happy to receive marketing communications from us – that is, if you have:

• Purchased services such as a holiday from us and have not told us that you don’t want to hear from us; or
• Signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.

8.2 Opting out of or withdrawing your consent in relation to marketing

If you no longer want to hear from us, you can opt out or unsubscribe by:

• Following the “unsubscribe” link contained in any marketing communications that you receive from us by email;
• By Email to: dataprotection@gbtours.com
• By Post to: GB Tours, 254-260 Borough Road, Birkenhead CH41 2RB
• By Phone on: 0151 652 2222

8.3 Third parties and marketing

We will not share your information with any third parties for their marketing purposes.

9. YOUR RIGHTS

9.1 Overview of your rights

You have certain rights in respect of the personal information that we hold about you, including:

• The right to be informed of the ways in which we use your information, as we seek to do in this Privacy Policy;
• The right to ask us not to process your information for marketing purposes;
• The right to request access to the information that we hold about you;
• The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
• In certain circumstances, the right to ask us to stop using information about you; and
• The right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.

Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.

9.2 Some upcoming new rights…

From 25 May 2018, you will have certain additional rights in respect of the information that we hold about you, including:

• The right to withdraw consent that you have provided to us to use your personal information (refer to paragraph 6 to see when we are relying on your consent);
• The right to object to our using your information on the basis of our legitimate interests (see paragraph 6 above to see when we are relying on our legitimate interests) (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; and
• The right to receive a copy of any information we hold about you (or request that we transfer this information to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances; and
• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

9.3 How to exercise your rights

• Contacting us. You can exercise your rights by contacting us using the details in the “ABOUT US” section above, or by checking the applicable boxes on forms that we use to collect your information, or to tell us that you don’t want to participate in marketing.
• Updating your own details. Alternatively, if you’d prefer not to contact us, you may be able to do it yourself depending on the nature of your request. For example:
• If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.
• We will comply with your requests unless we have a lawful reason not to do so.

9.4 What we need from you to process your requests

Please be aware that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request.

10. WHERE IS YOUR INFORMATION?

10.1 Our service providers and suppliers

We are based within the European Economic Area (EEA). However, in certain circumstances information that we collect about you will be sent to and held in countries outside of the EEA where we work with suppliers and service providers that are either based outside of the EEA or have servers based outside of the EEA. Countries outside of the EEA protect information differently, and so where we do transfer your information to suppliers based outside of the EEA, we will take all steps necessary to ensure that it is adequately protected and used in accordance with this Privacy Policy, including but not limited to relying on any appropriate cross-border transfer solutions. A list of the countries outside of the EEA to which we may transfer your personal information is available here.

10.2 Destination territories

As we outline above, in certain circumstances, we are required to share information about you with immigration or other government authorities before we can deliver you to your destination.

11. HOW WE LOOK AFTER YOUR INFORMATION

11.1 Our security measures

We strive to constantly keep our security practices under review to make sure that we’re keeping your information as safe as possible. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. For example we:

• Ensure the physical security of our offices;
• Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions;
• Are a “PCI DSS” compliant company, meaning that we apply certain high standards of security in respect of your payment information;
• Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work;
• Carry out regular penetration testing of our systems and third party reviews of our software; and
• Maintain internal policies and deliver data protection and confidentiality training to make sure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.

11.2 How you can help ensure the security of your information

You can also play a part in helping to keep your information safe. Here are a few useful starting points:

• Choose strong passwords and change them regularly;
• Keep your booking references and passwords confidential, and avoid sharing them with anyone else or using your password for multiple accounts;
• Keep your devices protected by ensuring that you’re using the latest version of your operating system and have suitable anti-virus software, if applicable; and
• Be alert to any fraudulent emails that may appear to be from us, but aren’t. Any emails that we send will come from [*]@gbtours.com.

11.3 Links to other sites and resources

Occasionally content or links to other sites that are operated by third parties may be contained within our site . Please note that we do not control these third party sites or the cookies that such third parties operate and this Privacy Policy will not apply to them. Be sure to consult the Terms of Use and Privacy Policy of the relevant third party site to understand how that site collects and uses your information and to establish whether and for what purposes they use cookies.

12. HOW LONG WE KEEP YOUR INFORMATION FOR

We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims. We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example:

• We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis unless we are required to retain it for evidential or legal purposes;
• We retain a suppression list of individuals who no longer wish to be contacted by us indefinitely. We need to keep this information to comply with their wishes not to contact them;
• We retain any unsuccessful CV’s or job applications that we receive for a period of up to 2 years in case we think you might be suited to another opportunity that becomes available in the near future;

13. COMPLAINTS

If you have any comments, questions or concerns about the contents of this Privacy Policy or the way in which we use your information, we encourage you to contact us using the details in the “ABOUT US” section above to see if we can help resolve the issue in the first instance.

However, if you’d still like to make a formal complaint or have concerns regarding the ways in which we use your information, you can contact the Information Commissioner’s Office (also known as the “ICO”). The ICO is an independent authority and the UK’s supervisory authority for information rights.

You can register your concerns on the ICO website (https://ico.org.uk/concerns/handling/)