DATA PROTECTION POLICY FOR BOOKINGS MADE IN THE UNITED KINGDOM

YOUR BOOKING

In order to process your booking and to ensure that your travel arrangements run smoothly and meet your requirements we need to use the information you provide such as name, address, any special needs/dietary requirements etc.

We take full responsibility for ensuring that proper security measures are in place to protect your information. We must pass the information on to the relevant suppliers of your travel arrangements such as airlines, hotels, transport companies etc. The information may also be provided to security or credit checking companies, public authorities such as customs/ immigration if required by them, or as required by law.

Additionally, as your holiday will be outside the European Economic Area (EEA), controls on data protection in your destination may not be as strong as the legal requirements within the EEA. We will not however, pass any information onto any person not responsible for part of your travel arrangements. This applies to any sensitive information that you give to us such as details of any disabilities, or dietary / religious requirements. (if we cannot pass this information to the relevant suppliers, whether in the EEA or not, we cannot provide your booking. In making this booking, you consent to this information being passed on to the relevant persons.)Your data controller is; Greaves Travel Ltd.

You are entitled to a copy of your information held by us. If you would like to see this please contact us.

Links to third party sites are not covered by ABTA or ATOL protection.

DATA PROTECTION POLICY FOR BOOKINGS MADE OUTSIDE THE UNITED KINGDOM

YOUR BOOKING

In order to process your booking and to ensure that your travel arrangements run smoothly and meet your requirements we need to use the information you provide such as name, address, any special needs/dietary requirements etc.

We take full responsibility for ensuring that proper security measures are in place to protect your information. We must pass the information on to the relevant suppliers of your travel arrangements such as airlines, hotels, transport companies etc. The information may also be provided to security or credit checking companies, public authorities such as customs/ immigration if required by them, or as required by law.

Controls on data protection in your destination may not be as strong as the legal requirements in your country of origin. We will not however, pass any information onto any person not responsible for part of your travel arrangements. This applies to any sensitive information that you give to us such as details of any disabilities, or dietary / religious requirements. (if we cannot pass this information to the relevant suppliers, we cannot provide your booking. In making this booking, you consent to this information being passed on to the relevant persons.)Your data controller is; Greaves Travel Ltd. in the U.K., or Greaves Tours L.L.C. in North America.

You are entitled to a copy of your information held by us. If you would like to see this please contact us.

Third party sites accessed via links from this site (www.greavesindia.co.uk) are not covered by this policy, nor are Greaves responsible in any way for such sites or links.

General Data Protection Regulations

January 2020 updates

We ask that you read this website privacy policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

This website privacy policy is divided into the following sections:

Who we are
Our collection and use of your personal information
Transfer of your information out of the EEA
Cookies and similar technologies
Marketing
Your rights
Keeping your personal information secure
How long we keep your personal information for
How to complain
Changes to this website privacy policy

Who we are

This website is operated by Greaves Travel Limited with company registration number 01032421.

We collect, use and are responsible for certain personal information about you and when we do so we will be acting as a ‘controller’ in relation to that personal information.

Our website may contain links to other sites. We are not responsible for the privacy practices or the content of such linked websites.

If you have any questions about this privacy notice or the information we hold about you please contact our Compliance Manager at elemos@greavesuk.com.

Our collection and use of your personal information

We collect personal information about you when you access our website, enquire about our holidays and tours, book a holiday or tour with us, complete a visa application form or otherwise contact us, for example through our website contact form or when you request a call back.

We collect this personal information from you either directly, such as when you book with us or contact us, or indirectly, such as your browsing activity while on our website (see “Cookies” below).

The personal information we collect about you depends on the particular activities carried out through our website. Such information includes:

Identity Data

your full name;
gender;
marital status;
education qualification details;
professional occupation details;
previous travel information;
specific trip details;
in-country referee details;
citizen ID number;
date of birth;
passport details; and
the name of your immediate family members.

Contact Data

your address;
your telephone number; and
your email address.

Financial Data

bank account and payment card details.

Transaction Data

the details of any holidays or tours enquired about or booked; and
details about payments received from you.

Usage Data

information about how you use our website and services.

Technical Data

internet protocol (IP) address; and
browser type and version.

We will also collect certain special categories of personal data, for example:

your nationality, when you complete one of our booking forms; and
details of any dietary or other special requirements, in order to ensure that this information is communicated to those third parties who need to be aware of such requirements when fulfilling your booking.

