The General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679) comes into force on 25 May 2018 and will impact how we, and all companies, collect, store and use your personal information. This policy covers how the Newmont Travel group of company’s collect, use, disclose, transfer and store your data. The Newmont Travel Group consists of the following trading names and their official website addresses: Newmont Travel – www.newmont.co.uk Hotels of the Caribbean – www.hotelsofthecaribbean.co.uk Holyland Travel – www.holylandtravel.co.uk
We understand and respect the importance of your privacy and we are committed to safeguarding your personal information – we take all reasonable steps to have appropriate security measures in place. In providing our service to you, we must collect personal information from you and this policy outlines how we treat your personal data after it has been collected by any of our channels which include our website, call centre, in-store and any future digital services or channels as they evolve. We are registered with the Information Commissioner’s Office as a Data Controller (registration number ZA344316) WHAT
PERSONAL INFORMATION WE COLLECT
When you contact us (by phone, email, fax, letter, in person or via our website) to inquire about our travel services, make a booking, to receive information from us or enter a competition, we will specifically ask you for the personal information necessary to fulfill your request. In many cases we will just need your name and contact details (telephone number, postal address and/or email address) but, if you plan to make a booking with us, we will usually need to collect some or all of the following information relating to you or other members of your travelling party: full names and addresses; dates of birth; passport details; travel insurance details; credit/debit card or other payment details; emergency contact details; special requirements such as those relating to any disability or medical condition which may affect your specific booking arrangements; dietary restrictions (which may disclose your religious beliefs). Some of this information (such as personal information relating to your racial or ethnic origin, religious beliefs or other beliefs of a similar nature, physical or mental health or condition) may be considered ‘sensitive personal data’ under the Data Protection Act 1998. Such data is subject to much stricter regulations than ordinary personal data and must only be processed when certain conditions have been satisfied. We collect this data only where necessary to cater to your needs or act in your interest. We will seek this consent when necessary. You are responsible for ensuring that other members of your party are aware of the content of this Policy and consent to you acting on their behalf in all your dealings with us. Please note that where information is also held by another travel agent acting on your behalf, this is subject to the agent's own data protection policy over which we have no control. Any queries which you may have in relation to such a policy should be directed solely to that travel agent.
HOW WILL WE COLLECT THIS INFORMATION?
We will only collect personal information from you by specifically asking for it: • When you purchase a product or service from or through us; • When you subscribe to our newsletter; • When you speak to any of our team; • When you complete a survey or enter a competition
HOW WE USE AND RETAIN THE PERSONAL INFORMATION WE COLLECT
We may retain you and your traveling companions’ names, email addresses, postal addresses, phone numbers and dates of birth (where provided) and use it for the following purposes:
1. To complete your booking with us, manage your booking and complete any subsequent bookings you make with us;
2. To send you notifications and communicate with you generally;
3. To contact you about special offers, brochures, new holidays, forthcoming events, surveys or competitions (if you do not wish to receive such communications. You may ask us to remove you from our marketing list in writing by contacting firstname.lastname@example.org or by clicking here on this privacy statement which will also be present on our websites or via the unsubscribe button that will be on any email that we send you.
4. To disclose to the providers of the services making up your booking (who could be located outside the UK/EEA);
5. To disclose some information to third parties in relation to customer services, credit card processing or other services;
6. To disclose your information where required by law, where such a request is made by a legal authority;
7. To disclose to organisations who act as “data processors” that perform business functions on our behalf (some of whom could be located outside the UK/EEA, where controls on data protection may not be as wide as the legal requirements in this country) and use the information for analysis including monitoring, measuring and assessing customer purchasing preferences and trends. Such business functions may include but are not limited to the provision of holiday feedback services, administration, business management, security and crime prevention/detection, research and analysis, marketing, dispute resolution, re-organisation/structuring of our business, customer care services, credit checking and debt collection services. These organisations may contact you directly in relation to your booking with Newmont Travel, Hotels of the Caribbean or Holy Land Travel;
8. To disclose, when it is mandatory to do so and in order for you to travel overseas (as requested by government authorities) your information for immigration, security and anti-terrorism purposes, or any other purposes which they determine appropriate. Even if not mandatory, we may exercise our discretion to assist where appropriate; 9
. To disclose to a third party who acquires or attempts to acquire all or a substantial part of the asset/stock in our company;
10. To disclose to other companies in the Newmont Travel Group for auditing purposes;
11. To disclose your information to a promotional partner, where you have given prior consent, when you enter an advertised competition or other promotion operated by the Newmont Travel Group of Companies. Should you be successful, your name(s), address(es) and email address(es) will be provided to the promotional partner in order to facilitate the management of the prize. If we collect detailed personal information during the booking process that is “Sensitive Personal Data”, it shall only be used in providing your booking arrangements and we will not retain it unless we specifically obtain your consent to do so for use in future bookings; if we wish to use it for any other purpose, we will specify the reason(s) to you and again seek your positive consent. We have taken all reasonable steps to have appropriate security measures in place to protect your information. Outside the European Economic Area, controls on data protection may not be as wide as the legal requirements in this country. The transmission of information via the internet is never completely secure. We exclude our liability for personal data lost in transmission to the website.
