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our privacy policy

Privacy Policy - updated february 2018

 

Travel Safety Limited (registered number 104741968), whose registered office is at 161, Holme Lacy, Hereford, HR26DG, knows that you care how information about you is used and shared and we appreciate your trust in us to do that carefully and sensibly. This notice describes our privacy policy and forms part of our website terms and conditions (‘Website Terms’).

By accepting our Website Terms or by visiting www.etravelsafety.com (‘the Website’) you are accepting and consenting to the practices described in this Privacy Policy.

The Website is brought to you by eTravelSafety.com. eTravelSafety.com believes it is important to protect your Personal Data (as defined in Chapter 1, Article 4 of the General Data Protection Regulations (GDPR – Regulation (EU) 2016/679)) and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy. This policy explains how we may collect Personal Data about you. It also explains some of the security measures we take to protect your Personal Data, and tells you certain things we will do and not do. You should read this policy in conjunction with the Website Terms.

When we first obtain Personal Data from you, or when you take a new service or product from us, we will give you the opportunity to tell us if you do or do not want to receive information from us about other services or products (as applicable). You can normally do this by ticking a box on an application form or contract. You may change your mind at any time by emailing us at the address below.

Some of the Personal Data we hold about you may be ‘sensitive personal data’ within the meaning of the Data Protection Act 1998, for example, information about your health or ethnic origin.


 1. Collecting Information
We may collect Personal Data about you from a number of sources, including the following:

1.1.        From you when you explicitly agree to take a service or product from us, in which case this may include your contact details, date of birth, how you will pay for the product or service and your bank details.

1.2.        From you when you contact us with an enquiry or in response to a communication from us, in which case, this may tell us something about how you use our services, but only with explicit permission, including double opt-in.

1.3.        We do not collect any data that is regarded as high risk

1.4.        When you first give us Personal Data through the Website, we will ALWAYS give you the opportunity to say whether you would prefer us not to contact you by email.

1.5.        You can also always send us an email (at the address set out below) at any time if you change your mind.

1.6.        It is important that if you write to us, your request (either permission to process or request to remove) should be presented in a manner which is clearly distinguishable for any other matters.

1.7.        We do not knowingly collect data from anyone under the age of 16, and will remove details of anyone, should data be found to be owned by anyone under 16.

1.8.        We will only user the data provided by you for the purpose it was intended by you.

2.     Using Your Personal Information
2.1.        Personal Data about our customers is an important part of our business and we shall only use your Personal Data for the following purposes and shall not keep such Personal Data longer than is necessary to fulfil these purposes:

2.1.1.  To help us to identify you when you contact us.

2.1.2.  To help us to identify accounts, services and/or products which you could have from us or selected partners from time to time. We may do this by automatic means using a scoring system, which uses the Personal Data you have provided and/or any information we hold about you and Personal Data from third party agencies (including credit reference agencies).

2.1.3.  To help us to administer and to contact you about improved administration of any accounts, services and products we have provided before, do provide now or will or may provide in the future.

2.1.4.  To allow us to carry out marketing analysis and customer profiling (including with transactional information), conduct research, including creating statistical and testing information.

2.1.5.  To help to prevent and detect fraud or loss.

2.1.6.  To allow us to contact you in any way (including mail, email, telephone, visit, text or multimedia messages) about products and services offered by us and selected partners unless you have previously asked us not to do so.

2.1.7.  To keep you up to date with any member benefit scheme under which, as part of your membership benefits, we will give you membership information and details of discounts and offers we negotiate from time to time on behalf of our members. If you do not wish to receive this benefit, please write to our Data Protection Manager at the address given in clause 7.1 below.

2.1.8.  We may monitor and record communications with you (including phone conversations and emails) for quality assurance and compliance.

2.1.9.  We may check your details with fraud prevention agencies. If you provide false or inaccurate information and we suspect fraud, we will record this.

2.2.        We will not disclose your Personal Data to any third party except in accordance with this Privacy Policy.

2.3.        We may allow other people and organisations to use Personal Data we hold about you in the following circumstances:

2.3.1.  If we, or substantially all of our assets, are acquired or are in the process of being acquired by a third party, in which case Personal Data held by us, about our customers, will be one of the transferred assets.

2.3.2.  If we have been legitimately asked to provide information for legal or regulatory purposes or as part of legal proceedings or prospective legal proceedings.

