National Holidays Limited


Website Privacy Policy

Introduction

 The website www.caledoniantravel.com is a trading name of by National Holidays Limited ("we" or "us") and we are a "data controller" for the purposes of the Data Protection Act 1998 and the EU General Data Protection Regulation 2016/679. This means that we are responsible for, and control the processing of, your personal information.

This privacy policy relates to your use of our website.

We take your privacy very seriously and we ask that you read this Policy carefully as it contains important information on:

 • the personal information we collect about you;

 • what we do with your information; and

 • who your information might be shared with.

How we use your information

We will collect your personal information for the following purposes:

a) To identify you and manage any accounts you hold with us – we will use your information so we can store customer records that allow us to identify you when you request products and services from us.

b) To process your booking – we will use your information to fulfill the services you request or purchase from us. This includes booking your holiday (with appropriate flights, transport, hotel etc) and issuing you with your tickets. When booking with us, some sensitive personal information may be collected – please see the ‘Information which we may collect’ section for more details.

c) To send you service and support communications – we will use your information to send any communications relevant to the products and services purchased from us. This may include emails to confirm your booking, customer service emails, information about any changes to your booking and review emails from our third party review aggregator, Feefo.

d) To process any brochure requests submitted via the website or over the phone – we will use your information to send out the relevant brochures, via our fulfillment house

e) To personalise your customer experience - we use your information to provide you with a more personalized service. For example tailoring the communications we can to you, or serving you with advertising that we think you will be interested in.

f) to provide assistance with online bookings – we collect your information when you will in the require fields on our website forms in order to offer assistance in case you are experiencing difficulties with our website (where we have your consent to do so)

g) to conduct research, statistical analysis and behavioural analysis – we may use your information to carry out research about engagement and interaction with our services and products. We may also ask you to participate in customer surveys and customer focus groups occasionally. We also may analyse the information we hold to profile our customer database.

h) if you agree, let you know about other products or services that may be of interest to you—see 'Marketing’ section below;

i) Notify you of any changes to our website or to our services that may affect you – we will notify you of any changes that are relevant to the services and purchases you have with us, for example changes to online account settings, preference captures and policy updates.

j) Carry out security vetting – we may use your information to ensure the security of our services and ensure we are protecting you and the business against fraud, unauthorized or illegal activities, systems testing, maintenance and development.

k) Improve our product and services, both online and offline – we may record and monitor calls for the purposes of improving our customer service, ensuring quality, for training purposes and for general business purposes.

l) Resolving complaints and dealing with any disputes – we will use your information and store records of customer complaints and communication with you for our business records.

Marketing

We may periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided.

From time to time, we may also use your information to contact you for market research purposes. We may contact you by email, phone, fax or mail. We may use the information to customise the website according to your interests.

We will only send you marketing messages when you tick the relevant boxes when you provide us with your personal information, and you can opt out at any time. To out of email communications, please use the link on our emails. To opt out of postal communications, please contact our customer services team. Please see 'The right to ask us to stop contacting you with direct marketing' below for further information.

Information which we may collect

We collect personal information about you when you register with us, book with us, contact us or when you submit a response to an online questionnaire on our website.

We may collect the following personal information:

a) full name;

b) postal address;

c) email address; and

d) telephone numbers;

e) Date of birth

f) Loyalty membership details/p>

g) Dietary requirements – this is only collected if you make a booking with us

h) Disability information – this is only collected if you make a booking with us

i) Special request / room requirements – this is only collected if you make a booking with us

j) Next of kin details – this is only collected if you make a booking

k) Insurance details – this is only collected if you make a booking and do not take out a policy with us

l) Passport details - this is only collected if you make a booking with us


[Please note that we do not collect any information in relation to your payment information, such as credit/debit card details.]

How long we will keep your personal information

We shall retain your information for 7 years after your booking date (bookers) and 3 years after your enquiry date (enquiries), unless we are required by law to retain your personal information for a longer period.

