Scout My Holidays PRIVACY POLICY & COOKIE INFORMATION


We are dedicated to protecting the privacy of our website visitors and service users; this policy explains how we will handle your personal information. By using our website and accepting this policy, you consent to our use of cookies as outlined in this policy.

Our website includes privacy settings that affect how we will handle your personal information. Using the privacy settings, you can specify whether you wish to receive direct marketing communications and restrict the dissemination of your information. Contact our Marketing Team to obtain access to the privacy controls.



1. HOW WE USE YOUR PERSONAL DATA


In this Section, we describe;


the general categories of personal data that we may process; in the case of personal data that we did not obtain directly from you, the source and specific categories of that data; the purposes for which personal data may be processed; and the legal bases for processing.

We may process data by recording both incoming and outgoing telephone calls. The data on these calls may be processed for quality assurance and training purposes, as well as to aid in the resolution of any disputes. The legal basis for this processing is our legitimate interest in monitoring and improving our services and protecting and asserting our legal rights, your legal rights, and the legal rights of others under the Limitations Act 1980.

We may process information regarding your visit to our website and use of our services ("usage data"). The usage data may contain your IP address, geographic location, browser type and version, operating system, referring source, length of visit, page views, and website navigation paths, as well as details about the timing, frequency, and pattern of your service use. Our analytics tracking system provides the usage information. This data may be processed for the purpose of analysing how the website and its services are utilised. This processing is based on our legitimate interests, which include monitoring and improving our website and services.

We may manage your account information ("account data"). Included in the account information may be your name and email address. You are the source of the account data. The account data may be processed in order to operate our website, provide our services, ensure the security of our website and services, create backups of our databases, and communicate with you. Consent is the legal basis for this processing.

We may use the details contained in your personal profile on our website ("profile data"). The profile information may include your name, address, phone number, email address, profile pictures, gender, date of birth, marital status, interests and hobbies, educational information, and employment information. The profile information may be processed to enable and track your use of our website and services. The legal basis for this processing is consent, specifically the performance of a contract between you and us or, at your request, taking steps to enter into such a contract.

We may process information contained in any inquiry you submit pertaining to our products and/or services ("enquiry data"). The enquiry data may be processed in order to offer, market, and/or sell you relevant products and/or services. The legal justification for this processing is your consent.

We may process data relating to transactions, such as purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). Your contact information and the transaction details may be included in the transaction data. The transaction data may be processed in order to provide the purchased goods and services and maintain accurate records of the transactions. The legal basis for this processing is the performance of a contract between you and us or, at your request, taking steps to enter into such a contract with a supplier, as well as our legitimate interests, namely our interest in the efficient administration of our website and business.

We may process the data you submit to subscribe to our email notifications and/or newsletters ("notification data"). The notification data may be processed to send you the appropriate notifications and/or newsletters. Consent and the performance of a contract between you and us, or taking steps, at your request, to enter into a contract, are the legal bases for this processing.

We might process data contained in or relating to any communication you send to us ("correspondence data"). The correspondence data may contain both the communication content and any associated metadata. Our website will generate the metadata associated with communications made via contact form submissions. The correspondence data may be processed in order to communicate with you and maintain records. This processing is based on our legitimate interests, namely the proper administration of our website and business, as well as our communications with users.

We may process any of your personal data identified in other sections of this policy if necessary for the establishment, exercise, or defence of legal claims, whether in court proceedings or administrative or out-of-court proceedings. The legal basis for this processing is the protection and assertion of our legal rights, your legal rights, and the legal rights of others in accordance with the Limitations Act of 1980.

In addition to the specific purposes outlined in this section for which we may process your personal data, we may also process any of your personal data if such processing is required for compliance with a legal obligation to which we are subject.

Please do not provide us with the personal information of any other person unless we specifically request it.



2. WHEN WE PROVIDE YOUR PERSONAL DATA TO OTHERS


We may share your personal information with any member of our group of companies, which includes our subsidiaries, our ultimate holding company, and all of its subsidiaries, insofar as it is reasonably necessary for the purposes outlined in this policy.

We may disclose your personal information to our insurers and/or professional advisers to the extent necessary to obtain and maintain insurance coverage, manage risks, obtain professional advice, and resolve legal disputes. We may disclose your passengers' names, ages, and booking itinerary to suppliers and subcontractors to the extent reasonably required for the performance of the travel contract.

