PRIVACY POLICY
INTRODUCTION
Welcome to the Orbital Travel Limited privacy notice concerning your data entrusted to us.
Orbital Travel respects your privacy and is committed to protecting your personal data. Our privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) advise you on your privacy rights and how the new law protects you.
This privacy notice contains the following detailed information.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. [HOW WE USE YOUR PERSONAL DATA]
5. [DISCLOSURES OF YOUR PERSONAL DATA]
6. [INTERNATIONAL TRANSFERS]
7. [DATA SECURITY]
8. [DATA RETENTION]
9. [YOUR LEGAL RIGHTS]
10. [GLOSSARY]
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how Orbital Travel collects and processes your personal data through your use of our website and booking information that you provide to us when booking your holiday.
This website is not intended for children and we do not knowingly collect data relating to children.
CONTROLLER
Orbital Travel is a data controller and responsible for your personal data (referred to as “Orbital Travel”, “we”, “us” or “our” in this document).
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager as detailed below.
CONTACT DETAILS
You can contact our Data Privacy Manager at:
Post:
Orbital Travel Limited,
Manor House,
High Street,
Buntingford,
Hertfordshire,
SG9 9AB
FAO: Data Manager
Email: enquiries@orbitaltravel.co.uk
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE.
This version was written on 21st May 2018.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA ORBITAL TRAVEL COLLECT
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, last name, marital status, title, and gender.
- Contact Data includes address (lead passenger only, postal address, email address, telephone numbers).
- Transaction Data includes details about your holiday/s with us.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of clients based in a certain geographical area or looking at certain pages on our web site. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data under the terms of a contract we have with you and you fail to provide that data when requested, we will not be able to perform the contract. In this case, we will have to cancel a product the service we have intended to supply but we will notify you if this is the case in good time.
PHISHING
Phishing is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an email to a user, in an attempt to get the user to send private information that will be used for identity theft and fraud.
Orbital Travel will never ask you to send any personal details via email. If we require such details, for security reasons we will ask you to contact us by telephone. Should you receive an email claiming to be from Orbital Travel requesting this kind of information please contact us by phone immediately.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms on our web pages, or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Purchase a Holiday or service either via phone, email or on our website;
- submit a holiday review and give your permission for this review to be included on our web pages, we would only include your name, date and type of holiday taken.
- speak to customer services on matters to linked to your contact with us in forming a contract with us.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you. This contract will normally be in the form of a holiday booked with Orbital Travel Limited.
- Where we have your consent, when placing a holiday booking this is required to form a contact between us.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
You have the right to withdraw consent to marketing at any time by unsubscribing via the link provided with each marketing email we send to your or by contacting us on enquiries@orbitaltravel.co.uk
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we will not process your personal data for more than one lawful contract for holiday booking. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a new client |
(a) Identity |
Performance of a contract with you |
|
To process and deliver your booking including: |
(a) Identity |
(a) Performance of a contract with you |
|
|
|
|
|
To manage our relationship with you which will include: |
(a) Identity |
(a) Performance of a contract with you |
|
To enable you to partake in an event, prize draw, competition or complete a survey |
(a) Identity |
(a) Performance of a contract with you |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity |
(a) Necessary for our legitimate interests (for running our business), provision of administration and IT services, network security. |
|
|
|
|
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. |
(a) Technical |
Necessary for our legitimate interests (to define types of customers for our products and services) |
|
|
|
|
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (this is “marketing”).
You will only receive marketing communications from us if you have requested information from us or purchased holidays from us and, in each case, you have opted in to receiving that marketing material. You will also receive marketing communications from us if you have provided us with your details when you entered a competition or registered for a promotion and gave us your consent as part of that process.
THIRD-PARTY MARKETING
We do not and will not share any information that you give us with any other company or marketing company in the form of a client list or in any other form. Your date is as important as your holiday and we treat both the same respect.
COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
- External Third Parties for the purposes of completing our contract with you for your holiday booking. This will only extend to names of clients travelling, no personal data is ever supplied to third parties.
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes, we do not provide them with any other data that clients names. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
6. INTERNATIONAL TRANSFERS
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data (names only) will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data (names only) to countries that have been deemed to provide an adequate level of protection for personal data.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
Direct clients, those clients who have booked their holiday with Orbital Travel.
We will only retain your personal data for a maximum of five years after the date of your return to the UK. This data will be used for statistical purposes and to provide information that may be required in the unlikely advent of a dispute after your return. We also have to keep hard copies of all invoices for HMRC for six years..
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.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
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.
9. YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
- [Request access to your personal data].
- [Request correction of your personal data].
- [Request erasure of your personal data].
- [Object to processing of your personal data].
- [Request restriction of processing your personal data].
- [Right to opt-out of automated profiling of your personal data]
- [Request transfer of your personal data].
- [Right to withdraw consent].