Our approach to information security

To protect your information, National Holidays Limited has policies and procedures in place to make sure that only authorised personnel can access the information, that information is handled and stored in a secure and sensible manner and all systems that can access the information have the necessary security measures in place. To accomplish this, all employees, contractors and sub-contractors have roles and responsibilities defined in those policies and procedures.

To make sure all employees, contractors and sub¬contractors understand these responsibilities they are provided with the necessary training and resources they need.

In addition to these operational measures, we also use a range of technologies and security systems to reinforce the policies.

To make sure that these measures are suitable, vulnerability tests are run regularly. Audits to identify areas of weakness and non-compliance are routinely scheduled. Additionally, all areas of the organisation are constantly monitored and measured to identify problems and issues before they arise.

Transfers of your information out of the EEA

We may need to transfer your personal data to relevant airlines, hotels, tour companies which are located outside the European Economic Area, for the purpose of fulfilling your holiday booking and related services with us. For example, to allow us to organise elements of your holiday including transfers, flights, insurance etc. Any transfer of your data will be subject to a European Commission approved contract that will safeguard your privacy rights and give you remedies in the unlikely event of a security breach.

Your rights

In order to process any of the requests listed below, we may need to verify your identity for your security. In such cases your response will be necessary for you to exercise this right.


The right to access information we hold about you

At any point you can contact us to request that the information we hold about you as well as why we have that information, who has access to the information and where we got the information. Once we have received your request we will respond within 30 days.

The right to correct and update the information we hold about you

If the data we hold about you is out of date, incomplete or incorrect, you can inform us and we will ensure that it is updated.

The right to have your information erased

If you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.

The right to object to processing of your data

You have the right to request that [Company] Limited stops processing your data. Upon receiving the request, we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue. If data is no longer processed, we may continue to hold your data to comply with your other rights.

The right to ask us to stop contacting you with direct marketing

You have the right to request that we stop contacting you with direct marketing. In order to process your request we may need to verify your identity for your security.

The right to data portability

You have the right to request that we transfer your data to another controller. Once we have received your request, we will comply where it is feasible to do so.

Consent

In those cases where we need your consent to hold your information, we will ask you to check a box on any form requiring consent. By checking these boxes you are stating that you have been informed as to why [Company] Limited is collecting the information, how it will be used, for how long it will be kept, who else will have access to it and what your rights are as a data subject.

Sharing your information

Where necessary to fulfil our obligations to you, National Holidays Limited may pass your details to third parties where this is necessary for the functioning of our product. These third parties include:

a) Members of the Shearings Leisure Group

b) Prospective buyers of our business or assets, which may include your personal information

c) Amazon Web Services

All of your personal information will be stored in a secure central database in the “cloud” (on Amazon AWS virtual servers) and transmitted securely across networks. This information will be accessible only to those who are authorised to view it. For any one user, this will include administrators working for National Holidays Limited, and it may also include one or more administrators who work for the company which employs the end user and who has been pre-authorised to access the data. This means that users who have the permissions will be able to see the information you have provided such as your personal details and records of any existing medical conditions.

d) Google

We work with third party company Google to automatically collect information including: IP address; MAC (Media Access Control) address; unique identifier or other persistent or non persistent device identifier; device software platform and firmware, mobile phone carrier and geo location data to help us understand your use of our app such as how often you return, what parts of the app you visit, how you use the app and how long you spend on the app. This third party provider is prohibited from using our data for any other purposes. Go to http://www.google.com/analytics/terms/us.html to read Google Analytics Privacy Policy. We use the data we collect about your use of our website to analyse trends across the data set of all customers worldwide, and to enable us to offer a better service to you.

e) Fulfillment & Distribution Houses

f) Travel Agencies

 

g) External development companies (Roville, Travelink)

We do not share your personal information with third parties for them to use for marketing purposes or their own purposes.

