1. Who we are and our commitment to data protection.
We are Sunways Travel a Corporate Travel Management Company and a Leisure Travel Agent based at Station Road, Longfield, near Dartford, Kent DA3 7QD. Company number 1302911.
We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care. We are committed to protecting and respecting your privacy and take this very seriously.
By providing personal information to us, you agree that this Privacy Notice will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Privacy Notice. If you do not agree with any part of this Privacy Notice, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Privacy Notice, this may affect our ability to provide services to you or negatively impact the services we can provide to you.
2. What information do we collect?
Personal information generally means information which relates to a living individual who can be identified from that information.
The type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf.
We therefore typically process the following types of personal information about you:
3. How do we collect personal information?
We will only collect personal information in compliance with GDPR regulations. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impractical to do so.
Generally, this collection will occur:
We may collect personal information about you:
In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveler on the booking.
Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree you have obtained the consent of the other person for Sunways Travel to collect, use and disclose the other person's personal information in accordance with this Privacy Notice and that you have otherwise made the other person aware of this Privacy Notice.
You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person's personal information to us.
We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information relating to you. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you, or a person acting on your behalf, provide to us.
4. How do we use your personal information?
Where you contact us in relation to a travel booking or query, the purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services.
We will only process your information, where:
By disclosing your personal information to us in person, on our website(s), by email, by post or over the telephone, you consent to the collection, storage, processing and other use of your personal information by us in the manner set out in this Privacy Notice. Some information and emails sent to us may be used as testimonials or case studies but no email address or contact details will be displayed.
When you book or otherwise arrange travel related products and services through us, we usually act as an agent for the relevant travel service providers (e.g. for a hotel). In this case, we process your personal information as necessary to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Privacy Notice and for the travel service provider for whom we act as agent (e.g. to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.
We may send your details outside the European Economic Area (EEA), e.g. if your holiday is outside the EEA and the hotel needs to be advised of your details. Due to the global nature of the infrastructure of the internet please be aware that controls on data protection outside the EEA may not be as strict as in the UK.
5. How long do we hold your data?
We will keep personal information only for as long as is required to continue to fulfil the services requested by our Clients. If you do not wish us to continue holding your data, please contact us by email or in writing at the details set out in Section 11 below requesting your personal information to be deleted.
The personal information you provide us with will only be used in the administration of the products and services you have requested from us and your details will not be added to any marketing lists unless you have given us clear consent to do so.
Your information will be held for our internal use to allow us to improve the services and products we offer, your customer experience, and to enable us to comply with our contractual obligations. If you telephone us, calls may be recorded for training and quality purposes.
If a previous subscriber or customer of Sunways Travel that has received marketing material from us before 24 May 2018, you will continue to receive information from us under the basis of legitimate interest.
If you have given us permission to use your data for marketing communications or have been receiving marketing material from us since before 24 May 2018, you can unsubscribe at any time if you change your mind by clicking on the unsubscribe link within the marketing emails you receive, by using the contact information provided on postal marketing or by contacting us at the address provided in Section 11 below.
7. Your rights in relation to the personal information we collect.
If you wish to:
you can request this by contacting us by email or in writing at the details set out in section 11 below. You will receive acknowledgement of your request and we will advise you of the timeframe within which you will receive your information pack.
We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests. We reserve the right to deny you access for any reason permitted under applicable regulations. Such exemptions may include national security, corporate finance and confidential references. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by local data protection regulations, will note your request and the denial of same in our records.
Further correspondence regarding your request should only be made in writing to the Data Protection Officer at the address set out in section 11 below.
Please note that, if you request that we restrict or stop using personal information we hold on you or withdraw a consent you have previously given to the processing of such information, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveler's full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.
You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it is not correct.
In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification for us to comply with our security obligations and to prevent unauthorised disclosure of personal information.
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal information, and for any additional copies of the personal information you request from us.
8. How we protect your information.
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in Section 4 of this Privacy Notice and in accordance with UK data protection laws. Note that, in this Privacy Notice, where we say "disclose", this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care. We are committed to protecting and respecting your privacy and take this very seriously.
9. IP addresses and Cookies.
Cookies identify the computer you are using, not you personally. On this website we use session cookies to store your current session details. We may use a 30-day cookie to store a campaign or referrer that might have sent you to the site. We may also use a more persistent cookie if you logged in to the site to access your profile. We use an analytics tool to understand which website pages you are visiting and to help us improve the customer journey through the website and site effectiveness. This data allows us to improve the quality of your visit and develop programs, navigation and content that will be of interest to you.
We collect information about your computer (not your name, address, email address or telephone number) through your permanent cookie file for assessing the effectiveness of site content and traffic. This data allows us to improve the quality of your visit.
10. Links to third party sites.
Our websites may contain hyperlinks to websites operated by parties other than us. Such hyperlinks are provided for your reference only. We do not control websites which we do not operate and are not responsible for their contents or your use of them. Inclusion of these links to such websites does not imply any endorsement of the material on such websites or any association with their operators. You should seek information concerning any financial protection that may be available to you from any non-ABTA company, as ABTA financial protection would not apply to these companies.
11. Feedback / Complaints / Contact.
If you have any enquiries, comments or complaints about this Privacy Notice or our handling of your personal information, or wish to inform us of a change or correction to your personal information, would like a copy of the information we collect on you or would like to raise a complaint or comment, please contact your consultant or our Data Protection Officer using the details set out below:
Telephone: 01474 706979
Post: Sunways Travel
5-7 Station Road
Kent DA3 7QD
We will endeavor to respond to any enquiries or complaints received within a month or less, although we reserve the right to extend this period for complex requests If you think there is a problem with the way in which we are handling your personal information, then you have the right to complain to the ICO by visiting their website www.ico.org.uk/concerns.
12. Changes to our Privacy Notice.
We may amend this Privacy Notice from time to time. If we make a change to the Privacy Notice, the revised version will be posted on our website. We will post a prominent notice on our website to notify you of any significant changes to our Privacy Notice and indicate at the end of the Privacy Notice when it was most recently updated. It is your responsibility, and we encourage you, to check the website from time to time to determine whether there have been any changes. If we update our Privacy Notice, in certain circumstances, we may seek your consent.
This Privacy Notice was last updated on 9 April 2018.