Privacy Policy

1. Policy Overview

Who is responsible for your personal data

Our Privacy Policy applies to the personal data that we at Newmont Travel Limited collect use and otherwise process about you as a customer, potential customer or just an enquirer.

We are Newmont Travel Limited and we are a company registered in England and Wales with registration no 02084914 and our registered office is at. Treviot House, 186-192 High Road, Ilford, Essex, IG1 1JQ We control the ways your personal data is collected and the purposes for which your personal data is used by us and we are the “data controller” for the purposes of the data protection laws that apply to us, like the GDPR which is the European General Data Protection Regulation

 

2. Personal data we collect about you

When we refer to “personal data” in this Policy, we mean information that relates to you. Depending on the nature of your interactions with us, your personal data may include for example your name, your contact details, information relating to your travel itinerary (e.g. your booking reference number, your hotel room preference), your reasons for travelling (e.g. wedding, birthday or anniversary), meal and other travel preferences or dietary requirements and, if necessary, your health information (to the extent that it is relevant to your holiday itinerary or to provide you with special assistance), or information on how you use our website and app or you interact with us.

We collect some of your personal data directly from you, for example when you book a holiday and/or flight with us, use our website or contact us. We may also receive your personal data from our suppliers who provide services to you on our behalf (for example when you provide feedback on our services) and our partners when you purchase their travel-related products

Categories of data we collect

We will only collect your personal data when we need to. The basis we rely upon for lawfully collecting and using your personal data will depend on the purposes for which we need to use your personal data. We may collect and process the following categories of personal information on a lawful basis as listed below:

To perform our contract with you:

Personal data used	Why (reason or purpose)
Details about you Your name and surname and your contact details (email address, telephone number and postal address)	When you create an account on our website. When you book a flight or holiday When you purchase our partners' travel products available through our website
Information about other passengers in your booking, and the age range of any children travelling with you.	When you make a booking on behalf of other passengers
Financial information This may include billing addresses, credit/debit card details and bank account details.	If you book services on our website, or by phone with us.
Transactional data Information about your transaction, including your payment card details, date and time, the amount charged and other related transaction details.	When you purchase flights or other travel products
Identification documents/information Advance Passenger Information ("API"). This information includes your full name, your nationality, your date of birth, your gender - the number and type of your travel document (e.g. passport or ID), its expiry date and country of issue. Passenger Name Record (PNR) The name of the passenger Ticketing details, either a ticket number or a ticketing time limit. Itinerary Name of the person providing the information or making the booking.	When you check in for specific travel routes.   To manage your travel bookings and provide our services to you.     .

Our legitimate interests:

Personal data used	Why (reason or purpose)
Information related to your flights and hotels and our services in connection with these (e.g. airport transfer, auto-bag drop service, declaring lost luggage) Your interactions with us The communications you exchange with us (for example, your emails, letters or calls, Direct Marketing communications (via email, telephone and post).	To manage your travel bookings and provide our services to you. To improve our services, fulfil our administrative purposes and protect our business interests  To personalise and improve your customer experience.

 

To comply with our legal obligations:

Personal data used	Why (reason or purpose)
Advance Passenger Information (API) Passenger Name Record (PNR) The name of the passenger Ticketing details, either a ticket number or a ticketing time limit. Itinerary Name of the person providing the information or making the booking.	To fulfil our obligation to provide information to immigration/border control agencies when flying on specific flight routes.

Your consent:

Personal data used	Why (reason or purpose)
API and Payment card details	Storing API and payment card details to speed up future payments

If at any point we need to collect types of data that are not included in the above list, we will make sure that we provide you in advance with all necessary information relating to this specific collection and use of your data.

3. Special categories of personal data 
In the course of providing services to you, we may collect some information revealing your health information, racial or ethnic origin, physical or mental health or religious beliefs. These types of information are considered “special categories of personal data” under the GDPR and other data protection laws. We only collect this information where you have given your explicit consent, it is necessary to protect your vital interests or those of other people, like our other passengers or crew, or where you have deliberately made it public. We may also collect information concerning criminal convictions and offences when this is necessary to ensure the safety of our customers, for example, if there is an offence committed during a flight.

For example, we may collect the above information in the following circumstances:
 

For your safety, when you have a specific medical condition, you will need to inform us of that and –where required – provide us with a medical certificate.

Your health (for example if you ask us to arrange special assistance during your travel arrangements, or to determine your fitness to fly, or if you specify a meal preference that indicates a medical condition.)

