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Privacy Policy

PRIVACY POLICY

This policy sets out the basis on which any personal data we collect from you, that you provide to us, or that we may collect from other sources will be processed by us.

Links to anythird-party sites are not our responsibility, although we use our best efforts to choose them with care. You should read and satisfy yourself with those third parties’ privacy policies before using such linked sites.

  1. What information do we collect from you?

1.1 Information you give us. This is information about you that you may give us by:

  1. filling in forms on any of our platforms;
  2. as part of using our services;
  3. by corresponding with us by phone, e-mail, online chat or otherwise;
  4. registering on our website;
  5. Sharing information on social media from our platforms; or

1.2. Information we collect about you. With regard to each of your visits to our sites we may automatically collect the following information:

  1. technical information, including the internet protocol (IP) address used to connect your computer to the internet, type of mobile device you use, a unique device identifier (for example your device’s IMEI number, the MAC address of the device’s wireless network interface or the mobile phone number used by the device), mobile network information, your mobile operating system, your login information, browser type and version you use, time zone setting, browser plug-in types and versions, operating system and platform;
  2. information about your visit to our platforms, including the full uniform resource locators (URL) clickstream to, through and from our platforms (including date and time); pages you viewed or information you searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
  3. information stored on your mobile device, which may include contact information, friends lists, login information, photos, videos or other digital content, check ins;
  4. details of your use and visits to any of our platforms including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access;

1.3. Information we receive from other sources. We may receive information about you if you use any other websites we operate or other services we provide. We also work with third parties (including, for example, electronic analytics, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

1.4 The types of personal information we process. The personal information we collect can include:

  1. your full name;
  2. postal address;
  3. employer and job title;
  4. e-mail address;
  5. records of your correspondence with us;
  6. phone number (s);
  7. username and password;
  8. photos and videos;
  9. social media account names;
  10. payment details;
  11. and any other information you may share with us or enter into any of our platforms.
  1. How do we use your personal information?

2.1. We use information held about you in the following ways:

  1. communicate with you in response to a specific action performed by you on our platforms, e.g. when you book a hotel, buy a ticket, reserve a table, leave a review, enter a competition, etc;
  2. to provide you with support in using our platforms, and to provide you with the information, products and services that you request from us;
  3. to provide you with information about our events
  4. to provide you with information about other services we offer that are similar to those that you have already enquired about, for example newsletters
  5. to send you news items which are relevant to your interests;
  6. to notify you about changes to our services;
  7. as part of our efforts to keep our platforms safe and secure;

 

  1. Our Legal Basis for processing data

3.1 Organisations that collect and use personal data must have a lawful basis for doing so under data protection law and we are required to let you know the lawful basis on which we rely to process your personal data. We rely upon the following lawful bases:

  • Your consent to use your data for a particular purpose (for example to send you direct marketing by e-mail or to collect sensitive personal data);
  • Where the use of the data is in our “legitimate interests” (see below for more information);
  • Where we need to process your data in order to perform our obligations under a contract that we have entered into with you (for example to enrol you in an event or provide you with access to resources); and
  • To process data where we are under a legal obligation to do so.

3.2 Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, as long as its use is fair and does not adversely impact the rights of the individual concerned. When we use your personal information, we will always consider if it is fair and balanced to do so and if it is within your reasonable expectations. We will balance your rights and our legitimate interests to ensure that we use your personal information in ways that are not unduly intrusive or unfair. Our legitimate interests include:

  • Administration and operational management, including responding to solicited enquires, providing information that you have requested, research, events management, the administration of our resources and tools.
  • Liaising with third parties, including working with partner organisations to develop new programmes and resources which further our purposes.
  1. Will we share your information with others?

4.1 We may share your personal information with any member of our group, which includes our group companies both in the UK and outside the UK.

4.2 We may share your information with selected third parties including:

  1. business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  2. we may (with your consent, where appropriate) pass your details onto third parties including our partners to provide you with information and offers which may be of interest to you;
  3. analytics and search engine providers that assist us in the improvement and optimisation of our platforms.

4.3 We may disclose your personal information to third parties:

  1. in the event that we transfer, sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and/or
  2. if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or our safety and/or, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

4.4 We may allow our staff, consultants and/or external providers (data processors) acting on our behalf to access and use your information for the purposes for which you have provided to us (e.g. to analyse data and to process payments). We only provide them with the information they need to deliver the relevant service, and ensure that we take steps to ensure that they process personal data in a secure manner.

  1. How do we protect the security of personal data?

5.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.

