NoteWorthy Privacy And Cookies Notice

 

1. Introduction and scope of this Privacy Notice

We take your privacy seriously and will only use your personal data as described in this Privacy Notice.

This Notice describes the personal data that we collect about you as a Participant in one of our Programs, as a person accessing our website or as a job applicant (in each case referred to in this Notice as “you” or “your”) and also explains how we’ll store and handle that data, and keep it safe.

We may need to update this Notice from time to time. We will notify you of any significant changes but you can easily check our Privacy Notice online on our website at any time.

Meanings of some other expressions used in this Notice

Intermediary means a tourism business that is selling you one of our Programs
Participant means you or any other person participating in one of our Programs
Program means one of our tailor-made experience itineraries designed for you and/or other Participants

 

2. Who are we?

Your personal data is held by Worthy International Travel Limited (referred to in this Notice as “we”, “us” or “our”), which is a company incorporated in England and Wales (with registered number 02007484), and you will find us registered as a “data controller” with the Information Commissioner’s Office (www.ico.org.uk).

 

3. What are the legal bases we rely on to collect your personal data?

The law on data protection sets out a number of different reasons that a business may collect and process your personal data which is explained below with some examples although the examples are not exhaustive of the circumstances in which we use personal data.

Legitimate Interest means the interest of our business in conducting and managing our business in a way which might reasonably be expected and which does not materially impact your rights, freedom or interests.

For example we use your personal data to enable us to give you the best service and the best experience if you are a Participant in one of our Programs or if you are accessing our website or to enable us to process your job application if you are a job applicant.

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 at dataprotection@noteworthy.co.uk  .

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.

For example, if you agree to book a Program with us where we are supplying the Program to you directly (rather than to an intermediary who is on-selling the Program to you) we need to collect and process your personal data for the purpose of fulfilling our contract with you to supply the Program.

Consent means we can collect and process your information with your consent.

For example, if you tick a box to receive newsletters or other marketing materials.

Compliance with legal obligations means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

For example, we can pass to law enforcement agencies information about people involved in any criminal activity.

For establishing, exercising or defending legal claims

For example we use information about people against whom we are enforcing our contractual rights or with whom we may be in any legal dispute.

 

4. How and when we collect your personal data

If you are a Participant we will collect personal data directly from you and/or from an Intermediary and who has provided to us personal data concerning you and other Participants to enable us to design and make the arrangements for the Program. This personal data may be collected in an information form that you are asked to complete or which is completed on your behalf. We may also collect your personal data when we receive complaints or feedback from you or the Intermediary.

If you are a job applicant we will collect personal data during the application process including personal data collected when you apply by email, in any job application form and during job interviews.

If you access our website we may collect personal data about you. Your internet service provider gives your device a number (called an IP address) to enable your device to connect to the internet. We may use this number to collect personal data about visitor traffic to our web pages. We do not use your IP address to identify you personally.  We also track your use of our website by putting cookies (which are small text files) on your device. There is more information on our use of cookies in our Cookies Policy at the end of this Privacy Notice.

If you supply services to us (for example as a tour guide, pilot or chauffeur).  We may collect personal data about you when you provide services to us.

 

5. What type of personal data do we collect about you?

As a Participant

Your details: Your name, title, marital status, email address, address, telephone number, date of birth, your accommodation and travel preferences, loyalty membership details, credit/debit card and other payment details, your reasons for travel (e.g. anniversary, wedding, family reunion, birthday, touring etc.).

Dietary, Health and Special Access Information: Any special dietary requirements and if necessary any information concerning your health or special access requirements to the extent it is necessary for you to enjoy your Program, and information contact details of your next of kin in case of emergency.

Identification documents: If required to enable you to enjoy your Program, your passport or identity cards and driving license including, where necessary, number, place and date of issue and expiry date.

Travel and Program details: Your travel details and itinerary before and after joining the Program to the extent necessary to integrate our Program with your other travel/itinerary arrangements, and details of the Program itself including, for example, experiences and excursions included in the Program, your baggage requirements and any other relevant information to enable us to make your Program a more enjoyable experience.

Your interactions with us: Information about your interactions or conversations with us or about your experiences during the Program, your feedback and comments about your experience on our Program, whether in writing, by email or verbal, including photographs of you and other people in your Program that we may take either specifically at your request for your own enjoyment or to show to the Intermediary to show how much you are enjoying our Program.

Information concerning your children: If any of your children under the age of 18 are accompanying you on one of our Programs we will ask you, if you have the necessary legal authority to do so, to provide some of the same information mentioned above in relation to your children but only in so far as it is necessary to enable them to participate in the Program.

Repeat Participants: if (as we hope) you have previously enjoyed one of our Programs and have decided to book another one of our Programs we might use personal data about you that has previously been provided and held in accordance with our retention policies to help us better design your next tailor-made experience, for example, taking account of any preferences, comments or feedback previously expressed.

As a job applicant

If you apply to us for a job, your name, email address, address, contact telephone number, your CV, work history, educational details, references, HM Revenue & Customs and National Insurance numbers and other associated information, visa information (if relevant) and the role that you are applying for.

If you access our website

The personal data we collect and how we collect it, if you access our website, is described in the section “How we collect your personal data” above. Our Cookies Policy is also available at the end of this Privacy Notice.

As a supplier of services to us

If you supply services to us (for example as a tour guide, pilot or chauffeur) we might use your personal data to help us make the experience more enjoyable for the Participants in one of our Programs by taking into account your special skills and interests when you are assigned to a particular Program.