Your religion (for example if you specify a meal preference that indicates a particular religion such as a kosher or halal meal).

If you request special assistance before or during a flight, this could reveal information about your health (for example if you ask for a wheelchair). Please note that in this case, we will need to provide this information to the staff of the airports to and from which you will be flying or those airports’ service providers, so that they can assist you during your trip.

When you provide us with information that could be considered a special category

By the provisions of the GDPR, we need to have a further legal basis for collecting, storing or using this type of personal data. We process special categories of personal data in the following circumstances:

In limited circumstances, with your explicit written consent;

To protect your vital interests or those of another person where you are physically or legally incapable of giving consent (e.g. in the event of a medical emergency).
 

Where it is needed concerning legal claims where it is needed to protect your interests (or someone else's interests) and you are not capable of giving your consent, or where you have already made the information public.
 

4. How and why we use your personal data

The data protection laws allow us to use your personal data only if we have a lawful basis to do so. Most of the time, we will use your personal data to perform our contract with you, i.e. to provide you with options relating to the travel destination, and to fulfil our legitimate interests or those of other parties, when these interests are not overridden by your rights (for example, to manage our relationship with you as our customer).

In some instances, we may rely on your consent to use some of your personal data, for example when you choose to save your API details on your account for future use or, where necessary, we will seek your explicit consent, for example when you provide us with information that may relate to your health. 

In other cases, we are obliged by law to collect and use some of your data, for example, to transfer your API details to border control authorities. 

We use your personal data for the following purposes:

 - To manage your travel bookings and provide our services to you

When you make a booking, we will create an account through which you can complete and manage your booking. Where you provide the details of other individuals you should ensure you have their permission to do so. Please advise the individuals to read this policy to find out more about how we may use their personal information.

If you no longer wish to use your account, you can deactivate it, but if you decide to make a booking again, you will need to create a new account with us. 

When you book your travel arrangements with us, we use your information to perform our services concerning your booking, for example, to issue your flight tickets and provide you with any special assistance (where you provide your consent). We also use it to change your bookings if you request such changes. 

 - To communicate with you and manage our relationship with you

Operational communications 
Occasionally we may need to contact you by email and/or SMS for administrative or operational reasons, for example to send you confirmation of your bookings and your payments, to inform you about your travel itinerary or to advise you of disruption and changes to your hotel reservation or flights. We may also use your contact details to get in touch concerning an emergency or a safety event. 

Please be aware that these communications are not made for marketing purposes and as such, you will continue to receive them even if you choose to not receive marketing communications.

Enquiries
When you send us a request or fill in a web form on our website, we will use your personal data to reply to you and fulfil your requests, administer your claims and resolve any complaints you may have. 

If you still have queries and you prefer to speak to one of our agents, you can always contact our Customer Service team. When you contact us by phone, please note that your calls may be recorded for training and quality control purposes, including for monitoring the services we provide to you. 

Feedback
Your opinion is very important to us, so we may send you an email or SMS to seek your feedback.

We will use the communications you exchange with us and the feedback you may provide to manage our relationship with you as our customer and to improve our services and experiences for customers (e.g. Determining the effectiveness of our site/tools/services and improving the security and optimisation of our site and services).
 

 - To personalise and improve your customer experience

We may use your personal data to tailor our services to your needs and preferences and to provide you with a personalised customer experience. For example, your travel/flight history helps us understand what you like and ensure that you have access to the offers and the products that you find interesting. We may also use your personal data to confirm your reservations with respective service providers. Also, if you inform us about your preferred departure airports we will be able to send you offers for flights that are relevant to your location. 

We may also collect information on how you use our website, which destinations you search for and what products you buy, to understand what you like. We may use this information to tailor the content and offers that you see on our website or the content of our Newmont Travel online advertisements and, if you have agreed to receive direct marketing communications, to send you relevant messages and inform you of offers that we think you like.  

If you are in the process of making a booking under your account and you leave our website before your order has been placed, we may contact you to help you easily complete your booking. 

 - To inform you about our news and offers that you may like

Marketing 
We may send you marketing communications about our flights, holidays, travel products, latest offers, partnerships, sales, and promotions to keep you updated on the travel sector if you have indicated that you are happy to receive these, for example when you create an account on our website or make a booking with us and you do not express a wish to not receive such communications.

If you are happy to receive marketing communications, we will provide you with news from us such as new destinations that you may be interested in or offers that you may like. 

