1 - Who are we and important information
This website is not intended for children and we do not knowingly collect data relating to children.
The Tartan Road Ltd,
Telephone: +44 (0)1631 402 066
Third-party links outside of our control
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 we are not responsible for their privacy statements.
2 - The personal data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
- Identity Data - this includes first name, last name, title, date of birth, gender.
- Contact Data - this includes billing address, home address, email address, telephone numbers.
- Financial Data - this includes bank account, payment card details.
- Transaction Data - this includes details about payments to and from you, and other details of products and services you have purchased from us.
- Technical Data - this includes IP address, browser type and version, location, operating system and platform, other technology on the devices you use to access this website.
- Profile Data - this includes purchases or orders made by you, your interests, preferences, feedback.
- Usage Data - this includes information about how you use our website, products and services.
- Marketing and Communications Data - this includes your preferences in receiving marketing from us and our third parties, your communication preferences.
Special categories of personal data
During our interactions, we may collect special categories of personal data about you as detailed below. This may be because you want us to have the information, or we may obtain this inadvertently as a result of a group you travel with. It may also be obtained because we need to know certain personal data about you, which is special category data, in order that we can provide you with the best possible service and/or to advise you whether a trip is suitable for you. Data relating to your health is one of the best examples of this.
E.g. If we receive a group booking from a specific religious association, we will inadvertently have information about the religious beliefs of those individuals. The same can be said for groups from political associations and trade union associations.
E.g. We are sometimes asked whether certain medication is allowed to be taken into certain jurisdictions, which discloses certain medical conditions.
Other special categories of personal data, which we may end up receiving from you include details about your:
- dietary requirements, which may include information about your religious or philosophical beliefs or any health conditions
- race or ethnicity
- sex life or your sexual orientation
- political opinions
- trade union membership
- genetic and biometric data
We collect and process the above data only where it is strictly necessary for us to do so. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to allow us to do so.
You are not under any obligation to consent to us processing your sensitive personal data.
If you consent to our use of your sensitive personal data, you will be able to withdraw that consent at any time.
If you fail to provide personal data
Where we are required by law to collect your personal data, 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service, but we will notify you if this is the case at the time.
3 - How we collect your personal data
We use different methods to collect data from and about you including:
- Directly. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Enquire about our products or services
- Purchase our products or services
- Request for our marketing materials to be sent to you
- Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
- Analytics providers [such as Google, based outside the EU]
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services [such as travel agents based inside or outside the EU]
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:
- Performance of a Contract - this 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.
- Legitimate Interest - this means the course of conducting and managing our business to enable us to give you the best service/product and the 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).
- Consent - this means we will ask your permission to send you marketing publications, including e-newsletters on an occasional basis. We will ensure that any consent requests will be prominent, unbundled from other terms and conditions, concise and easy to understand. It will require a specific and positive action to opt-in by the individual. You have the right to withdraw consent to marketing at any time by contacting us at firstname.lastname@example.org.
- Comply with a legal or regulatory obligation - this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Purposes for which we will use your personal data
We have set out below a description of all the ways we plan to use your personal data, with the legal bases we rely on to do so.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. 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 described below.
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including managing payments, fees and charges
Performance of a contract with you
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(d) Marketing & Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing & Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
- 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. You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and, in each case, you have not opted out of receiving that marketing.
- Third-party marketing: We will get your express opt-in consent before we share your personal data with any company outside The Tartan Road Ltd for marketing purposes.
- Opting out: You can ask us or third parties to stop sending you marketing messages at any time. This can be done either by following the unsubscribe link on any marketing message sent to you, or by emailing email@example.com at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, experience or other transactions.
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 email firstname.lastname@example.org.
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.
5 - Who we share your personal data with
We may have to share your personal data with the parties set out below for the purposes set out in the table in section 4 above (PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA).
- External Third Parties which includes:
- Providers based in the UK and Ireland who provide services for the holiday that is being undertaken (eg: accommodation, car hire, ferries bag transfers, taxis etc).
- Professional advisers including accountants, lawyers, bankers, auditors and insurers based in the UK.
- HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
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.
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.
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.
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.
By law, we have to keep basic information about our customers, including contact, identity, financial and transaction data for 6 years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
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.
Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:
- The right to request a copy of the personal data which we hold about you;
- The right to request that we correct any personal data if it is found to be inaccurate or out of date;
- The right to request your personal data is erased where it is no longer necessary to retain such data;
- The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
- The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable (i.e. where our processing is based on consent or is necessary for the performance of our contract with you or where we process your data by automated means);
- The right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
- The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics).
If you wish to exercise any of the rights set out above, please email email@example.com.
No fee required - with some exceptions
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 admin 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.
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.
9 - Changes to this policy and your duty to inform us of changes to your data
10 - Queries, Requests or Concerns
To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact us at firstname.lastname@example.org.
If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 0303 1231113 or via email or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.
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