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. GLOSSARY
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent means you have explicitly given us permission to process your personal data. In such circumstances we will have asked you a specific question and you will have entered information or ticked a tick-box to indicate your consent.
THIRD PARTIES
EXTERNAL THIRD PARTIES
- Service providers acting as processors based in the UK who provide marketing, IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK and EU who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Customer service call, email, webchat, display advertising and website behavioural service providers, acting as processors, based in the UK, EU or USA;
- Social media platforms and service providers based in the USA
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. In such circumstances we may reserve the right to delete your personal data rather than hold it but restrict processing, where our processes are not set up to enable a restriction.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Request to opt out of automated profiling of your personal data. You have the legal right to opt-out of any automated profiling of your personal data that could have a legal consequence for you, and have a human being involved in the processing decision rather than it being automated. The only profiling of this type that we undertake is in our marketing activities, in which we tailor our marketing communications to your transactional history and product preferences. If you wish to opt-out of this automated profiling please contact us, though please be aware that our systems are not configured to send un-tailored marketing communications to you, so in practice opting out of automated profiling will result in you being opted out of receiving marketing communications from us.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Orbital Travel is the sole owner of the information collected on our Website. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement.
YOUR DATA(UK SPECIFIC CONTENT)
Your privacy is of the highest importance to us, and we promise never to release your personal details to any outside company for mailing or marketing purposes.
We may collect and process information that you provide by filling in forms on our website, details of transactions you carry out through our site and details of your visits to our site. If you contact us, we may keep a record of that correspondence.
Any personal data gathered by us in your use of this site will be recorded electronically and only used in accordance with the UK Data Protection Act 1998.
For the purpose of the Data Protection Act 1998, the data controller is Orbital Travel Limited of Manor House, High Street, Buntingford, Hertfordshire SG99AB.
None of our service providers are given personal information outside of the UK except your name in order to perform their obligations under any contract between you and Orbital Travel.
IP ADDRESSES AND COOKIES
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.
For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our site and to deliver a better and more personalised service. They enable us:
To estimate our audience size and usage pattern.
To store information about your preferences, and so allow us to customise our site according to your individual interests.
To speed up your searches.
To recognise you when you return to our site.
You may refuse to accept cookies by indicating that you do not consent to their use on the banner that appears on the homepage on your first visit. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.Our cookies fall into fivecategories:
Strictly Necessary Cookies - These cookies enable services you have specifically asked for, they allow you to move around the website and use certain features, such as accessing secure pages.
Session Cookies – These cookies allow the site to ‘remember’ content from page to page for example shopping basket. These cookies expire when the user leaves the site or closes the browser.
Performance Cookies - These cookies collect information about how you use the website, for example pages you go to and any error messages you experience. These cookies don't gather information that identifies you, they are anonymous and help to improve how the website works.
Functional Cookies - These cookies allow a website to remember choices you make, and tailor the website to provide enhanced content for you.
Targeting Cookies - These cookies are used to tailor marketing so it is relevant to you. They are also used to limit the number of times you see an advertisement.
Persistent cookies - This type of cookie is saved on your computer for a fixed period (usually a year or longer) and is not deleted when the browser is closed. Persistent cookies are used where we need to know who you are for more than one browsing session. For example, we use this type of cookie to store your preferences, so that they are remembered for the next visit.
We will only use information held about you to carry out our obligations arising from any contracts entered into between you and us and marketing if you have opted into receiving this..
We may use your data to provide you, via email, post, telephone or SMS with information, products or services that you request from us or which we feel may be of interest to you, or share your details with selected third parties which we believe may be of interest to you, where you have consented to be contacted for such purposes.We may use the data in accordance with the preferences expressed in your acceptance of the Radley cookie policy and terms and conditions of use of the Radley website.
Our [website/app] uses cookies/advertising IDs for the purpose of advertising. This enables us to show our advertisements to visitors who are interested in our products on partner websites and apps. Re-targeting technologies use your cookies or advertising IDs and display advertisements based on your past browsing behaviour.
We realise how important it is to securely store any information that you provide us..
You can tell whether a webpage is secure as 'https' will replace the 'http' at the front of the www.orbitaltravel.co.uk in your browser address window, also a small locked padlock will appear in your browser window.
Phishing is the practice of tricking someone into giving confidential information. Examples include falsely claiming to be a legitimate company when sending an email to a user, in an attempt to get the user to send private information that will be used for identity theft and fraud.
Orbital Travel will rarely ask you to send any personal details via email. If we require such details, for security reasons we will ask you to contact us by telephone. Should you receive an email claiming to be from Orbital Travel requesting this kind of information please do not respond but contact us immediately.
You have the right to access any information that we hold about you. Your right of access can be exercised in accordance with the UK Data Protection Act 1998. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
If you feel that Orbital Travel is not abiding by its posted privacy policy, you should first or telephone 01762-247174. You can also write to us at:-
Orbital Travel Limited, Manor House, High Street, Buntingford, SG9 9DP
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