2.3.3.  We employ companies and individuals to perform functions on our behalf and we may disclose your Personal Data to these parties for the purposes set out in clause 2.1 or, for example, for fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analysing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit and debit card payments and providing customer service. Those parties are bound by strict contractual provisions with us and only have access to Personal Data needed to perform their functions, and may not use it for other purposes. Further, they must process the Personal Data in accordance with this Privacy Policy and as permitted by GDPR. From time to time, these other people and organisations to whom we may pass your Personal Data may be outside the European Economic Area. We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Policy and GDPR.

2.4.        Where you give us Personal Data on behalf of someone else, you confirm that you have provided them with the information set out in this Privacy Policy and that they have not objected to such use of their Personal Data.

2.5.        In connection with any transaction which we enter into with you:

2.5.1.  We, and other companies in our group, may carry out credit and fraud prevention checks with one or more licensed credit reference and fraud prevention agencies. We and they may keep a record of the search. Information held about you by these agencies may be linked to records relating to other people living at the same address with whom you are financially linked. These records will also be taken into account in credit and fraud prevention checks. Information from your application and payment details of your account will be recorded with one or more of these agencies and may be shared with other organisations to help make credit and insurance decisions about you and members of your household with whom you are financially linked and for debt collection and fraud prevention. This includes those who have moved house and who have missed payments.

2.5.2.  If you provide false or inaccurate information to us and we suspect fraud, we will record this and may share it with other people and organisations. We, and other credit and insurance organisations, may also use technology to detect and prevent fraud.

2.5.3.  If you need details of those credit agencies and fraud prevention agencies from which we obtain and with which we record information about you, please write to our Data Protection Office at Unit 4c, Ramsden Road, Hereford, HR26LR

2.6.        You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

2.7.        All eTS staff are trained on GDPR and are obligation to hold up its content and ethos.  A copy of the Data Protection Policy is available on request.

3.     Protecting Information
3.1.        We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.

3.2.        We reveal only the last five digits of your credit card numbers when confirming an order. Of course, we transmit the entire credit card number to the appropriate credit card company during order processing.

3.3.        We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

3.4.        It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer.

3.5.        We will ensure that if there is a data breach, we will inform you and the Supervising Agency without undue delay and, where feasible, within 72 hours of us being made aware.

3.6.        Where, and in so far as, it is not possible to provide the information at the same time, the information may be provided in phases without undue further delay.

3.7.        eTS will at all times align and adhere to GDPR codes of conduct and monitoring that may be given by the official Supervising Agencies.

 4.     Data Transfers

4.1.        Any transfer of personal data which are undergoing processing or are intended for processing after transfer to a third country or to an international organisation shall take place only if, subject to the other provisions of GDPR.

4.2.        We may have to transfer personal data to a third country or an international organisation but only if we have provided appropriate safeguards, and on condition that enforceable data subject rights and effective legal remedies for data subjects are available

4.3.        Where personal data is transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate relating to the transfer.

5.     The Internet
5.1.        If you communicate with us using the internet, we may occasionally email you about our services and products.

5.2.        Please remember that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless they have been encrypted. Your communications may go through a number of countries before they are delivered – this is the nature of the internet. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.

6.     Restrictions

6.1.        Union or Member State law to which we are subject may restrict by way of a legislative measure the scope of the obligations and rights provided for in Articles 12 to 22 and Article 34, as well as Article 5 in so far as its provisions correspond to the rights and obligations provided for in Articles 12 to 22, when such a restriction respects the essence of the fundamental rights and freedoms and is a necessary and proportionate measure in a democratic society to safeguard:

6.1.1.  national security;

6.1.2.  defence;

6.1.3.  public security;

6.1.4.  the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including the safeguarding against and the prevention of threats to public security;

6.1.5.  other important objectives of general public interest of the Union or of a Member State, in particular an important economic or financial interest of the Union or of a Member State, including monetary, budgetary and taxation a matters, public health and social security;

6.1.6.  the protection of judicial independence and judicial proceedings;

6.1.7.  the prevention, investigation, detection and prosecution of breaches of ethics for regulated professions;

6.1.8.  a monitoring, inspection or regulatory function connected, even occasionally, to the exercise of official authority in the cases referred to in points (a) to (e) and (g); the protection of the data subject or the rights and freedoms of others; the enforcement of civil law claims.