Third parties and marketing

We might rely on third parties to help us with our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so. 

Our partners’ products

In addition, we will send you communications promoting our partner’s products and services that may relate to your travel arrangements, if you have indicated that you are happy to receive these. 
Please note that we will never share your contact details and other personal data with these partners or other companies for marketing purposes.

We also work with carefully selected suppliers that carry out certain functions on our behalf. For example, companies that help us with IT services, storing and combining data, marketing, advertising campaigns, market research, processing payments and delivering products and services in connection with these purposes and on the lawful grounds described above

Our partners have their own privacy policies and terms of use over which Newmont Travel does not have control. Whilst Newmont Travel carefully selects these partners, it has no responsibility or liability for their privacy policies, terms of use or the way they process your personal data. Please make sure you review the relevant privacy policies and terms of use of these partners before purchasing their goods or services, using their website, apps or services or providing any personal data to them.   

How we get in touch

To provide you with marketing material about our or our partners’ products, we will mainly contact you via email.

We value your privacy and we will always respect your choice to not receive marketing communications. If you do not want to hear from us about our or our partners’ products and services, you can simply tell us so by choosing the relevant option before confirming your booking. You can also choose to opt-out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of the marketing-related communications you may receive from us.

 
If you prefer, you can also call our Customer Service team and express your preference to not receive marketing communications.

 - To improve our services, fulfil our administrative purposes and protect our business interests

We will also use your information to fulfil our legitimate business interests. These interests include improving our services and offering you a better customer experience, using information for accounting, billing and audit purposes, credit or other payment card verification, fraud screening, safety, security and legal purposes, statistical and marketing analysis, systems testing and maintenance.

We will use personal information for the above business purposes only where we consider it necessary and we will try where possible to use information that does not allow the identification of our customers, for example, we will mainly use aggregate data for analysis purposes. 

When we need to use information that can potentially allow the identification of our customers, we will use as little information as possible and we will do that in a way to respect our customers’ rights and freedoms. 

 - To comply with our legal obligations, for example, our obligation to provide information to immigration/border control agencies on specific flight routes. The majority of destinations require airlines, cruise lines and tour operators to provide “Advance Passenger Information” about you to the border/immigration authorities of the country of your travel destination. Advance Passenger Information comprises the basic information contained in your passport that you would be required to present on your arrival. In addition, laws in certain destinations in your itinerary such as the USA and countries your flight may fly over require airlines to provide certain additional advance information about you and your travel arrangements. We will provide this information where we are required to do so.
 

5. Your data protection rights

The GDPR and other data protection laws give you specific rights that help you be in control of your personal data and we want to make it easy for you to exercise these rights. Below you will find more information about your rights and how we work to fulfil these. You can exercise any of your rights concerning the data that Newmont Travel holds about you, by contacting us at the address available at the end of this section.

Data access 

You are entitled to know whether we hold your personal data and if so, receive a copy of your data. You can contact us at the address below to request a copy of your personal data. 

In order for us to be able to process your request, you will need to provide us with the required information below:

• Your full name.
• A description of the data you would like to access including a date range (e.g. your booking history for the past 12 months). An accurate description of your request will save you time and effort and will allow us to focus our searches on what you need and quickly reply to you.
• All email addresses you have used to book Newmont Travel products and services or communicate with us, even if you no longer use these. 
• Other information that may help us locate your data (e.g. your booking reference). 

• For the protection of your information, we will also need to verify your identity, so make sure you provide a copy of your current and valid photo ID (e.g. passport page).
   

If you submit a request on behalf of another person, we will need to ensure that this person has authorised you to make this request and receive their data. 

Please note that our Data Protection team does not deal with requests for invoices. To quickly and easily receive invoices for your bookings, please use the usual contact you deal with here at Newmont Travel.

Data rectification 

If you believe that we hold incorrect or incomplete information about you, please let us know and we will correct it.

Please note that any requests for changes in your active bookings, for example, changes of passenger names or travel document details, will be processed by Customer Services, so contacting our Customer Service team directly will save you time.   

Data deletion

We will retain your information for the period required to fulfil the purposes set out in this Policy and when there is a legal obligation to do so.  

Please see the section on “How long we keep your personal data” below for more information.

Data restriction

In certain circumstances, you may ask that we continue to store your data but not use it. For example, if you consider that we hold information relating to you that you may need for legal purposes, you can request from us to not delete this information. 

