© Luxury Gold 2023. All Rights Reserved.
Last updated: August 2021
This privacy notice supplements other notices and is not intended to override them.
We respect your right to privacy, and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data.
We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal data unless at least one of the following requirements are met:
|PROCESSING ACTIVITY||BASIS FOR LEGITIMATE INTEREST|
|Direct marketing activities including tracking, profiling, segmentation, and communication across multiple channels, see section 8.8||Legitimate interest in promoting relevant services and products based on your relationship and interaction with us|
Record keeping and reporting, see section 8.6
|Legitimate interest in understanding and improving our business|
|Statistical analysis of customer data, see section 8.7 & 8.9||Legitimate interest in understanding and responding to customer behaviour and preferences|
|Provision of customer data to insurance providers, border authorities & other law enforcement agencies, see section 11.4 & 11.7||Legitimate interest in protecting and maintaining the safety of our guests and employees; legitimate interest in taking appropriate legal action in case of disputes|
|Processing of guest preferences and other information volunteered by the guest prior to a trip, see section 8.3||Legitimate interest in personalizing and improving the delivery of our services and products|
|Processing of customer data as part of prize draws, competitions, sweepstakes, and surveys, see section 6.4 & 6.5||Legitimate interest in engaging with our customers and promoting our products|
|Processing of customer data in the course of administration and maintenance of our websites and systems, see section 6.8 & 8.7||Legitimate interest in running our business and improving our systems|
We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal data, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal data for unrelated purposes, based on our legitimate Interest.
We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);
individuals in respect of whom any enquiry or booking is made with us by an agent;
where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;
individuals whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).
When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.
When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:
This section summarises the types of personal data about you that we process:
We may collect the following:
If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you:
Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:
Information collected or generated out of any surveys we conduct.
Information collected or generated out of any competitions or promotions we run.
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.
We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
This information may include:
This information may also include:
This section sets out the ways in which we may collect or generate personal data concerning you.
Your personal data will include data you provide (or later amend), whether:
This includes when you:
We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let [Brand Name] and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:
We may obtain personal data concerning you from third parties, including from:
We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:
We may record telephone calls with you for training and quality purposes.
This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.
To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.
To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.
To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.
To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us.
To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.
To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.
To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;
For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings. This is done on the basis of our legitimate interests in ensuring our business runs efficiently.
To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you. We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 10.1 for the types of products we may market to you this way.
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.
You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.
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.
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 your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you would like to know more about our data retention policy, please ask us.
We do not use or disclose your personal data for direct marketing purposes unless:
If you do not want to receive direct marketing activities anymore, you can manage your communications preferences on your online account or unsubscribe by following the link at the end of every of our electronic communications.
In addition to data protection law if we use your personal information for direct marketing purposes, we may also be subject to additional rules that regulate direct marketing, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.
We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:
Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or SMS).
From time to time, we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:
You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”
When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.
You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.
We transfer your personal data to third parties in the following circumstances:
We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;
Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.
We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.
We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.
We may supply personal data to a government authority or regulator where required to:
We may disclose your personal data where otherwise required by or permitted by law.
We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent. Please refer to the direct marketing section above for more information.
If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.
If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
Where we provide your personal data to a third party one of the following two circumstances will apply:
We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”) and the United Kingdom.
We will only send your personal data outside the EEA and the United Kingdom to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA and the United Kingdom. You can find out about what adequate safeguards these are by contacting us using the details provided in Section 16 of this privacy notice.
We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:
Unfortunately transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.
We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on https://www.priv.gc.ca.
To exercise any of your rights below, please use a dedicated online form https://ttc.com/personal-data-request/, or send your request via email to email@example.com.
You may request the following information be provided to you:
We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case.
The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive. We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
You have the right to have your personal data amended if it is inaccurate or incomplete.
You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.
You have the right to have your personal information deleted or removed in the following circumstances:
When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.
We have the right to refuse to act on a request of erasure if the data is necessary for:
You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:
You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:
Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so.
We will inform you before the restriction of processing is lifted.
You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10.3 for details as to how to object to our direct marketing communications.
The laws we comply with are regulated by the Information and Privacy Commissioner of Ontario, 2 Bloor Street East, Suite 1400, Toronto, ON M4W 1A8. https://www.ipc.on.ca/. In addition to your rights above, it is open to you, if you have a complaint or a concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have. You can contact us using the details provided in Section 16 of this our privacy notice.
We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.
Applicable Law and Disputes
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