TRAVLUX LTD respects your privacy and is committed to protecting your personal data. This 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) and tell you about your privacy rights and how the law protects you. We have a legal duty to protect personal data that we collect under the Data Protection Act 1998 (and any law which replaces it, including the new UK Data Protection Bill) (the “DPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”). For the purpose of the DPA and GDPR, we (TRAVLUX LTD) are the data controller (in other words, the organisation that determines how your personal information is used). Our contact details are set out in part 1 below:

This privacy notice aims to give you information on how TRAVLUX collects and processes your personal data through your use of this website (www.travlux.co.uk), including any data you may provide through this website when you sign up to our newsletter, submit a travel quotation enquiry, use the Live Chat plugin, request a callback to discuss your travel requirements, or purchase any services afterwards. This website is not intended for children and we do not knowingly collect data relating to children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

TRAVLUX LTD is the controller and responsible for your personal data (collectively referred to as “TRAVLUX”, “we”, “us” or “our” in this privacy notice). We take privacy seriously, therefore if you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below:

info@travlux.co.uk
Registered Office: TRAVLUX LTD, Kemp House, 160 City Road, London, EC1V 2NX

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.

This version was last updated on 29th September 2021. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your engagements with us.

This website may include links to third-party websites, plug-ins (to help us track, analyse online activity, and improve our service) 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.

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, maiden name, last name, marital status, title, date of birth and gender]

• Contact Data includes [billing address, email address and telephone numbers]

• Financial Data includes [bank account and payment card details]

• Transaction Data includes [details about payments to and from you and other details of products and services you have purchased from us]

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences

• Technical Data includes includes [internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website]

• Profile Data includes travel enquiry requests, travel quotations, or purchases made by you, your interests, preferences, feedback and survey responses. We also have tracking in place on our website which allows us to see the usage and activities of users to understand and improve your online experience and provides a better, more personalised, tailor made service to you. You consent to this when you accept the terms of our Cookie Policy, via our Cookie Banner, when you arrive on our site

• Usage Data includes information about how you use our website, products and services

We also collect, use and share Aggregated Data such as statistical or demographic 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 users accessing a specific website feature. 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 the following Special Categories of Personal Data about you: race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data). Nor do we collect any information about criminal convictions and offences. We may however need to request health related data that is relevant to your travel requirements at the point of purchase. We do this only with your express consent so that it can be passed to either the airline, hotel or other travel supplier to assist with either dietary needs or where you may need assistance during your trip. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

We will collect personal information from you when you make an enquiry. This includes your name, contact information, destinations and countries you are interested in and any additional details of your travel plans which you voluntarily give to us. We may also collect details about the best time to contact you where you request a callback as well as what prompted you to contact us, and any other requests or comments that you may make. We will use this information so that we can provide you with information that you have requested or contact you via phone or email if you have indicated you want to hear from us. We also collect personal information from you when you make a booking We have a legitimate interest to use your information in this way to make sure that we are able to help you find the right destination and start to plan the best holiday for you. Where we rely on our legitimate interests, we’ll always ensure that your rights are protected.

If you engage a service with us and a financial transaction takes place to guarantee this arrangement, we may ask you to provide certain details about your travel arrangements. This is likely to include details of your passports, emergency contacts, travel insurance arrangements, preferences and special requirements, frequent flier club membership, and visa requirements. This will also include details of any other friends or family who are accompanying you as part of your booking. You must obtain explicit consent from your friends and family, before providing us with their details. We will use this information to help us organise your trip, make bookings on your behalf and ensure that you (and any other friends or family accompanying you) receive the products and services set out in your itinerary. We collect this information so we can fulfil our contract with you and provide you with the quality of service we strive to provide. Where you are a regular customer we may retain some of this personal information so that we can use it when you next book with us as we have a legitimate interest to improve our customer journey and ensure we look after our regular customers. If you have made an enquiry with us, or booked a trip with us, we may send you via email details of any special offers, flash sales and inspirational travel ideas from time to time We send you this on the basis of our legitimate interests, but you always have a right to object to direct marketing (see further below) and if you do not want to receive these emails please let us know using the contact details or using the ‘unsubscribe’ link on all of our emails we send you.

We will collect certain technical information about you when you visit our website. This is likely to include: the internet domain you use, your IP address or other device identifier, your browser type and version (e.g. Chrome or Internet Explorer), the operating system and platform that you are using (e.g. Windows or Mac), the screen resolution of your device, the dates and times when you access our website, the full URLs of the pages you visit and the websites or links that you use to access our website, login information, details of products or services that are viewed and the length of visits to certain pages of the website. We do not sell, trade, or rent your personal information to others.

We may collect and use information from various sources in connection with the marketing and advertising of our services. This may include your contact details (and your marketing preferences) to contact you with certain marketing messages (e.g. marketing e-mails). We may also use data we collect from you (either directly or via our website or advertising) to help us to measure the effectiveness of our advertising and to establish what interests you and what doesn’t. We sometimes rely on your consent to contact you directly about our offering. In other scenarios in carrying out efficient and appropriate marketing and advertising for our services, we will rely on our legitimate interests, whilst always ensuring that your rights are protected. You can withdraw your consent or opt out of our direct marketing at any time through the ‘unsubscribe’ link in any marketing email or by contacting us direct. We may collect your contact details when you enter into competitions or promotions, or complete surveys. We will rely on your consent or on our legitimate interests (depending on whether we are marketing or carrying out market research), whilst always ensuring that your rights are protected. 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 (we call this marketing). You will receive marketing communications from us if you have requested a holiday quotation from us or made a travel booking with us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

We may collect details about you, such as your user name, when you engage with us on social media (by mentioning or tagging us in a post or contacting us directly) this is so that we can respond to any comments and queries you have. We rely on our legitimate interests to do this as we want to ensure our customers have the best possible experience, whilst always ensuring your rights are protected.

We may receive personal data about you from various third parties and public sources, as set out below here: (a) analytics providers such as Google analytics software based outside the EU]; (b) advertising networks such as Google, Facebook, Instagram, Twitter etc based inside or outside the EU; (c) search information providers such as Google and Bing based inside or outside the EU.

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, 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.

There are several grounds on which TRAVLUX may store and use your personal data. As follows:

• Consent: for certain types of processing (e.g. marketing activities), we rely on your consent to use your data. You may withdraw your consent at any time by contacting info@travlux.co.uk

• Contract: much of the time, our use of your personal data will be because of the contract between us – that is, in relation to your holiday booking. We will usually retain relevant data for up to seven years from the date the contract completes – e.g. the last day of your holiday

• Legal obligations: we are under certain binding legal obligations, such as accounting to the government for tax and making financial records available for audit. In such cases, we are typically obliged to retain data for up to seven years from the date of transaction

• Legitimate interests: we use data to manage our operations and to make business process improvements. Our legitimate interests will not override your right to privacy

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us (info@travlux.co.uk).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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, agents, contractors and other third parties 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.