Our payment service providers, Worldpay and Barclaycard Merchant Services, manage all financial transactions associated with our website and services. We will only share transaction data with our payment services providers to the extent necessary for the purposes of processing your payments, issuing refunds for such payments, and addressing complaints and questions relating to such payments and refunds. Access information regarding the privacy policies and procedures of Worldpay and Barclaycard Merchant Services by clicking here.

In addition to the specific disclosures of personal data described in this Section 3, we may also disclose your personal data if required to do so by law or to protect your vital interests or the vital interests of another natural person.



3. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA


In this Section, we explain the conditions under which your personal data may be transferred to countries outside the European Economic Area (EEA)].

Our website's hosting facilities are located in the United Kingdom, making them part of the EEA and subject to GDPR EU 2016/679. Suppliers of lodging, tours, and transfers are located in the United States, Africa, Australia, Egypt, and Asia. Countries outside the European Economic Area (EEA) do not always provide the same level of protection for your personal data; therefore, European law prohibits transfers of personal data outside the EEA unless certain conditions are met.

Some of our third-party service providers are located outside of the European Economic Area (EEA), so their processing of your personal information will involve a transfer of data outside of the EEA.

Whenever we transfer your personal information outside the EEA, we do our best to ensure a comparable level of data security by implementing at least one of the following safeguards:

We will only transfer your personal information to countries deemed by the European Commission to provide an adequate level of protection for personal information; or

When employing certain service providers, we may use specific contracts, codes of conduct, or certification mechanisms approved by the European Commission to provide the same level of protection for personal data as in Europe; or

If we use US-based providers who participate in the EU-US Privacy Shield, we may transfer data to them, as they have in place equivalent protections.

In the absence of any of the aforementioned safeguards, we may request your explicit consent for the specific transfer. You will be able to revoke this consent at any time.



4. RETAINING AND DELETING PERSONAL DATA


This Section 5 outlines our data retention policies and procedures, which are intended to assist us in meeting our legal obligations regarding the retention and deletion of personal data.

Personal information that we process for a particular purpose or purposes shall not be stored for longer than is required for that purpose or those purposes.

We will retain and delete your personal information as outlined below:

(a) All information collected at the time of booking will be kept for 36 months after the return date of your trip, after which it will be deleted from our internal system unless you make future reservations with us. Your information will be deleted 36 months after your last trip with us.

We may retain your personal data notwithstanding the other provisions of this Section 5 if doing so is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.



5. AMENDMENTS


This policy may be updated periodically by publishing a new version on our website.

You should periodically check this page to ensure you're happy with any policy changes.



6. YOUR GENERAL RIGHTS


You may instruct us to provide you with any personal information we hold about you; provision of such information is subject to: (a) the provision of appropriate evidence of your identity for this purpose, we will typically accept an email from the lead passenger via the email address provided at the time of booking or a letter sent via regular mail.

We may withhold requested personal information to the extent permitted by law.

You may at any time instruct us not to use your personal data for marketing purposes.

In practise, you will either expressly consent to our use of your personal information for marketing purposes in advance, or we will provide you with an opportunity to opt out of such use.



7. YOUR LEGAL RIGHTS


In this section, we have outlined your rights under the data protection law. Some of the rights are intricate, and we have not included every detail in our summaries. For a comprehensive explanation of these rights, you should consult the applicable laws and regulatory authorities' guidance.

Your primary rights under the data protection law are as follows:

the right of access,

the right of rectification,

the right of erasure,

the right to restrict processing,

the right to data portability,

the right to lodge a complaint with a supervisory authority, and

the right to withdraw consent.

You have the right to obtain confirmation as to whether or not we process your personal data and, if we do, access to those data along with certain additional details. This additional information includes specifics regarding the processing's purposes, the categories of personal data involved, and the recipients of the personal data. If the rights and liberties of others are not compromised, we will provide you with a copy of your personal information. We will not assess fees for subject access requests unless they are deemed to be "excessive" (e.g. repetitive). You should receive a response within 30 days of our receiving your request. You can access your personal information by sending an email to our Data Privacy Manager.

You have the right to have inaccurate personal data about you rectified and incomplete personal data about you completed, taking into account the purposes of the processing.

