What is the purpose of this policy?
What is our role in relation to your personal data?
For the purposes of data protection laws, we, Adventure Travel Networking Limited, are a data controller in respect of the personal data you provide us with.
What is my personal data and what do you mean by process?
When we refer to personal data, we mean any information which relates to an identified or identifiable individual. Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties and erasing it.
What personal data will we collect from you and why?
In order to respond to an enquiry, provide a quote, administer and fulfil your booking or send you any promotional material, we need to process personal data we obtain from you. Where you wish to make a booking, the personal data we need to collect and process at various stages is likely to include;
name and job titles of the delegates and the main contact at the company
contact details for the delegates including their work e-mail and postal addresses and telephone number(s)
if different to the delegates or main point of contact at the company, the point of contact for financial arrangements / payments including their e-mail and postal addresses and telephone number(s)
special dietary information
information in respect of any medical condition, disability or reduced mobility which may affect any delegate’s ability to attend the event – this comes within special categories of personal data (see below)
For an enquiry, the personal data we will need to process is likely to include the name and contact details of the person making the enquiry.
For a booking or booking enquiry, we will process your personal data (other than any data which comes within special categories of personal data - see below) on the basis that this is necessary for the performance of your contract with us or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency situation).
If you wish to receive promotional material from us, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address.
We do not use any personal information for marketing purposes other than the names and applicable contact details of the person who has consented to receive such material.
What are special categories of personal data?
Personal data which concerns your health or which reveals your racial or ethnic origin or your sexual orientation are special categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the booking and provision of travel arrangements.
Generally speaking, the processing of special categories of personal data requires the explicit consent of the person concerned.
Accordingly, information concerning any disability, medical condition, restricted mobility or other health related issue (and related requirements) as well as dietary restrictions which disclose your religious beliefs or any health issue are special categories of personal data. We will ask for your consent to our processing this information at the time you make your booking or your booking enquiry or whenever you otherwise provide or indicate that you intend to provide such information. This consent should be provided to us by the party leader on behalf of the person concerned who must authorise the party leader to do so.
Who may we provide your personal data to?
Where you make a booking, appropriate personal data may be passed on to suppliers and other third parties, which are likely to include the following;-
venues where events are due to take place
other delegates or companies who are due to attend the event
caterers in relation to dietary information
credit card companies / banks in respect of payments
You may be asked to input personal data onto a third party platform, for example to book appointments with other companies or to make payments.
The information may also be provided to government / public authorities if required by them, or as required by law.
We may also make personal data available to other companies who provide services on our behalf, such as mailing marketing material.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does notcollect any personal data from you in the course performing their services.
Where will we process your personal data?
Your personal data may be processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein.
We may also process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Can we use your personal data to send you information about our events in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so or, in relation to e-mail marketing, where we comply with the Privacy and Electronic Communications Regulations 2003 (PECR). PECR permits us to send you e-mail marketing where you have previously provided us with your e-mail address in the course of entering into a contract with us for tour arrangements or negotiations for such arrangements and we wish to e-mail you marketing material about our similar services or products. You will of course be given the opportunity to opt out of receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send you any e-mail marketing.
You may provide your consent to receiving marketing material from us either on-line or by telephone. You may also choose in what ways you are happy to receive communications from us. You may, for example, be happy to receive information and offers by post and e-mail but not by telephone.
Can you withdraw your consent to our processing your personal data?
Yes, you can withdraw your consent to receiving marketing material or other communications from us at any time, either generally or in any particular way, by e-mailing us at email@example.com. Alternatively you can telephone us.
How can you find out what information we are holding about you?
You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within 1 month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.
What should you do if the personal data we are holding is inaccurate, out of date or incomplete?
If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within 3 months if the rectification request is complex.
How long can we retain and process your personal data?
We will not process your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose. We will retain your personal data for what we consider to be a reasonable period of time.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
Can you ask us to delete your personal data?
Yes, you can ask us to erase your personal data in certain circumstances, for example where you have withdrawn your consent to further marketing material where the data in question has only been processed for this purpose. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.
What should I do if I have a complaint about the processing of my personal data?
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to firstname.lastname@example.org. We will investigate and respond to you as soon as we reasonably can. If you remain dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see www.ico.org.uk
What are our contact details?
You can contact us here:
Adventure Travel Networking Ltd
51A Percy Road
Telephone: 44 (0)7775 754 615
© Copyright 2018 MB Solicitors Limited trading as mb LAW of Studio 3, The Quays, Concordia Street, Leeds LS1 4ES
tel +44 (0) 113 2424444 www.mb-law.co.uk Ref: CGI