Last updated: 22nd March 2019
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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© Trafalgar Tours West, Inc. 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.
6.1 Our customers
6.2 Examples of who this policy covers
6.3 When we are data processor only
6.4 Terms used in this policy
When we refer to "processing" 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 vacations, package vacations, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and 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 provided by a third party which we book for you (acting as agent for you or the third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.
We process your personal data in accordance with the following data protection law(s): The Data Protection Act 1998 (which covers protection of personal data generally).
We also seek to comply generally with the laws of the United States in relation to the processing of your personal data.
This section summarizes the types of personal data about you that we process:-
8.1 Data concerning you as an individual
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licenses, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out about you (such as to verify your identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and other information provided to us by or in relation to you which concern you as an individual.
8.2 Business Related Information
If you are an individual associated with a business or other organization that is our customer, your personal data may include the following information that we link to you: business or organization details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organization (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).
8.3 Enquiry and Booking information
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: records of enquiries and searches for vacation and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the vacation, accommodation, travel, car hire, and other travel services booked or enquired about; details of passengers / vacationers traveling; details of the provider of travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.
8.4 Performance information
Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any vacation or other travel services, and information relating to payments to be made.
8.5 Survey Information
Information collected or generated out of surveys we conduct.
8.6 Competition Information
Information collected or generated out of competitions or promotions we run.
8.7 Account, Registration and Loyalty Information
Information concerning accounts, registrations, or memberships with us, or participation in loyalty programs.
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. The range of data we collect will depend on how you interact with our website.
This information may also include: data inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.
This section sets out 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 that is automatically provided by your browser to our servers; information recorded 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: from correspondence with you; verbally to us over the phone or in person; by filling in any field or form on a website; by filling in any printed form we provide you; by e-mail; from documents you provide us; and from updates to information provided from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a vacation or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; or request sales or advertising information, including brochures.
We may obtain personal data concerning you from third parties, including: providers of vacations, accommodations, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organizations; from any business or organization you are associated with; and telephone numbers identified by the telephone system when you telephone us.
We and any suppliers or sub-contractors working for us may generate personal data relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through analysis of your personal data or data gained from your use of our website. We may record telephone calls with you when lawful to do so.
10. What do we use your personal data for ?
This section sets out the uses which we make of your personal data. We use your personal data to:
Operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing accounts or registrations you have with our websites and making changes to your settings and profile at your request.
Provide information to you about our website, systems and services, including to respond to booking enquiries and searches for vacations and travel, and keep you updated generally.
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 process transactions authorized or made with us which relate to you.
Collect and make payments due and administer our accounts.
Communicate with you concerning enquiries, bookings, travel services provided, problems and complaints, and respond to submissions, enquiries or requests from you.
Keep internal records and maintain reasonable archives, including as to enquiries, bookings, contracts, travel services, and complaints.
Analyze, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; carry out surveys and analyze the results; run promotions and competitions; undertake product or customer research/development; assist us in and help us improve sales, editorial, advertising and marketing processes; carry out other business development and improvement activities; and provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how customers generally use our websites and book travel services with (or through) us. We may also use this information to ascertain interests so we can better tailor our business offerings.
Carry out direct marketing to you. See next section below for further information.
Report aggregate information concerning usage of our websites to our advertisers. For example, we may create anonymous statistical data about browsing actions and patterns, without identifying any individual.
10.10 Cooperation with government, police and judicial authorities
Provide information in response to a command or request from a government, police or judicial authority. This could include, by way of example, a government agency, police department, or court that either requires or asks us to voluntarily cooperate in providing information for their investigation of any matter or for purposes of a pending proceeding.
For any purpose which we obtained your consent to.
We do not use or disclose your personal data for direct marketing purposes unless we obtained your consent, such as through an opt-in or opt-out tick box on any form or website of ours.
We may also use personal information you provide us to review and improve the guided vacations and services we offer, and to contact you (by mail, email, telephone or other means) about other guided vacations and services offered by Trafalgar that my interest you. If you don't want to receive this information, or you want a copy of the personal information we hold about you, write to us at Trafalgar, 801 East Katella Avenue, Anaheim, California 92805. Trafalgar may charge a fee for supplying you this information as permitted by law.
