- Our role as a data controller
In respect of the data protection laws Kipling Tours Ltd is a data controller for the personal data you provide to us (collectively referred to as “we”, “us” or “our” in this privacy notice).
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 18 August 2018 and historic versions can be obtained by contacting us (details set out above).
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
- Collecting of personal data on our website
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.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Dataincludes first name, maiden name, last name, marital status, title, date of birth and gender.
- Contact Dataincludes postal address, email address and telephone numbers.
- Financial Dataincludes bank account and payment card details.
- Transaction Dataincludes details about payments to and from you and other details of purchases you have made from us.
- Technical Dataincludes internet protocol (IP) address, 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 our website.
- Usage Dataincludes information about how you use our website.
- Marketing and Communications Data includes your preferences in receiving marketing from us and, where applicable, our third parties and your communication preferences.
You may refuse to provide us with some or all of this personal information, but where we need to collect personal data by law, or under the terms of a contract we have with you, refusing to provide the data may delay or prevent us from corresponding with you, responding to your enquiry or prevent us from performing the contract with you.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
- How is your personal data collected and used?
We collect personal data about you when you make a telephone enquiry or register on our website for our regular electronic newsletters, when you complete and submit a form requesting more information about our tours, or for a quote or any other service or feature which we may, from time to time, place on our website. We may collect identity data such as your name and contact data including your address, email, phone number and other personal information that you voluntarily provide us with.
We process this information so that we are able to perform a contract with you and because it is necessary for our legitimate interests in developing and growing our business.
During the process of making a booking we collect appropriate personal data from you. This includes your personal details and those of all other tour participants including name, date of birth, passport number, passport issue and expiry date, nationality, dietary restrictions and any medical information which may impact on your ability to take part in the tour.
We process this information as an essential part of performing a contract with you.
This information will be passed to third parties such as airlines, coach companies, rail operators and hotels (and where necessary, third parties such as credit card payment processing companies) who require this information so that your tour can be organised in accordance with your request. Your personal data may also be provided to third parties such as government or official authorities such as immigration or visa issuers if required by them or if required by law. If we are unable to pass your data to these third parties, we will be unable to process your booking and you will not be able to travel with us. We only pass to third parties the precise information that they need to provide their services or functions, and no more.
Collecting personal data via automated technologies on our website
We may use your Identity, Contact and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or booked tours from us or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at firstname.lastname@example.org or by post to Salcombe House, Long Street, Sherborne DT9 3BU at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a tour you have booked or other purchase you have made with us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to enquire as to the use of your personal data at any time, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- International transfers
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission, for more details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.
- Where we use certain service providers, we may use specific contracts which give personal data the same protection it has in Europe.
How we protect your data
How long do we keep your data?
We retain your data only for as long as is necessary for the purposes set out in this policy and to comply with our legal obligations.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our on request from us.
Your legal rights
Under Data Protection Legislation, you have the following rights:
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.