The Travel Vault Privacy Policy

The Travel Vault Limited respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after the personal data that you provide to us when you apply to be a member of The Travel Vault Membership Scheme and tells you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION

2. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

3. PURPOSES FOR WHICH WE USE PERSONAL DATA

4. DISCLOSURES OF PERSONAL DATA

5. DATA SECURITY

6. DATA RETENTION

7. INDIVIDUAL LEGAL RIGHTS

1. IMPORTANT INFORMATION

PURPOSE OF THIS PRIVACY POLICY

This privacy notice aims to give information on how The Travel Vault collects and processes any personal data that is provided to us when a travel business applies to be a member of the Travel Vault Membership Scheme, including any personal data that is provided through our online application form on our website www.thetravelvault.co.uk.

It is important that this privacy policy is read carefully together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data so that you are fully aware of how and why we are using personal data. This privacy policy supplements the other notices and is not intended to override them.

CONTROLLER

The Travel Vault Limited is the controller and responsible for any and all personal data that is provided to us (referred to as ”Travel Vault, “we”, “us” or “our” in this privacy policy). Travel Vault is registered with the Information Commissioner’s Office.

We have appointed a data protection officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your individual legal rights, please contact the data protection officer using the details set out below.

CONTACT DETAILS

Our full details are:

Data Protection Officer
The Travel Vault Limited
Albert House
256-260 Old Street
London
EC1V 9DD

Email address: info@thetravelvault.co.uk

Complaints may be made by individual data subjects 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 any concerns first, so please contact us in the first instance.

CHANGES TO THE PRIVACY NOTICE AND MEMBER’S DUTY TO INFORM US OF CHANGES

This version was last updated on 31 May 2018 and historic versions can be obtained by contacting us.

It is important that the personal data we hold is accurate and current. Members of the Scheme must keep us informed if any personal data that they have provided us with changes during their membership.

THIRD-PARTY LINKS

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 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.

2. PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

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).

Businesses who apply to become a member of The Travel Vault Membership Scheme may be asked to provide the following different kinds of personal data to us during the application process:

    Identity Data: includes first and last name, title, date of birth and gender of all directors and individual shareholders of the applicant, and key staff who will be key contacts for the applicant’s membership of the Scheme;
    Contact Data: includes email address and telephone numbers of key staff who will be key contacts for the applicant’s membership of the Scheme;
    Customer Booking Data: including customer’s name; address; bank account and payment card details; and details of services purchased from the member, either accessed by the e-Trip software provided to the member as part of the Scheme, or provided separately to Travel Vault by the member from their own back office system;
    Verification Data: includes passport details, bank statement and utility bill of individual directors of the applicant;
    Special Category Data: includes details of criminal convictions and other legal proceedings against individual directors.

All of the above personal data is required in order to allow us to assess an application for the Scheme. If the applicant fails to provide that data when requested, we may not be able to assess the application and/or offer membership as a result. We collect the personal data specified above through the applicant’s completion of the Scheme application form (either online or in paper form) or otherwise through the application process.

3. PURPOSES FOR WHICH WE WILL USE PERSONAL DATA

We will only use personal data as follows:
    - Contact Data, Identity Data, Verification Data and Special Category Data: to consider an application for the Scheme, and if successful, to provide the member with the Scheme services contracted for, including, without limitation, financial protection insurance by a third party insurance company and an ATOL licence from the Civil Aviation Authority, as further described in the Scheme documents;
    - Contact Data, Identity Data, Verification Data and Special Category Data: to comply with our legal obligations such as the need to verify identify pursuant to the Money Laundering Regulations before setting up a membership account;
    - Contact Data, Identity Data, Verification Data and Special Category Data: to protect our legitimate interests by conducting credit checks and to prevent fraud;
    - Contact Data, Identity Data, Customer Booking Data and Special Category Data: to administer the Scheme on an ongoing basis as set out in the Scheme documents, including monitoring and reporting on the member on behalf of the member’s insurance provider, the Civil Aviation Authority (as provider of the Scheme ATOL) and other regulatory authorities.
We will require an applicant to ensure individual directors, shareholders and staff providing personal data have given their explicit written consent to our use of their personal data including Special Category Data for the purposes set out above – see the consent section of the Scheme application form for further details.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any company outside Travel Vault Limited for marketing purposes. You can change your mind at any time by Contacting us.

CHANGE OF PURPOSE

We will only use 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 we need to use a person’s personal data for an unrelated purpose, we will notify them and we will explain the legal basis which allows us to do so.

Please note that we may process personal data without knowledge or consent of the data subject, in compliance with the above rules, where this is required or permitted by law.

4. DISCLOSURES OF PERSONAL DATA

We may have to share personal data with:
    • the insurance provider of the member under the Scheme for the purpose of providing and renewing financial protection and other applicable insurances;
    • the Civil Aviation Authority and other regulatory bodies concerned with the operation of the Air Travel Organiser’s Licensing scheme;
    • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of personal data and to treat it in accordance with the law.

If the provider of insurance to a member is based outside of the European Economic Area (EEA), we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission;
    • We may use specific contracts approved by the European Commission which give personal data the same protection as 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 which requires them to provide similar protection to personal data shared between the Europe and the US.
Please Contact us if you want further information on the specific mechanism used by us when transferring personal data out of the EEA.

5. DATA SECURITY

We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process 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 the data subject and any applicable regulator of a breach where we are legally required to do so.

6. DATA RETENTION

We will only retain 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 personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of personal data are available in our retention policy which you can request from us by Contacting us.

7. INDIVIDUAL’S LEGAL RIGHTS

As an individual data subject, 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 information 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 information 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 information which you initially provided consent for us to use or where we used the information 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 certain products or services to the Scheme member. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

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.