Introduction

1. We are committed to safeguarding the privacy of our website visitors, service users, individual customers and customer personnel.
2. This policy applies where we are acting as a data controller with respect to the personal data of such persons; in other words, where we determine the purposes and means of the processing of that personal data.
3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
4. In this policy, “we”, “us” and “our” refer to Travlotickets Limited.

The personal data that we collect

1. In this Section, we have set out the general categories of personal data that we process and, in the case of personal data that we did not obtain directly from you, information about the source and specific categories of that data.
2. We may process data enabling us to get in touch with you (“contact data”). The contact data may include your name, email address, telephone number, postal address and/or social media account identifiers. The source of the contact data is you and/or your employer. If you log into our website using a social media account, we will obtain elements of the contact data from the relevant social media account provider.
3. We may process your website user account data (“account data”). The account data may include your account identifier, name, email address, business name, account creation and modification dates, website settings and marketing preferences. The primary source of the account data is you and/or your employer, although some elements of the account data may be generated by our website. If you log into our website using a social media account, we will obtain elements of the account data from the relevant social media account provider.
4. We may process information relating to transactions, including purchases of goods and/or services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details, your payment card details (or other payment details) and the transaction details. The source of the transaction data is you and/or our payment services provider.
5. We may process information contained in or relating to any communication that you send to us or that we send to you (“communication data”). The communication data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms.
6. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system.
7. In some cases we may also need to collect more sensitive data such as medical information and details of any special requirements, or dietary information to ensure your booking is delivered to meet your needs.

1. Relationships and communications

2. We may process contact data, account data, transaction data and/or communication data for the purposes of managing our relationships, communicating with you (excluding communicating for the purposes of direct marketing) by email, SMS, post, fax and/or telephone, providing support services and complaint handling. The legal basis for this processing is our legitimate interests, namely communications with our website visitors, service users, individual customers and customer personnel, the maintenance of relationships, and the proper administration of our website, services and business.

3. Direct marketing

4. We may process contact data, account data and/or transaction data for the purposes of creating, targeting and sending direct marketing communications by email, SMS, post and/or fax and making contact by telephone for marketing-related purposes. The legal basis for this processing is consent OR our legitimate interests, namely promoting our business and communicating marketing messages and offers to our website visitors and service users. You can unsubscribe from marketing emails at any time by clicking on the unsubscribe link in a marketing email you have received from us.
   Please note you will always receive emails and/or text messages or phone calls related to any bookings with us.

5. Research and analysis

6. We may process usage data and/or transaction data for the purposes of researching and analyzing the use of our website and services, as well as researching and analyzing other interactions with our business. The legal basis for this processing is consent OR our legitimate interests, namely monitoring, supporting, improving and securing our website, services and business generally.

7. Record keeping

8. We may process your personal data for the purposes of creating and maintaining our databases, back-up copies of our databases and our business records generally. The legal basis for this processing is our legitimate interests, namely ensuring that we have access to all the information we need to run our business properly and efficiently in accordance with this policy.

9. Security

10. We may process your personal data for the purposes of security and the prevention of fraud and other criminal activity. The legal basis of this processing is our legitimate interests, namely the protection of our website, services and business, and the protection of others.

11. Insurance and risk management

12. We may process your personal data where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks and/or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

13. Legal claims

14. We may process your personal data where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

15. Legal compliance and vital interests

16. We may also process your personal data where such processing is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.

Providing your personal data to others

1. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice.
2. Your personal data held in our website database will be stored on the servers of our hosting services providers.
3. We may disclose you name, email address, telephone number, postal address to our suppliers or subcontractors insofar as reasonably necessary for the completion of the services requested by you. We need to share details for all passengers on the booking with the airline, hotelier or any other supplier we are buying your requested service from. This will include personal information for all passengers such as title, name, date of birth and sometimes passport information including nationality (for Advanced Passenger Information purposes). It will also include more sensitive data such as medical information and details of any special requirements, or dietary information however; we will only share information that is relevant and necessary to fulfil your booking.
4. We may also be required by law to share your information with certain government organizations such as customs or immigration authorities, the police or other legal bodies if a valid legal request has been received.

Retaining and deleting personal data

1. This Section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain your personal data as follows:
   
   1. contact data will be retained for a minimum period of 6 months following the date of the most recent contact between you and us, and for a maximum period of 12 months following that date;
   2. account data will be retained for a minimum period of 6 months following the date of closure of the relevant account, and for a maximum period of 12 months following that date;
   3. transaction data will be retained for a minimum period of 6 months following the date of the transaction, and for a maximum period of 12 months following that date;
   4. communication data will be retained for a minimum period of 12 months following the date of the communication in question, and for a maximum period of 24 months following that date;
   5. usage data will be retained for 6 months following the date of collection.
4. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. All information will be stored on our own secure servers and systems to help us handle your booking. Your information will be backed up on to secondary servers and eventually tape backup. We will take reasonable technical and organizational precautions to prevent the loss, misuse or alteration of your personal information. All electronic transactions you make to or receive from us will be encrypted using SSL (Secure Socket Layer) technology. Of course, data transmission over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.