Cookies and Tracking

Use of cookies

A cookie is a small text file which is placed onto your computer (or other electronic device) when you access our website. We use cookies on this website to:

a) recognise you whenever you visit this website (this speeds up your access to the website as you do not have to log in each time);

b) obtain information about your device, browsing preferences, online movements and use of the internet;

c) carry out research and statistical analysis to help improve our content, products and services and to help us better understand our customer requirements and interests;

d) target our marketing and advertising campaigns more effectively by providing interest-based advertisements that are personalised to your interests; and make your online experience more efficient and enjoyable

e) identify if you have engaged with us on social media, so we have respon to any comments and queries you have.

f) website tracking purposes and,

g) Site management and security purposes such as troubleshooting and testing.

In most cases we will need your consent in order to use cookies on this website. The exception is where the cookie is essential in order for us to provide you with a product or service you have requested.

Consent

There is a notice on our home page which describes how we use cookies and which also provides a link to our website privacy policy. If you use this website after this notification has been displayed to you, we will assume that you consent to our use of cookies for the purposes described in this website cookie policy and our website privacy policy.

Description of cookies

Cookie Name: Homepage - What it does: Captures users cookie for retargeting purposes -Why is it used: To ensure we can retarget users who have failed to convert with Display banners - How long it lasts: 180 days


Cookie Name: Homepage -What it does: Captures users cookie for retargeting purposes - Why is it used:to ensure we can retarget users who have failed to convert with Display banners - How long it lasts: 180 days

Cookie Name: All Pages - What it does: Captures users cookie for retargeting purposes -Why is it used: to ensure we can retarget users who have failed to convert with Display banners - How long it lasts: 180 days

Cookie Name: Conversion Page -What it does: Associates cookie with conversion - Why is it used: to track online conversions (sales and revenue)- How long it lasts: 180 days

Cookie Name: PPC Call -What it does: Captures Cookies for call tracking purposes - Why is it used: This allows us to report on the number of phone calls from online activity -How long it lasts: 30 Days

Cookie Name: Booking -What it does: Captures users Cookie at the point of purchase -Why is it used: This allows us to report on sales that take place on our websites -How long it lasts: 30 Days

Cookie Name: Doubleclick -What it does: - Doubleclick is Google’s real time bidding advertising exchange. These cookies support the delivery, targeting & measurement of ads, ensuring that you can see relevant & informative advertising. Why is it used: To provide effective and reliable tracking and measurement of advertising. - How long it lasts: Variable.

Cookie Name: VWO -What it does: Collects information about types of users coming to a website (new/ returning) and whether or not they should be exposed to website testing. -Why is it used: To deliver testing and variants to web pages with effective tracking and measurement analytics - How long it lasts: 90 days

Cookie Name: Facebook -What it does: When people interact with Facebook via our website, for example clicking ‘like’ buttons, this cookie collects data on this engagement, which it might use to target people with advertising when using its services or where it advertises on other websites. -Why is it used: Uses data to target people with relevant advertising.

How to turn off cookies

If you do not want to accept cookies, you can change your browser settings so that cookies are not accepted. If you do this, please be aware that you may lose some of the functionality of this website. For further information about cookies and how to disable them please go to the Information Commissioner’s webpage on cookies: https://ico.org.uk/for-the-public/online/cookies/.

Enquiries

When contacted with an enquiry, National Holidays Limited will hold the entity name and contact details only for the purposes of handling the enquiry.

The online forms are subject to the same cookies and tracking as the rest of the website (see the above section “Cookies and Tracking” for more information).

Right to Complain

You can make a complaint to us by contacting us via email to DPO@shearings.com or to the data protection supervisory authority – in the UK, this is the Information Commissioner's Office, at https://ico.org.uk/.

Contact details

If you have any queries about this Policy, need further information or wish to lodge a complaint you can use the details below to contact the relevant party.

Mark Williams - Data Protection Officer

Waterside House
Waterside Drive
Wigan Pier Business Park
Wigan
WN3 5AZ

DPO@shearings.com

Changes to this Privacy Policy

We may change this Policy from time to time. You should check this policy occasionally to ensure that you are aware of the most recent version that will apply each time you access the website.