HAYS TRAVEL PRIVACY POLICY (AUGUST 2022)

Introduction

1- Hays Travel is committed to respecting your privacy and protecting your personal information. This privacy notice sets out:

– When we collect personal information about you;
– What types of personal information we collect;
– Our legal basis for using your personal information;
– How we keep it safe;
– Who we share personal information with;
– Marketing communications;
– Data retention;
– Your rights and choices about the personal information that we hold;
– Contact us and
– Making a complaint

2- This privacy notice has been updated to reflect GDPR (the General Data Protection Regulation) which came into effect on the 25th of May 2018.

When we collect personal information about you

3- We collect personal information about you whenever you make a booking or otherwise interact with in person or via telephone, our websites, email or other contact methods (whether directly with us or through agents acting on our behalf).

The types of personal data we collect and why we collect it

4- Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

(A) Identity Data

This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender and passport details.

(B) Contact Data

This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers, emergency contact details and next of kin contact details.

(C) Financial Data

This includes data relating to your means and methods of payment, such as your bank account details to set up direct debits.

(D) Transaction Data

This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

(E) Technical Data

This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

(F) Profile Data

This includes the data that we receive when you create a profile on our website and make use of that profile, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(G) Usage Data

This includes information about how you use our website, products and services.

(H) Marketing and Communications Data

This includes your preferences in relation to whether or not you want to receive marketing information from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Special Categories of Personal Data

We collect the following special categories of personal data about you. Details about your:

– dietary requirements which may disclose your religious or philosophical beliefs;
– health;
– nationality which may disclose your race or ethnicity

We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.

If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellation charges referred to in clause [18.2] of our Terms and Conditions will become payable.

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

– make a booking of travel services;
– create an account on our website;
– subscribe to our newsletter or other publications;
– request marketing to be sent to you;
– enter a competition, promotion or survey;
– leave us a review or give us some feedback;
– submit a web enquiry

Purpose/Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as a new customer.	(a) Identity; (b) Contact.	Performance of a contract with you.
To process and deliver your booking including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us.	(a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you which will include: (a) Notifying you about changes to our terms or Privacy Policy; (b) Asking you to leave a review or take a survey.	(a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition or complete a survey.	(a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications.	(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business re-organisation or group restructuring exercise) (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical.	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences	(a) Technical; (b) Usage.	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you.	(a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile; (f) Marketing and Communications.	Necessary for our legitimate interests (to develop our products/services and grow our business)
To monitor our communications with you in order to check any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to defend legal claims.	(a) Identity; (b) Contact; (c) Technical.	(a) Necessary for our legitimate interests (to assist us in training our employees and defend our business in the event of a claim); (b) Necessary to comply with a legal obligation;
To sign you up as a member and to receive our emails.	(a) Identity; (b) Contact; (c) Marketing and Communications.	(a) To send you e-mails; (b) To let you know about our latest offers, news and promotions; (c) To notify you of interesting news, money saving deals and cruise holidays you which you may be interested in; (d) Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To follow up your web enquiry.	(a) Identity; (b) Contact; (c) Marketing and Communications.	(a) To send you news, exclusive offers and products; (b) Necessary for our legitimate interests (to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

 

Our legal basis for using your personal information

5- We will only process your personal information where we have a legal basis to do so. Depending on the circumstances, the legal basis will almost always be one or more of the following:

– so that we can make and fulfil your booking or otherwise perform our contract with you;
– because it is in our legitimate interests to use your personal information to operate and improve our business as a travel agency;
– to comply with a legal obligation;
– to protect the vital interests of you or another person; or
– because you have consented to our using your information for a particular purpose.

How do we keep your personal information safe?

6- Protecting the confidentiality and integrity of your personal data is a responsibility that we take seriously at all times. We use appropriate technical and organisational measures to help to keep personal data secure against unauthorised or unlawful processing, and against accidental loss, destruction, or damage.

Who do we share your personal information with?

7- With suppliers – in order to provide products or services requested by you we share personal data with suppliers of your travel arrangements, including airlines, hotels and insurance providers. In many cases such suppliers will themselves separately be controllers of your personal data.

8- Within the Hays Travel Group – we share personal information with the other companies in our group (Hays Tour Operating Limited, Hays Beds Limited, Hays Transfers Limited, Hays Foreign Exchange Limited, Hays Transport Limited) where necessary for them to be involved in providing the services you have requested. This privacy notice applies to their processing of personal information as well as to Hays Travel’s.

9- Payment processing companies to process your payment.

10- With regulatory authorities – it may be necessary to disclose personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes required by regulatory authorities.

11- It is often necessary for us to send your personal information outside the European Economic Area to fulfil your travel arrangements. This is because the suppliers providing your travel services are located around the world. Also, your personal information may need to be transferred to border control and immigration outside of the EEA. This may involve sending your data to countries where under their local laws you may have fewer legal rights.

12. With third party service providers which help us understand our customer behaviour or help improve our website, our products and services.

Marketing communications

13- When you book or register with us, we will ask if you would like to receive marketing communications. If you have previously agreed to receive marketing communications, we may send you relevant offers and news about our products.

14- You can change your marketing preferences by contacting us in any way or by using the ‘unsubscribe’ link in our marketing emails or by replying STOP to our marketing text messages, or UNSUBSCRIBE / STOP to our WhatsApp marketing messages.

15- We will respect your choice as to what communications you wish to receive and the methods by which you are sent them.

Data retention

16- We will keep your personal data for only as long as it is necessary for the purposes set out in this privacy notice. For example, after travel we will keep the information related to your booking so that we can respond to any complaints and fulfil our record keeping obligations. After this time, we will securely erase or anonymise personal data.

Your rights and choices about the personal information that we hold

17- You can ask us for a copy of the information that we hold about you.

18- You can also ask us to correct any information which you don’t think is correct or to delete the information we hold about you.

19- To comply with these requests we may need you to confirm your identity by providing documents or additional information.

Contact us     

20- If you have any concerns about our use of your personal information, you can make a complaint to us at:

Data Protection Manager
Hays Travel Limited
Gilbridge House
Keel Square
High Street West
Sunderland
SR1 3HA

You can also email dpmanager@hays-travel.co.uk or call us on 0333 033 9985.
(Standard call charges apply. If you are unsure, please check with your network provider).

Making a complaint

21- You can also complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address is:

Information Commissioners Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline number: 0303 123 1113
ICO website: https://www.ico.org.uk