Objection 
You have the right to object to the use of your data for direct marketing purposes at any time. Please see section 4 above for more details on how you can unsubscribe from marketing. 

Also, you may consider that you have reasons to object to the use of your data when such use is based on our legitimate interests as explained in this Policy. Before using your data for our business interests we have balanced these interests against your rights and freedoms; however, if you consider that you have grounds to object to the use of your data, you can explain to us your particular situation and we will individually review your request. 

Withdrawing consent 

As explained in section 4 above, we may use your personal data for various purposes and in most cases this is not your consent. When we rely on your consent to process your personal data (for example when you save details in your account for future use), you have the right to withdraw your consent at any time. We will respect your choice and stop further processing your data; however, any use of your data before you withdraw consent will not be affected. 

How long do we keep your personal data?

We store all personal data safely and only hold for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us. In some cases, we may keep your personal data for longer periods to enable us to comply with any legal obligations that require us to keep information, or for as long as reasonably required for purposes of our legitimate interests, including maintenance of accurate records of your dealings with us to help manage complaints or claims you or others may raise, or otherwise exercise our legal rights and defend ourselves against claims. Newmont Travel operates a data retention policy and constantly explores ways to reduce the amount of information we hold and the length of time that it’s kept.
  
Data related concerns 

We always aim to be clear and transparent with our customers but we understand that sometimes this can be complicated. If you have a concern concerning how we use your personal data and satisfy your rights, please let us know; we will reply to your queries and if necessary, take steps to ensure our practices are consistent with our promise and our obligations. If you are still not satisfied with the way we use your personal data and you believe this is not in accordance with data protection laws, you have the right to complain to a data protection authority. In the UK, the relevant supervisory authority is the Information Commissioner’s Office (ICO). You can contact the ICO via their web form at https://ico.org.uk/concerns/ or call the ICO helpline at +44 (0)303 123 1113.

 

6. Protecting your personal data

We are committed to protecting the personal data we hold by taking appropriate technical and organisational measures against unauthorised, unlawful or accidental access, loss, destruction or damage of such personal data. We are constantly taking steps to improve in the field of Information Security as the sector itself is constantly changing as well. 

How you can protect your data

You can follow some simple steps to keep your information secure. When you create your Newmont Travel account, choose a strong password that is unique to this account and do not share your password with other people. If you use the same password across your different accounts, you increase the risk of your data being compromised if your password is accidentally or unlawfully accessed by another person. If you suspect that someone else has access to your password, make sure that you change it immediately. 

If you receive an email that looks suspicious, e.g. it refers to a booking that you are not aware of, or you have doubts as to whether an email was sent by Newmont Travel, please report it to us. Please note that we will never ask for your payment card details via email.  

When we promote our offers, we do so by using the same email account through which we send you all our marketing communications and we will not ask for your personal information in these emails. If you have doubts about whether a post, notification or communication you receive is authentic, you can easily verify whether the same information appears on our official website. If this is not the case, please let us know so that we can investigate and take necessary action.  
 

How we protect your data

When you provide your personal data through our website, this information is transmitted across the internet securely using industry-standard encryption. We use a variety of different technical and operational security measures to protect your information against unauthorised access or unlawful use. For example we:

Ensure the physical security of our offices, shops and other sites;

Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions;

Newmont Travel is a PCI DSS-compliant organisation. This means that we adhere to high-security standards to protect your payment card details when you are sending us this information.

Ensure appropriate access controls so that access to your information is only granted to those of our people who need to use it in the course of their work;

Carry out regular penetration testing of our systems and third-party reviews of our software; and

Maintain internal policies and deliver data protection and confidentiality training to make sure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities. 
 

7. Where is your information?

The information that you provide to us will be held in our systems which are located on our premises and in the cloud (with carefully selected service providers) or those of our appointed suppliers. 

As described in this Privacy Policy, we may in some instances disclose or allow access to your information by third parties who act for us for the purposes described in this policy or for other purposes approved by you. Where these third parties process your personal data on our behalf, we require that they have appropriate technical and organisational measures in place to protect this data. 

