Effective date: September 24, 2018
Information that may be collected by Sports Tours Overseas Ltd about you:
We may collect, use, store and transfer different kinds of personal information about you which we have summarised below:-
- Details about you and your touring party: Your first and last name, marital status, title, gender, e-mail address, telephone number, date of birth, loyalty membership details, your reasons for travel, meal and other travel preferences or dietary requirements, accessibility and mobility needs, religious preferences , medical requirements and any other personal data for the purposes of travel.
- Payment details: Details about payments to and from you and other details of products and services you have purchased from us.
- Identification documents: Passport or identity card details including your passport number, the country in which your passport was issued and the expiry date for the purposes of supply to our sub-contractors to enable you to travel to your booked destination.
- Details about your booking with us including where you are flying from and to, your booking information (including anyone else on the booking), any onward travel details if relevant, details of excursions booked through us, baggage requirements, upgrade information, 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.
- Additional information communicated by you to us and or our staff in relation to your tour specifics, 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 sites, social media pages, IP addresses and information you may post on social media.
- Special types of data: In some circumstances we may need to collect information from you that is deemed sensitive. For example, we might collect:
- Where personal data is needed by law or under the terms of the booking contract we have with you and you fail to provide that data when requested, we may have to cancel your booking with us as per the terms of our booking conditions.
Our collection of sensitive personal information is limited only for the purposes of making your travel experience as enjoyable as possible and unless we have a specific lawful reason to use this information, we will ask for your consent to collect it.
HOW DO WE COLLECT YOUR INFORMATION AND WHY?
We may collect and store information on you in the following way:
2.1) Direct contact
You may provide us your contact information and financial data by filling in forms or by corresponding with us by face to face meet, post, phone, interactive app, email, website form, and brochure request or otherwise. This includes (but is not limited to) personal data you provided when you enquire about one of our tours.
2.2) Indirect contact – Automated techniques
2.3) Third parties or publicly available sources
We may also receive personal data about you from various third parties , including airlines, hotel providers coach operators and any other contractor as necessary to fulfil the terms of your contract with us effectively.
WHAT DO WE USE YOUR INFORMATION FOR?
3.1) Your information will only be used in the following way:
i) To fulfil a contract we have with you
ii) When it is our legal duty
iii) When we have a legitimate interest (or those of a 3rd party) and your interests & fundamental rights do not override those interested.
iv) When you consent to it.
HOW DO WE USE YOUR PERSONAL DATA?
4.1) To manage your booking with us. We will use your information to provide you the service you have requested on your booking form. This includes (but is not limited to) your flights, accommodation, transportation, excursions and any other package element on the basis of performing our contract with you.
4.2) To inform you about your booking and relevant follow up information.
4.3) We may collect information about you when you submit forms on our websites or electronic apps but do not complete your booking. We do so in order to offer assistance in case you are experiencing difficulties making a booking.
4.4) To take part in promotions and customer reward incentives and to communicate marketing information. We may use your information to contact you in order to keep you up to date with the latest news, offers, events, sales, brochures, promotions and competitions that we consider may be of interest or relevant to you. We will only usually contact you if you have given us specific consent to do so.
4.5) To provide you with a personalised service. This might include personalising the communications we send to you with preferences, sending you only information that we think will benefit you based on previous information requested.
4.6) 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);
4.7) To improve our Websites. We use data analytics to improve our website and continue to offer the best possible service to our customers.
4.8) For market research purposes. We may use your information to carry out market research if you choose to participate in any of our customer feedback surveys.
4.9) To comply with any legal obligations not set out within the terms of our Privacy and Data Protection policy
4.10) We may also record and/or monitor calls in order to improve our customer service.
We may, from time to time, communicate with you providing that;
5.1) You have signed up to receive marketing communications from us and have not since informed us you no longer wish to receive information from us
5.2) You have made a booking with us and have not told us that you do not want to hear from us.
How to opt out of receiving communications from us
Should you no longer wish to receive relevant information from us, you can unsubscribe from marketing by clicking on the 'unsubscribe' link included in all of our e-mails or by contacting us directly.
Third parties and marketing
We never share your data or information with any third party unless we use 3rd party providers to send our communication to you on our behalf. Our 3rd party mailer, Vertical Response do not have the right to send marketing to you for their own purposes.
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:
6.1) Third party suppliers we work with to provide your booking and tour components to you. We may share your information with parties such as travel agents, booking agents, airlines, hotels, tour operators, transport companies, excursion providers, airport authorities, insurance companies, car hire companies, ground handling agencies, and cruise companies.
6.2) Other suppliers that we work with in connection with our business. This might include (but not limited to) Sales and marketing agencies, Sales agents, Information Technology contractors, database administrators, service providers and hosting providers, third parties that manage promotions or competitions, third party software companies ground agents, site analytics providers, medical service providers, credit card processing companies, credit referencing and fraud prevention agencies, accountancy contractors and legal representatives.
6.3) Airports, immigration / border control and/or other government authorities. Sometimes we have to provide 'Advance Passenger Information' about you to border or immigration authorities of the country of your travel destination. This would usually be the basic information contained in your passport but the laws of certain countries may require additional information. We will provide this information when we are required to do so.
6.4) We may also provide data when requested for legal purposes by the police, courts of law, solicitors or any other legal or regulatory body necessary to conduct duties according to the relevant legislations, jurisdictions and where required by law.
HOW WE HANDLE YOUR DATA OUTSIDE THE EEA
7.1) We will only send your data outside the European Economic Area ("EEA") to either follow your instructions, comply with a legal duty, or for the purposes of arranging your tour or trip in line with your requirements.
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 this is necessary we will ensure that your data is given a similar degree of protection.
PERSONAL DATA RIGHTS
You have the right to:
8.2) Obtain a copy of any personal data we hold about you
8.3) Ask for us not to use your information for Sales and Marketing purposes
8.4) Delete information we hold about you in certain circumstances.
8.5) Withdraw any previous consents given to use or store personal data about you.
These rights may be exercised either in writing to our office or by opt out forms, check boxes or unsubscribe lists detailed in any communication received by you from us. We may require confirmation of your identity to carry out these requests from time to time.
9.1) Any data online data that we store online is protected with multi- level security. Off line electronic data is stored behind a secure encrypted firewall. There are also additional security measures in place to protect stored offline data to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Any data we store about you is access restricted only to employees, agents, contractors and other third parties who have a business need to know. Should we suspect a data breach, we will immediately notify you and inform the Information Officer and any regulatory body where we are legally obliged to do so.
9.2) We store your data for as long as necessary to fulfil the purpose we collected it for, including satisfying any legal, accounting and reporting requirements. By law we have to keep basic information about bookings and our customers for six years for legal claims and tax purposes.
DISPUTES WITH YOUR DATA FILE
Please notify us immediately if you feel there are discrepancies with any data we hold about you. 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 (www.ico.org.uk) or the relevant data protection authority where you live.