6.2.        In particular, any legislative measure referred to in paragraph 1 shall contain specific provisions at least, where relevant, as to:

6.2.1.  the purposes of the processing or categories of processing;

6.2.2.  the categories of personal data;

6.2.3.  the scope of the restrictions introduced;

6.2.4.  the safeguards to prevent abuse or unlawful access or transfer;

6.2.5.  the specification of the controller or categories of controllers;

6.2.6.  the storage periods and the applicable safeguards taking into account the nature, scope and purposes of the processing or categories of processing;

6.2.7.  the risks to the rights and freedoms of data subjects; and

6.2.8.  the right of data subjects to be informed about the restriction, unless that may be prejudicial to the purpose of the restriction.

7.     Cookies
7.1.        When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer. These are called ‘cookies’.

7.2.        These cookies cannot be used to identify you personally and are used to improve services for you, for example through:

7.3.        Letting you navigate between pages efficiently

7.3.1.  Enabling a service to recognise your computer so you don’t have to give the same information during one task

7.3.2.  Recognising that you have already given a username and password so you don’t need to enter it for every web page requested

7.3.3.  Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast

7.3.4.  Users typically have the opportunity to set their browser to accept all or some cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these options, of course, means that personalised services cannot be provided and the user may not be able to take full advantage of all of a website’s features. Refer to your browser’s Help section for specific guidance on how it allows you to
manage cookies and how you may delete cookies you wish to remove from your computer.

7.3.5.  Multiple cookies may be found in a single file depending on which browser you use.

7.3.6.  The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide, as follows:

7.3.6.1.               Category 1: strictly necessary cookies. These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

8.     Right to Lodge a Complaint and Representation

8.1.        Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

8.2.        The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy.

8.3.        The data subject shall have the right to mandate a not-for-profit body, organisation or association which has been properly constituted in accordance with the law of a Member State, has statutory objectives which are in the public interest, and is active in the field of the protection of data subjects’ rights and freedoms with regard to the protection of their personal data to lodge the complaint on his or her behalf.

9.     Links

9.1.        The Website may include third-party advertising and links to other websites. We do not provide any personally identifiable customer Personal Data to these advertisers or third-party websites.

9.2.        These third-party websites and advertisers, or internet advertising companies working on their behalf, sometimes use technology to send (or ‘serve’) the advertisements that appear on the Website directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, web beacons (also known as action tags or single-pixel gifs), and other technologies to measure the effectiveness of their ads and to personalise advertising content. We do not have access to or control over cookies or other features that they
may use, and the information practices of these advertisers and third-party websites are not covered by this Privacy Policy. Please contact them directly for more information about their
privacy practices. In addition, the Network Advertising Initiative offers useful information about internet advertising companies (also called ‘ad networks’ or ‘network advertisers’), including
information about how to opt-out of their information collection.

9.3.        We exclude all liability for loss that you may incur when using these third party websites.

10.  Further Information

10.1.    If you would like any more information or you have any comments about our Privacy Policy, please either write to us at Data Protection Officer, Unit 4c, Ramsden Road, Hereford, HR26LR, or email us at info@etravelsafety.com.

10.2.    We may amend this Privacy Policy from time to time without notice to you, in which case, we will publish the amended version on the Website. You confirm that we shall not be liable to you or any third party for any change to this Privacy Policy from time to time. It is your responsibility to check regularly to determine whether this Privacy Policy has changed.

10.3.    You can ask us for a copy of this Privacy Policy and of any amended Privacy Policy by writing to the above address or by emailing us at info@etravelsafety.com. This Privacy Policy applies to Personal Data we hold about individuals. It does not apply to information we hold about companies and other organisations.

10.4.    If you would like access to the Personal Data that we hold about you, you can do this by emailing us at info@etravelsafety.com or writing to us at the address noted above.  We will respond to your request within one month of receipt.

10.5.    If for any reason we are unable to provide the data we will inform the you without delay, and at the latest within one month of receipt of the request, of the reasons for not taking action and on the possibility of you lodging a complaint with a supervisory authority and seeking a judicial remedy.

10.6.    This service will be free of charge except where the requests are manifestly unfounded or excessive.  In such cases we reserve the right to charge a reasonable fee to cover the time and resources or refuse to act on the request.

10.7.    Any request for such information needs to be backed up with relevant and suitable evidence of identity.

10.8.    We aim to keep the Personal Data we hold about you accurate and up to date. If you tell us that we are holding any inaccurate Personal Data about you, we will delete it or correct it promptly.

Please email us at hello@etravelsafety.com or write to us at the address above to update your Personal Data.