In addition to the above, we will also collect the following special categories of personal data, as required if you request for us to complete a visa application on your behalf:

your religion (if any);
visible identity marks;
place of birth;
political views;
the nationality and place of birth of your immediate family members; and
criminal conviction details.

We use this personal information to:

process and manage your bookings with us
verify your identity
provide holidays and tours to you
customise our website and its content to your particular preferences
notify you of any changes to our website or to our services that may affect you
improve our services
send marketing communications to you

This website is not intended for use by children and we do not knowingly collect or us personal information relating to children.

Our collection and use of your personal information

We collect personal information about you when you access our website, enquire about our holidays and tours, book a holiday or tour with us, complete a visa application form or otherwise contact us, for example through our website contact form or when you request a call back.

We collect this personal information from you either directly, such as when you book with us or contact us, or indirectly, such as your browsing activity while on our website (see “Cookies” below).

The personal information we collect about you depends on the particular activities carried out through our website. Such information includes:

Identity Data:

your full name;
gender;
marital status;
education qualification details;
professional occupation details;
previous travel information;
specific trip details;
in-country referee details;
citizen ID number;
date of birth;
passport details; and
the name of your immediate family members.

Contact Data:

your address;
your telephone number; and
your email address.

Financial Data

bank account and payment card details.

Transaction Data

the details of any holidays or tours enquired about or booked; and
details about payments received from you.

Usage Data

information about how you use our website and services.

Technical Data:

internet protocol (IP) address; and
browser type and version.

We will also collect certain special categories of personal data, for example:

your nationality, when you complete one of our booking forms; and
details of any dietary or other special requirements, in order to ensure that this information is communicated to those third parties who need to be aware of such requirements when fulfilling your booking.

In addition to the above, we will also collect the following special categories of personal data, as required if you request for us to complete a visa application on your behalf:

your religion (if any);
visible identity marks;
place of birth;
political views;
the nationality and place of birth of your immediate family members; and
criminal conviction details.

We use this personal information to:

process and manage your bookings with us
verify your identity
provide holidays and tours to you
customise our website and its content to your particular preferences
notify you of any changes to our website or to our services that may affect you
improve our services
send marketing communications to you

This website is not intended for use by children and we do not knowingly collect or us personal information relating to children.

Purpose/Activity Type of data Legal basis for processing including basis of legitimate interest
To process and manage your booking with us.

(a) Identity

(b) Contact

(c) Financial

Performance of a contract with you
To respond to any queries raised via the “contact us” section of our website.

(a) Identity

(b) Contact

Necessary for our legitimate interests (to enable us to respond to your queries)
To process a visa application on your behalf.

(a) Identity

(b) Contact

Including the categories of special categories of personal data listed above

Performance of a contract with you
To update and enhance the services that we provide to you

(a) Identity

(b) Contact

(c) Transaction

(d) Usage

(e) Technical

Necessary for our legitimate interests (to study how customers use our services and to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for provision of administration and IT services, network security and to prevent fraud)

(b) Necessary to comply with a legal obligation

To use data analytics to improve our website, marketing, user relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of users and to keep our website updated and relevant)
To email you with suggestions and recommendations about holidays, tours and other services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(a) Consent;

OR

(b) Necessary for our legitimate interests (to grow our business), only where we are are permitted to do so because you have previously purchased a similar product or service from us, or have entered into negotiations with us in relation to a similar products or services.

Sharing with trusted third parties

We may share your personal data with the following third parties:

affiliated companies within our corporate family (in particular Greaves India);
a potential purchase of our business;
law enforcement or other authorities if required by applicable law.
third parties with which we have partnered to allow you to benefit from their services integrated into our own service offering;
third party payment processors, when we take a card payment from you;
trusted third party service providers as necessary for them to deliver services to you, that we are booking on your behalf:
activities i.e. safaris;
accommodation; and
travel and transportation i.e. airlines, transfers and other at-destination travel.

Where we share your personal data with a  third party service provider we only do so as necessary for such third party service providers to provide the services as requested or as needed on our behalf. These third parties (and any subcontractors) are subject to strict data processing terms and conditions and are prohibited from utilising, sharing or retaining your personal data for any other purpose than that which they have been specifically contracted to provide.

Some of these third party recipients will be based outside the European Economic Area and in particular many will be located in India where our holidays and bookings take place. Greaves India is part of our corporate group and we routinely share personal data with Greaves India to allow us to administer your booking.  For further information including on how we safeguard your personal data when this occurs, see ‘Transfer of your information out of the EEA’.