5.2 While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred via the internet. If you have any particular concerns about your information, please contact us.

6 The information we collect from you may be transferred to and processed and/or stored at a destination outside the European Economic Area (“EEA”). If we send your personal data outside the EEA we will take reasonable steps to ensure that the recipient implements appropriate measures to protect your information.

  1. How long do we keep your data for?

7.1 We will only retain your personal information 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.

7.2 In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you no longer have a relationship with us, we will retain and securely destroy your personal information in accordance with applicable laws and regulations.

7.3 If you request to receive no further contact from us, we will keep some basic information about you on our suppression list in order to avoid sending you unwanted materials in the future.

  1. Your privacy rights

8.1 You have a number of rights under data protection legislation. These include:

  1. Right of access You have the right to know what information we hold about you and to ask, in writing, to see your records. We will provide you with details of the records we hold as soon as possible and at latest within one month, unless the request is complex. We may require proof of identity before we are able to release the data.
  2. Right to be informed You have the right to be informed how your personal data will be used. This policy as well as any additional information or notice that is provided to you either at the time you provided your details, or otherwise, is intended to provide you with this information.
  3. Right to withdraw consent Where we process your data on the basis of your consent (for example, to send you marketing texts or e-mails) you can withdraw that consent at any time.
  4. Right to object You also have a right to object to us processing data where we are relying on it being within our legitimate interests to do so (for example, to send you direct marketing by post).
  5. Right to restrict processing In certain situations you have the right to ask for processing of your personal data to be restricted because there is some disagreement about its accuracy or legitimate usage.
  6. Right of erasure In some cases, you have the right to be forgotten (i.e. to have your personal data deleted from our database). Where you have requested that we do not send you marketing materials we will need to keep some limited information in order to ensure that you are not contacted in the future.
  7. Right of rectification If you believe our records are inaccurate you have the right to ask for those records concerning you to be updated.
  8. Right to data portability Where we are processing your personal data because you have given us your consent to do so, you have the right to request that the data is transferred from one service provider to another.

Complaints If you are unhappy with the way in which we have handled your personal information please contact us at 

  1. How will we let you know of changes to our privacy policy?

We may update this policy from time to time without notice to you, so please check it regularly. We will however aim to bring any significant changes to your attention. The privacy policy was last updated in 24 May 2018.

  1. How to contact us?

10.1 Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to 

10.2 Contact Office: 15 West Central Street, London, WC1 1JJ

Cookies

Our platforms use cookies to distinguish you from other users of our platforms. A cookie is a small file of letters and numbers that we store on your browser or your hardware (your computer or mobile device). Cookies contain information that is transferred to your computer or mobile device.

Cookies help us to provide you with a good experience when you use our platforms and also allow us to improve our platforms. By continuing to use and browse our platforms, you are agreeing to our use of cookies.

We use the following cookies:

  1. Strictly necessary cookies. These are cookies that are required for the operation of our platforms. They include, for example, cookies that enable you to log into secure areas of our platforms.
  2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our platforms when they are using them. This helps us to improve the way our sites and/or the App works, for example, by ensuring that users are finding what they are looking for easily.
  3. Functionality cookies. These are used to recognise you when you return to our platforms. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).
  4. Targeting cookies. These cookies record your visits to our platforms, the pages you have visited and the links you have followed. We will use this information to make our platforms and any advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose.
  5. Remarketing cookies. You may notice that sometimes after visiting a site you see increased numbers of adverts from the site you visited. This is because advertisers, including ourselves pay for these adverts. The technology to do this is made possible by cookies and as such we may place a so called “remarketing cookie” during your visit. We use these adverts to offer special offers etc to encourage you to come back to our site. We cannot proactively reach out to you as the process is entirely anonymised.

Google Analytics

Google Analytics are used widely by websites and mobile applications to collect information about how visitors use a site and/or the App. We may use Google Analytics cookies to collect information about how users use our platforms and to improve our platforms.

Google Analytics collect information in an anonymous form and will not allow us to identify you or collect any personal information about you.

Google Analytics do not track your internet activity after leaving our platforms.

Social media cookies

Our platforms may contain buttons and content from social media sites such as Facebook, Twitter and YouTube to enable you to share content from our platforms with your social media networks. If you use these features, these social media sites may use their own cookies. Information on how these are used can be found on their respective websites.

Third parties’ cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies you may not be able to access all or parts of our platforms.

It may be that your concerns around cookies relate to so called “spyware”. Rather than switching off cookies in your browser you may find that anti-spyware software achieves the same objective by automatically deleting cookies considered to be invasive.