In certain situations, you have the right to the prompt erasure of your personal information. The personal data are no longer required in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. There are, however, general exceptions to the right to erasure. These general exclusions include situations where processing is required for the purposes of exercising the right to freedom of expression and information, complying with a legal obligation, or establishing, exercising, or defending legal claims.

You have the right to restrict the processing of your personal data under certain conditions. You contest the accuracy of the personal data; the processing is unlawful, but you oppose erasure; we no longer require the personal data for the purposes of our processing, but you require the personal data for the establishment, exercise, or defence of legal claims; and you have objected to processing pending the verification of that objection. We may continue to store your personal data where processing has been restricted on this ground. However, we will only otherwise process it with your consent, to establish, exercise, or defend legal claims, to protect the rights of another natural or legal person, or for important reasons of public interest.

You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or the purposes of the legitimate interests pursued by us or a third party. If you object, we will cease processing the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms, or the processing is for the establishment, exercise, or defence of legal claims.

You may object to our use of your personal information for direct marketing purposes (including profiling for direct marketing purposes). If you object, we will cease processing your personal information for this purpose.

You have the right to receive your personal data from us in a structured, commonly used, and machine-readable format to the extent that the legal basis for our processing of your personal data is consent and such processing is carried out by automated means. However, this right does not apply in situations where it would violate the rights and liberties of others.

If you believe that our processing of your personal information violates data protection laws, you have the legal right to file a complaint with the Information Commissioner's Office (ICO), the UK supervisory authority for data protection.

To the extent that consent is the legal basis for our processing of your personal information, you may at any time withdraw your consent. The withdrawal will not affect the legality of processing that occurred prior to the withdrawal.

You may exercise any of your rights regarding your personal data by providing us with written notice.



8. ABOUT COOKIES


A cookie is a file sent by a web server to a web browser that contains an identifier (a string of letters and numbers) and is stored by the browser. When the browser requests a page from the server, the identifier is sent back to the server.

Cookies can either be "persistent" or "session" cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiration date, unless the user deletes it prior to its expiration date; a session cookie will expire at the end of the user session, when the web browser is closed.

Cookies typically do not contain any information that personally identifies a user, but we may link personal information that we store about you to information stored in and obtained from cookies.



9. COOKIES THAT WE USE


We use cookies for the purposes outlined below :

Authentication - cookies are used to identify you when you visit and navigate our website.

Status - we use cookies to determine if you are currently logged into our website.

We use cookies to store information about your preferences and personalise the website for you.

Cookies are used as part of our security measures to protect user accounts, including preventing fraudulent use of login credentials, as well as our website and services in general.

Analysis - cookies assist us in analysing the performance and usage of our website and services.

Cookie consent - we store your preferences regarding the use of cookies in general using cookies

COOKIES USED BY OUR SERVICE PROVIDERS

When you visit our website, cookies from our service providers may be stored on your computer.

Google Analytics is utilised to analyse the usage of our website. Google Analytics collects information regarding website usage through cookies. The information gathered about our website is used to generate reports about its utilisation. Visit the official Google Analytics page for more information on Google Analytics cookies.

Our website contains Google AdSense advertisements. Google will use cookies to track your behaviour on our website and other websites across the web in order to determine your interests. This tracking enables Google to tailor advertisements you see on other websites to your specific interests (but we do not publish interest-based advertisements on our website). By visiting https://adssettings.google.com , you can view, remove, or add interest categories associated with your browser. You can also opt out of the AdSense partner network cookie using these settings or by visiting http://optout.networkadvertising.org and using the Network Advertising Initiative's multi-cookie opt-out mechanism. However, these opt-out mechanisms rely on cookies, and if you delete cookies from your browser, your opt-out preference will be lost. Consider using the Google browser plug-ins available at https://support.google.com/ads/answer/7395996 to ensure that an opt-out is maintained for a specific browser.



10. MANAGING COOKIES


The majority of browsers allow you to reject and delete cookies. The methods for achieving this vary by browser and version. The following links provide up-to-date information about blocking and deleting cookies:


Crome, Firefox, Opera, Internet Explorer, Safari for Mac, Safari for iphone and ipad,and Edge

Numerous websites' usability will suffer if all cookies are blocked.

If you block cookies, you will not be able to utilise all of our website's features.


11. DATA PRIVACY MANAGER


Our data privacy manager’s contact details are : dataprivacy@scoutmyholidays.com