Transfer of your information out of the EEA

We will routinely transfer your personal information to destination countries where we deliver our travel services, which are located outside the European Economic Area (EEA). This is predominantly India, but also Sri Lanka, Bhutan, Nepal, Maldives and Egypt.

Such countries do not have the same data protection laws as the United Kingdom and EEA. Any non-occasional transfer of your personal information will be subject to us putting in place adequate safeguards, such as European Commission approved contract clauses which are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. We may make occasional transfers to these third parties where it is necessary for us to do so in order to perform our contract with you.

Cookies and other tracking technologies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For further information on cookies, our use of cookies, when we will request your consent before placing them and how to disable them, please see our Cookies Policy below.

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Marketing

We would like to send you information about our holidays and tours, competitions and special offers, which may be of interest to you. Where we have your consent (either verbally or via a tick box on your booking form) or it is in our legitimate interests to do so (because you have previously purchased or enquired about our travel services), we may do this by post, email, telephone, text message (SMS) or automated call.

You can unsubscribe at any time by contacting us, or by using the unsubscribe button at the bottom of any marketing emails that we send you.

Your rights

Under the General Data Protection Regulation you have a number of important rights free of charge. In summary, those include rights to:

access to your personal information and to certain other supplementary information that this Privacy Notice is already designed to address;
require us to correct any mistakes in your information which we hold
require the erasure of personal information concerning you in certain situations
receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations
object at any time to processing of personal information concerning you for direct marketing
object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you
object in certain other situations to our continued processing of your personal information
otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

email, call or write to our Compliance Manager
let us have enough information to identify you
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and
let us know the information to which your request relates.

When you visit our websites we use cookies.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How long we will keep your personal data for

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.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you

How to complain

We hope that our Compliance Manager can resolve any query or concern you raise about our use of your information.

The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/.

Changes to this website privacy policy

This website privacy policy was published on 15th January 2017 and last updated on 23rd January 2020. We may change this website privacy policy from time to time, so please ensure you regularly review the information contained herein.

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Cookies Policy

Please read this cookie policy carefully as it contains important information on who we are and how we use cookies on our website. This policy should be read together with our above privacy policy  which sets out how and why we collect, store, use and share personal information generally, as well as your rights in relation to your personal information and details of how to contact us and supervisory authorities if you have a complaint.

Who we are

This website is operated by Greaves Travel Limited with company registration number 01032421.

Our website

This cookie policy relates to your use of our website, https://www.greavesindia.co.uk/.

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us recognise you and your device and store some information about your preferences or past actions.

For example, we may monitor how many times you visit the website, which pages you go to, traffic data, location data and the originating domain name of your internet service provider.

We use this information to:

Improve our products and online experience.
Tailor your experience: Cookies allow us to provide you with information, products and services that we think you’ll find interesting.
Make our marketing relevant: We can show you relevant offers and promotions on our own websites and through our advertising networks.
Email newsletters: If you receive our email updates, we tailor the information we send you based on the data our cookies have collected from your recent visits to our website.

For further information on our use of cookies, including a detailed list of your information which we and others may collect through cookies, please see below.

For further information on cookies generally, including how to control and manage them, visit the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

Consent to use cookies and changing settings

We will ask for your permission (Consent) to place cookies or other similar technologies on your device, except where they are essential for us to provide you with a service that you have requested

You can withdraw any consent to the use of cookies or manage any other cookie preferences by emailing us at elemos@greavesuk.com.

Our use of cookies

The table below provides more information about the cookies we use and why:

Essential Cookies Name Purpose More information/ Duration

Non-Essential Cookies Name Purpose More information/Duration

[i.e. Google Analytics] [i.e Google Analytics sets cookies to help us accurately estimate the number of visitors to the website and volumes of usage. This is to ensure that the service is available when you want it and fast.] [insert further information and time period before cookie expires]

How to turn off all cookies and consequences of doing so

If you do not want to accept any cookies, you may be able to change your browser settings so that cookies (including those which are essential to the services requested) are not accepted. If you do this, please be aware that you may lose some of the functionality of our website.

For further information about cookies and how to disable them please go to the guidance on cookies published by the UK Information Commissioner’s Office, www.aboutcookies.org or www.allaboutcookies.org.

How to contact us

Please contact our Compliance Manager at elemos@greavesuk.com if you have any questions about this cookie policy or the information we hold about you.

This policy was published on May 2018 and last updated on 23rd January 2020.

We may change this cookie policy from time to time, so please ensure you regularly review the information contained herein.

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