We will only use and retain your personal data with your consent or other lawful basis. We ask for your consent on those occasions and in those places where we specify what we will use your personal data for.
This document, and all content of our websites is Copyright © 2018 Grosvenor Tours. ALL RIGHTS RESERVED.
We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data.
(1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organizations booking with or through us);
(2) individuals in respect of whom any enquiry or booking is made with us by an agent;
(3) where our customer is a business or organization, employees or individuals who are acting as representatives of that business or other organization, and individuals connected to that business or other organization, such as owners, partners, shareholders, and directors;
(4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).
When we refer to “processing” of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.
When we refer to “travel services” this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both
(1) all such products and services which we supply or operate ourselves (including where we sub-contract); and
(2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.
This section summarizes the types of personal data about you that we process: –
We may collect the following:
If you are an individual associated with a business or other organization that is our customer, then your personal data may include the following information that we link to you:
Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.
Information collected or generated out of any surveys we conduct.
Information collected or generated out of any competitions or promotions we run.
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.
We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
This information may include:
This information may also include:
Session cookies last only for the duration of your visit and are deleted when you close your browser. These facilitate various tasks such as allowing a website to identify that a user of a particular device is navigating from page to page, supporting website security or basic functionality.
Persistent cookies last after you have closed your browser, and allow a website to remember your actions and preferences. Sometimes persistent cookies are used by websites to provide targeted advertising based upon the browsing history of the device.
We use persistent cookies to allow us to analyse customer visits to our site. These cookies help us to understand how customers arrive at and use our site so we can improve the overall service.
These cookies are essential in order to enable you to move around the website and use its features, and ensuring the security of your experience. Without these cookies services you have asked for, such as applying for products and managing your accounts, cannot be provided. These cookies don’t gather information about you for the purposes of marketing.
These cookies collect information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is only used to improve how a website works, the user experience and to optimise our advertising. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
These cookies allow the website to remember choices you make (such as your username). The information these cookies collect is anonymized (i.e. it does not contain your name, address etc.) and they do not track your browsing activity across other websites. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
These cookies collect several pieces of information about your browsing habits. [They are usually placed by third party advertising networks]. They remember that you have visited a website and this information is shared with other organisations such as media publishers. These organisations do this in order to provide you with targeted adverts more relevant to you and your interests.
This section sets out the ways in which we may collect or generate personal data concerning you.
By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.
Your personal data will include data you provide (or later amend), whether:
This includes when you:
We may obtain personal data concerning you from third parties, including from:
We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:
We may record telephone calls with you.
This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.
To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. This is done on the basis of our legitimate interests in ensuring our business is run efficiently.
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. This is done on the basis of our legitimate interests in ensuring our business is run efficiently.
To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us.
To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. This is done on the basis of our legitimate interests in ensuring our business is run efficiently.
To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business to run efficiently.
To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;
For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings. This is done on the basis of our legitimate interests in ensuring our business to run efficiently.
To carry out direct marketing to you, see section 12.1 for further information.
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis.
You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
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.
We do not use or disclose your personal data for direct marketing purposes unless:
In addition to data protection law if we use your personal information for direct marketing purposes we may also be subject to additional rules that regulate direct marketing. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.
We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:
Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email).
From time to time we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:
12.3 Withdrawing from Direct Marketing
You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”
When you elect to stop receiving marketing information we will, from that point onwards, not share you information further with any other third parties.
You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.
We transfer your personal data to third parties in the following circumstances: –
We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;
Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you.
We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.
We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal data to them as required for use for or processing as part of those purposes.
We may supply personal data to a government authority or regulator where required to:
We may disclose your personal data where otherwise required by or permitted by law.
We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.
If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorized representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.
If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.
Where we provide your personal data to a third party one of the following two circumstances will apply: –
We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”).
We will only send your personal data outside the EEA to companies either within our group or to parties with whom we have a contract. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA. You can find out about what adequate safeguards these are by contacting us using the details provided in section 2 of this privacy notice.
We take appropriate technical and organizational measures to secure your information and to protect it against unauthorized or unlawful use and accidental loss or destruction, including:
Transmission of information over email is not secure, and if you submit any information to us over the internet by email you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by email.
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal data to. We never contact you to ask you for sensitive personal data, such as payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold.
The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.
You have the right to have your personal data amended if it is inaccurate or incomplete.
You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.
You have the right to have your personal information deleted or removed in certain circumstances and we may have the right in some cases to refuse to do so.
You have the right to obtain and re-use your personal information for your own use in certain circumstances.
You may prevent or suppress the processing of your personal information in certain circumstances.
The laws we comply with are regulated by the Information Commissioner (https://www.justice.gov.za/inforeg/) in South Africa. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have. You can contact us using the details provided in section 2 of this our privacy notice.
You are free to withdraw your consent at any time. Please contact using the details outlined in Section 5 of this policy. See also section 12.3 for details as to how to unsubscribe from our mailing lists.
This policy is subject to the law of The Republic of South Africa and you must bring any claims against us exclusively in the courts of South Africa.
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