21 June 2019
2. Who We Are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
• Our site address is www.streamline-travel.com
• Our company name is Streamline Travel Ltd
• Our registered address is 10-12 Lumina Way, Rainbow House, Enfield EN1 1FS, United Kingdom
• Our nominated data protection representative can be contacted at firstname.lastname@example.org
3. What we may collect
We may collect and process the following data about you:
• Identity Data including first name, last name, username or similar identifier.
• Contact Data including address, email address and telephone numbers.
• Financial Data including billing address, bank account and payment card details.
• Transactions Data including check in- check out dates, travel dates, date of birth, passport number, airline membership numbers, hotel membership numbers and details of any products or services that you bought from us or sold to us.
• Technical Data including the IP addresses, browser type, language preference, referring site, and the date and time of each visitor request, to better understand how visitors use our site. From time to time we may, for example, release aggregate non-personally-identifying information by publishing a report on trends in the usage of our site. We do not use information on IP addresses and similar to identify our visitors and we only use it for aggregated statistics. We may collect statistics about the behavior of visitors to our site. For instance, we may monitor the most popular pages.
• Marketing and Communications Data including your preferences in receiving marketing from us and your communication preferences.
• We may also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity.
• We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
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5. How we use what we collect
We use information about you to:
• Present our site content effectively to you.
• Provide information, products and services that you request, or (with your consent) which we think may interest you.
• Carry out our contracts with you.
• Tell you our charges.
If you are already our customer, we will only contact you electronically about things similar to what was previously sold to you. If you are a new customer, you will only be contacted if you agree to it. If you don’t want to be contacted for marketing purposes, please contact us via the unsubscribe link that you may find within our marketing emails, or by contacting us at email@example.com. Please note: We don’t identify individuals to our advertisers, but we do give them aggregate information to help them reach their target audience, and we may use information we have collected to display advertisements to that audience. In addition, if you don’t want us to use your personal data for any of the other reasons set out in this section in 5, you can let us know at any time by contacting us at firstname.lastname@example.org, and we will delete your data from our systems. However, you acknowledge this will limit our ability to provide our services to you. In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the services we can provide you if you don’t provide your personal data in these cases.
6. Where we store your data
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and deal with payment. By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure and we have security measures in place, including the use of usernames and passwords. Whenever we transfer your personal data out of the EEA, we will ensure that there is a similar degree of protection as applies within the EEA but having at least one of the following safeguards in place:
• Transferring to a country that has an adequate level of protection as approved by the European Commission;
• Where we use services providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield scheme. If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our efforts. We only keep your personal data for as long as we need to in order to use it as described above in section 5, and/or for as long as we have your permission to keep it. In any event, we will conduct regular reviews to ascertain whether we need to keep your personal data and our usual retention period is 18 months. Your personal data will be deleted if we no longer need it.
7. Disclosing your information
We are allowed to disclose your information in the following cases:
• If we want to sell our business, or our company, we can disclose it to the potential buyer.
• We can disclose it to other businesses in our group.
• We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
• We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, banking, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
Sage; Worldpay – processing of payments
HSBC – banking
Travel Agency Suppliers and Partners – assistance in the provision of our services, hotel and flight information Amadeus; Galileo; Sabre – systems that assist us in providing our services Where any of your data is required for such a purpose, we will only disclose the data that is needed to be disclosed for the performance of our contract with you, a legitimate interest or another lawful basis, take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
8. Your rights
You can ask us not to use your data for marketing. You can do this by ticking the relevant boxes on our forms, or by contacting us at any time at email@example.com. Under the GDPR, you have the right to:
• request access to, deletion of or correction of, your personal data held by us at no cost to you;
• request that your personal data be transferred to another person (data portability);
• be informed of what data processing is taking place;
• restrict processing;
• to object to processing of your personal data; and
• complain to a supervisory authority.
9. Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
10. Automated Decision-Making and Profiling
We do not undertake any automated decision-making, including profiling.