Where you consented, we may use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which are offered by or which can be booked with third parties through us or through any other company in the same group of companies as us (i.e. within The Travel Corporation group) or third parties selected by us.
Where you consented, we may disclose your personal data which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within The Travel Corporation group), or to third parties. They may use this to carry out direct marketing and send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal data for this purpose, by contacting us as detailed above. Withdrawing your consent will not affect any disclosures we already made (i.e. we will not be able to remove your personal data from anyone we disclosed it to), but we will tell you who they are on request, and you can contact them directly.
We transfer your personal data to third parties in the following circumstances:-
We may disclose your personal data to third parties (including intermediaries) to carry out checks concerning you or enforce a booking or contract with you (including credit, security, fraud and identity checks). This 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) to deal with a booking enquiry made by or for you, to make a booking requested by or for you, to perform and administer a booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, collect payments to be made by you, investigate and respond to complaints, and enforce a booking or other contract with you. Such third parties may include suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).
We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make enquiries with or engage or sub-contract to perform a booking or other contract, including to provide any travel, tour or other products or services we agreed to provide to you. We may disclose your personal data to suppliers with whom we make an enquiry concerning or book 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 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 an application is made through us for travel or other insurance to cover you, we will pass your personal data 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), we may provide your personal data to them for use for or processing as part of those purposes.
Where a facility on our website is designed to make certain of your personal data public (e.g. posts you make to a public forum or review of a facility) then personal data you provide in relation to that forum or facility, which is provided in circumstances indicating it is intended to be published, will be disclosed to the public.
We may supply personal data to a government authority or regulator, police authority, court or party in litigation, where requested to cooperate with the authority or required to comply with a legal requirement, for the administration of justice, for purposes of customs, visas and immigration, or where reasonably required to protect your interests or enforce any booking or other contract. 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 consent, to third parties to carry out direct marketing. See the direct marketing section above.
If our customer is a business or organization, and we hold your personal data in your capacity as an associate of that business or organization (including as agent, representative, contact, employee, officer, owner, partner, or director), we may disclose to them that personal data. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your 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, your personal data will be transferred to the acquirer to enable them to continue our business. If we investigate or negotiate a possible transfer to a third party, your personal data may be transferred in the process of investigating the possible transfer.
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 in the world.
Where we disclose your personal data to third parties, the disclosure may involve transfer of your personal data anywhere in the world, and the third parties may transfer, store or otherwise process that information anywhere in the world.
We intend to comply with legal requirements concerning the transfer of your personal data by us to any third party outside the country where we are established, and where your personal data is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.
15.1.1 Security Measures
We have implemented security policies, rules and technical measures with a view to security of personal data.
15.1.2 Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software to encrypt personal information you provide us while it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.
15.1.3 Storage of your personal data
Personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.
For your privacy protection, you should maintain anti-virus and other malware protection software on your computers and other devices, and maintain other measures and follow other procedures to protect your personal data. You should not include sensitive personal data in any e-mails you send us, including payment card information.
We encourage you to be careful about whom you give personal data to. Regarding sensitive personal data, such as payment card information, or passport numbers or log-in details, we will only ask you for such information in person or through our website, or by telephone in connection with a booking you make or made. If you are ever in doubt about who is contacting you, asking for information, or why, please do not provide the information. Instead, contact us directly to inquire about the request for information. Please let us know if someone purports to contact you in other circumstances, using our name.
We keep your personal data as long as reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal data may be relevant to a possible obligation or liability we may have.
You may ask 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 a copy of your personal data that we hold. We may charge a fee for handling your request, in an amount prescribed by law. The law allows 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 ask us to stop using your personal data for any purpose in any manner that causes you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.
You have the right to ask us to stop using your personal data to carry out direct marketing to you.
You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal data we hold about you.
You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.
The laws we comply with are regulated by the State of California Department of Justice. In addition to your rights above, if you have a complaint or concern, you can seek assistance from such government regulator, who has powers to compel us to comply with laws and fine us for non-compliance. Before you do so, we hope you will contact us first to discuss any complaint or concerns you have.
This policy is subject to the law of the state of California, County of Orange, and you must bring any claims against us exclusively in the courts of the state of California, County of Orange.[England and Wales].