Caledonian Leisure LTD

This privacy policy relates to your use of our website www.caledonian.com

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.

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;

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) payment information; and

m) passport details - this is only collected if you make a booking with us.

Please note that when you make a booking on behalf of others (e.g. members of your family, including children) we may collect the above personal information about such other individuals. You confirm that you are authorised to provide such personal information to us and will to the extent necessary provide a copy of this privacy policy to such other individuals for their attention.

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, manage and deliver your booking – we will use your information to fulfil the services you request or purchase from us. This includes booking your holiday (with appropriate, transport, hotel etc.) and issuing you with your tickets. We may use this information to provide any suppliers and travel providers who we have agreements with, allowing us to carry out our contract of service with you. When booking with us, some special categories of personal information may be collected such as medical information.

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

d) To process any brochure requests submitted via the website or over the phone – we will use your information to send out the brochures which you have requested.

e) To personalise your customer experience - we use your information to provide you with a more personalised service. For example we will tailor our communications to you based on information contained in your account, or we will send you advertising which we think you will be interested in (where we have your consent to do so).

f) to provide assistance with online bookings – we collect your information when you fill in the required fields on our website forms such as our live chat forms in order to offer assistance where you are experiencing difficulties with our website.

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) To 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 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.

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 to handle and resolve your complaints. We will store records of customer complaints and communications with you for our records.

What Do We Do With Your Sensitive Personal Information?

Special categories of personal information, such as any relevant health conditions, disabilities, access requirements and dietary requirements, require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.

We may use your personal information which falls into a special category in the following ways:

a) to allow us to process your booking and provide appropriate assistance to your medical needs/requirements; and

b) to allow us to process any special dietary requirements that are relevant when travelling with us

c) to provide you with appropriate travel insurance, where relevant.

What is our Legal Basis for using your personal information?

We only use your personal information where that is permitted by laws that protect your privacy rights. We will only use your personal information where:

a) we have your consent (if consent is needed);

b) we need to use the information for legal purposes;

c) we need to use the information to perform a contract with you;

d) it is fair to use the personal information either in our interests or someone else's interests, where there is no disadvantage to you (what is known as a 'legitimate interest') – this can include where it is in our interests to market additional products or services to you.

Marketing

We may use your personal information to 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, or mail. We may use the information to customise the website according to your interests.

We will only send you marketing messages where there is a legal basis for us to do so, and you can withdraw your consent at any time or opt out of marketing at any time. To unsubscribe from marketing communications, please click on the unsubscribe link contained in any of our emails. To opt out of postal communications, please contact our customer services team on 03445717528. Please see 'The right to ask us to stop contacting you with direct marketing' below for further information.

How long we will keep your personal information

We will only retain your 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.

Our approach to information security

To protect your information, Caledonian Leisure has policies and procedures in place to make sure that only authorised personnel can access personal information, that personal information is handled and stored in a secure and sensible manner and all systems that can access personal 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 information to third parties (such as relevant hotels, tour companies) which are located outside the European Economic Area, for the purpose of fulfilling your booking and related services with us. For example, to allow us to organise elements of your holiday including insurance etc. We shall ensure that any such transfers are lawful by putting in place appropriate contractual undertakings, and that your personal information is kept secure in accordance with data protection legislation. For more information on how we do this please contact our data protection officer at dpo@caledonian.com

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 Caledonian Leisure Ltd 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.

Sharing your information

Where necessary to fulfil our obligations to you, Caledonian Leisure 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 Caledonian Leisure Ltd– including UK Breakaways, and Wallace Arnold Travel

b)Prospective buyers of our business or assets

c)Our travel partners and suppliers- such as hoteliers, insurance companies and ground handling agents so that they can provide you with the arrangements and assistance you require.

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 https://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- we work with a number of companies who help fulfill our direct mailing and distribution requirements, who may have access to some of your personal data to enable them to fulfill their responsibilities they have with us.

f)External data management and development companies- we work with a number of external development and systems companies to operate our business and perform services related to the contracts we enter into with you.

g) Card payment facilitators– we work with selected card payment facilitators who help us process customer payments and assist us in detecting and preventing fraudulent payments or bookings.

Please note - If you book one of our holidays through a third party travel agent, certain personal data applicable to your booking, such as your name, date of birth or any special requirements will be passed to us to provide the services you have requested/booked.

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;

e) make your online experience more efficient and enjoyable;

f) identify if you have engaged with us on social media

g) website tracking purposes and,

h) 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.

Description of cookies

The table below provides some information on the cookies which we may use on our website:

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, Caledonian Leisure ltd will hold the name and contact details 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).

Calls made to us may be recorded to protect the interests of all parties. Call records are deleted after 18 months unless needed for ongoing actions.

Right to Complain

You can make a complaint to us by contacting us via email to 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 privacy 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

dpo@caledonian.com

Changes to this Privacy Policy

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