As we sell travel services direct to the general public we have been using booking and enquiry information to decide what to mail and email our customers and enquirers for many years. Our experience is that these communications are well received and those who prefer not to receive them are happy to simply let us know so that we can stop sending them. This way of direct marketing is a core part of the way we operate as a business and, as we currently understand the forthcoming legislation, this constitutes what is termed a legitimate interest. In terms of the regulation this can be the legal basis for processing an individual’s booking and enquiry data for the purposes of marketing. Following the introduction of GDPR, it is currently our intention to continue to send promotional information in relation to our offers to individuals based on the bookings and enquiries they have previously made and, on occasion, tell people about a product or service from another company if we feel it relates to our customers best interests. Once a year we will also continue to send out our Christmas Calendar to qualifying client files. You will, of course, continue to have the right to request that we send no further marketing information including the Christmas Calendar.
WHAT CAN I DO?
If you do not agree to our use of the information as set out above, you should inform us as soon as possible by writing to us at Newmont Travel, Building 3, North London Business Park, Oakleigh Road South, London N11 1GN or by email at email@example.com. In accordance with the Data Protection Act 1998, you may ask us in writing for a copy of the information we hold about you (There will not be a charge unless your requests are deemed excessive for the purposes that they have been requested) and to correct any inaccuracies in your information. We aim to respond to you within 30 days from the date of request. You can also choose not to provide us with some of the information we request, however, as a result, we may not be able to complete your travel arrangements.
Should you feel you do not wish to continue receiving any details of our special offers or our Christmas calendar you can of course continue to opt out at any time by writing to us at Newmont Travel, Building 3, North London Business Park, Oakleigh Road South, London N11 1GN or by email to firstname.lastname@example.org or by clicking here on this privacy statement which will also be present on our websites or via the unsubscribe button that will be on any email that we send you.
If you consent to join our email database to receive our email newsletters, then we may collect your name, country of residence and information about your booking preferences in addition to your email address. This information will be used to send you the email newsletters and to create a profile of our user base. We may conduct small surveys via email. If you wish to take part in any such survey, we will only use the information you provide via the survey for the purposes specified in the survey. If at any time you wish to unsubscribe from our email newsletter service you may do so by emailing email@example.com or by clicking here on this privacy statement which will also be present on our websites or via the unsubscribe button that will be on any email that we send you.
PROTECTING YOUR INFORMATION
We take website security very seriously and we are committed to safeguarding your personal information. We take a number of administrative and technical steps to ensure the security of the information you provide to us.
PERSONAL INFORMATION COLLECTED FOR LEGAL, COMPLIANCE, REGULATORY AND CRIME DETECTION AND PREVENTION PURPOSES
We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a legal claim, summons or regulatory order and to protect our property, rights, and interest as well as the property, rights, and interests of other person. We also process your personal information for accountancy and auditing, crime prevention and detection purposes, including the prevention of fraud for offline and online payments by identity checking. If you visit one of our stores, you may be monitored by CCTV which is in place for security purposes. In each case, we do so in compliance with applicable laws.
To ensure that we carry out your instructions accurately, to help improve our service and in the interest of security, we may monitor and/or record: (1) your telephone calls; and (2) customer transactions and activities on our website. All recordings are and shall remain our sole property.
UPDATES AND CHANGES
As our privacy and cookies policy may change due to developments in the law we encourage you to read this from time to time so you are aware of any changes in how we gather and use your personal information. Any changes to this policy will be either posted on our website, brochure and/or made available on request.