In some instances, your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, also referred to as the “EEA”) - including by staff operating outside the EEA who work for us or for our suppliers or agents (this includes staff engaged in, among other things, the fulfilment of your booking, for example our airport transfer operators who assist you at the airport, and the provision of support services). Where your personal data are transferred outside of the EEA, we require that one of the following appropriate safeguards is in place, under data protection laws: 

• there is a decision by the European Commission that the country to which our customers’ data is transferred provides an adequate level of data protection
• in the absence of such a decision, the contracts that we have in place with these suppliers include EU-approved model clauses concerning the protection of our customers’ data
• when our suppliers access customer information from the US, we aim to ensure that they participate in the EU-US Privacy Shield framework, a self-certification mechanism that provides safeguards concerning data transfers to US companies
  
  Also, in some instances, we may be compelled by law to disclose our customer’s personal data to a third party, such as airports and border control agencies, and we have limited control over how data is protected by that party.

 

8. Why we use cookies

To improve our services, to provide you with more relevant content and to analyse how visitors use our website and app, we may use technologies, such as cookies, pixels or tracking software. Please be aware that in most cases we will not be able to identify you from the information we collect using these technologies. 

Most sites collect certain information automatically in log files about how you interact with them. This might include your IP address, geographical location, device information (such as your hardware model, mobile network information, and unique device identifiers) browser type, referral source, length of visit to the site or app, number of page views, the search queries you make, and similar information.

For example, we use software to monitor customer traffic patterns and website usage to help us develop the design and layout of the website to enhance the experience of the visitors to our website. This software doesn’t let us collect any personal data. In addition, to understand how our customers interact with the emails and the content that we send, we use pixels that allow us to know if the emails we send are opened or if the content of our emails is displayed in text or HTML form.

We also use cookies on our website and our emails. Cookies are small pieces of information stored by your browser on your computer's hard drive. They enable you to navigate on our website or app and allow us to provide features such as remembering aspects of your last holiday/flight search to make subsequent searches faster. You can delete cookies if you wish; while certain cookies are necessary for viewing and navigating on our website or app, most of the features will be still accessible without cookies.

This information will be collected by us or by a third-party site analytics service provider and will be collected using cookies.

 

9. Sharing personal data

Your personal data may be shared with other companies such as a third party who acquires us, or substantially all of our assets. We may also share your information with third-party suppliers that provide us with services in connection with the provision of our services to you.

We may also share some of your personal data with, or obtain your personal data from, the following categories of third parties:

• Airports, government authorities, law enforcement bodies and regulators when this is necessary to get you to your destination or is required by law.
  For example, for specific travel routes, we are required by law to provide border control agencies with information that relates to your travel documents and your travel itinerary. This information is known as API (Advance Passenger Information).
• We may also share your personal data with third parties in the event of a medical emergency to obtain advice and to manage and record passenger medical issues e.g. in the course of a flight. Your personal data may also be recorded in the flight report which is sent to the flight operator.
• Suppliers providing services to us to help us run our business and improve our services and your customer experience. We may for example share your personal data with the companies who provide services at airports. We may also disclose your information to our contact centre, the companies who help us get your feedback on our services or the company that provides IT support to us.
• At Newmont Travel, we select very carefully our suppliers who process your personal data on our behalf and require that they comply with high-security standards for the protection of your personal data.
• Credit and debit card companies
• We share some of your personal data, which includes information about your method of payment, flight booking and in some cases passenger names, to the credit or debit card company that issued the card you used to make your booking. To ensure the security of your transactions and prevent or detect fraudulent transactions, we will usually also share your information with our fraud screening partner.
• Authorities, including the Civil Aviation Authority. In some circumstances, we may also be required to disclose part of your personal data to the UK Civil Aviation Authority (“CAA”) or other national CAAs, to ensure compliance with and the enforcement of ATOL regulations or for other regulatory purposes.
• In addition to the categories of parties listed above, we may disclose your personal data when this is required by the law of any jurisdiction to which Newmont Travel may be subject.
• Where it is necessary to transfer personal data to a third party, we operate stringent reviews of those with whom we share data and we will only transfer the data in line with the purpose for which it was collected

 

10. Updates to our Privacy Policy

Our Privacy Policy is a dynamic tool and we will modify it when there is a change to the way we process your data. We may update this Privacy Policy from time to time, to ensure that the information we provide to you is up to date and following the relevant data protection laws. Any new version of this Policy will be published on our website.
 

11. Contact information

Questions, comments and feedback regarding this Privacy Policy, are welcomed and should be addressed to our Data Protection Officer in writing at the following address:

Data Protection Officer
Newmont Travel Ltd.

Building 4
North London Business Park
Oakleigh Road South
London

N11 1GN