 

6. In what circumstances do we collect sensitive information?

We collect information about your health for the purposes described under the sub-heading  “Dietary, Health and Special Access Information” in Section 5 above.

We try to limit any sensitive information we collect, and unless there is any other lawful reason to use this information (such as in an emergency) we will always obtain your consent to collect it. If we have been given sensitive information concerning you by an Intermediary before we have obtained your consent to processing it we will not use the sensitive information until we have obtained your consent to do so, or we will delete it if you ask us to do so.

 

7. How we use your personal data

We will use your personal data for the following purposes and on the following grounds permitted by the data protection rules.

If you are a Participant

(i) to personalise and make the arrangements for your Program including booking your accommodation, travel, tours, visits, excursions and experiences and providing you with any special assistance (where you provide your consent) and/or

(ii) to send you any communications relevant to the Program, including any changes to your itinerary, or providing you with instructions and other details of experiences included within your Program, to send you tickets and vouchers; and to provide you with support and advice, dealing with your enquiries, scheduling changes, complaints, comments or observations shared with us.

Use of your personal data for these purposes is based on Performance of Contract (if we have a contractual relationship with you) and/or on the basis of Legitimate Interest. The meanings of “Performance of Contract” and “Legitimate Interest” are explained in Section 3 above.

If you are a job applicant

to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any advertisement), on the basis of our Legitimate Interest to recruit new employees or contractors.

In other circumstances

We may also use your personal data with your consent, for compliance with legal obligations or to establish, exercise or defend legal claims as is explained in Section 3 above.

Marketing

We may occasionally send you marketing information.

 

8. Who do we share your personal data with?

We don’t sell your personal data to third parties, but we do share your personal data with trusted third parties where this is a necessary part of arranging your Program or running our business. We do not share personal data with third parties for their own purposes.

This is our policy we adopt when sharing with third parties:

We provide only the personal data they need to perform their specific services.

They may only use your data for the exact purposes we specify in our contract with them.

We work closely with them to ensure that your privacy is respected and protected at all times.

If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.

Examples of the third parties with whom we share your personal data (but only to the extent necessary to maximize your enjoyment of the Program):

We may provide your personal data to other companies in order to run credit checks, take payment from your credit card or bank, deliver your purchases, and recover money owed to us.

We share your personal data with IT companies that support our website and other business systems and our professional advisers but only where it is necessary to provide us with advice in connection with the operation of our business; and with HM Revenue &Customs, regulators and other authorities based in the United Kingdom to the extent required by law.

We may also disclosure your personal data to the police and similar bodies, hospitals and doctors, where this is to prevent a crime, or necessary in the event of a medical emergency or when we are required to do so by law.

Finally, if we sell our business, then your personal data may be transferred to the new owner. But the new owner will be subject to the same laws concerning your personal data as we are.

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 and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

9. International transfers

We do not usually transfer your personal data outside the European Economic Area (EEA) although occasionally we may transfer your personal data to the Intermediary, for example, feedback or comments about how you enjoyed your Program or with your consent we may send the Intermediary photographs of you and other people in your Program that we may take either specifically at your request for your own enjoyment or to show to the Intermediary to show how much you are enjoying our Program.

Any transfer of personal data outside of the EEA will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.

 

10. 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, 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.

 

11. How long will we keep your personal data?

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.

 

12. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data which are set out below under “YOUR LEGAL RIGHTS”.

If you wish to exercise any of the rights set out above, please contact us at     dataprotection@noteworthy.co.uk  .

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.

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 personal data 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 personal data 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.

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 personal data which you initially provided consent for us to use or where we used the personal data to perform a contract with you.

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 the Program or other services to you. We will advise you if this is the case at the time you withdraw your consent.

 

13. Change of purpose  

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 at  dataprotection@noteworthy.co.uk  .  If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that 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.

 

14. Any questions?

We hope this Privacy Notice is helpful in explaining the way that we handle your personal data and your rights to control it.  If you have any questions or comments about how your personal data is used, please email us at:   dataprotection@noteworthy.co.uk  .You can also write to our Data Compliance Manager at Worthy International Limited, 152 Buckingham Palace Road, London, SW1W 9TR, England.

 

15. Contacting the Regulator

If you feel your personal data has not been handled properly or are unhappy about our response to any request you have made to us regarding use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office whose online contact details can be found here www.ico.org.uk/concerns .

 

16. Status of this Privacy Notice

This Privacy Notice was updated in May 2018. It is non-contractual and we reserve the right to amend it from time to time to take account of changes in law, including Britain leaving the European Union and changes in our business practices and personal data processing activities.

Copyright: Worthy International Travel Limited © 2018

 

Cookies Policy

Our website uses cookies. Cookies are small text files that are placed on your computer or mobile device when you visit our website. Our website uses both session cookies and persistent cookies. Session cookies enable you to move from page to page within our website and any information you enter to be remembered. A session cookie is deleted when you close your browser or after a short time. Persistent cookies allow our website to remember your preferences and settings when you visit our website in the future. Persistent cookies expire after a set period of time.  We use Google Analytics to provide us with information about how you use our website. We use this information to compile statistics and to help us to improve our website and the services we offer. Google uses cookies as part of this process to collect anonymous information, including the number of visitors to the website, where they have come to the website from, the pages they visit and the length of time they have spent on the website.

The use of cookies in these ways is to improve the functionality of our website and your experience when using it. Cookies can be disabled by changing the settings on your browser.  By continuing to use our website without changing your settings, you consent to our use of cookies as described above.

You can learn more about cookies at www.allaboutcookies.org and www.youronlinechoices.eu.

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