Expressions Holidays privacy policy and use of cookies
Whether you are booking a holiday or requesting our E-Newsletter, the privacy of our clients is highly important to Expressions Holidays and we (Garland Hoff Limited, trading as Expressions Holidays, a company established in England and Wales, with company number 2328857 whose registered office is at Lynx House, Pynes Hill, Exeter EX2 5JL, hereafter referred to as "Expressions Holidays") have thus set out the following online Privacy Policy, intended for your peace of mind.
YOUR ACCEPTANCE OF EXPRESSIONS HOLIDAYS' PRIVACY STATEMENT
Through the usage of the expressionsholidays.co.uk site ("the Website") or submittal of personal data you unreservedly accept and agree to the use of that data, by Expression Holidays as detailed in this privacy statement.
WHAT PERSONAL DATA DOES EXPRESSIONS HOLIDAYS COLLECT?
1. Using the Website
When you use the Website you may provide Expressions Holidays with your name, postal and email address and telephone number.
2. Booking a holiday
When you book a holiday with Expressions Holidays, we collect personal data needed to facilitate and arrange travel related services on your behalf.
Depending on the nature of your holiday, typically, we request the following personal data about you:
• Name, address and telephone number;
• Email address;
• Payment account information (credit/debit card details including card type, card number, security number and expiry date);
• Passport details;
• Loyalty programme/frequent flyer details;
• Other details relevant to your holiday arrangements including any information required by the relevant travel service provider(s) and 3rd party product and service providers;
We may also collect, store and use the following "special categories" of more sensitive personal information:
• Dietary requirements;
• Health issues (if any).
3. Information we collect about you through our site
With regard to each of your visits to the Website, we will automatically collect the following information:
• Technical information, including the Internet Protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• Information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including time and date), page response times, download errors, length of visits to certain pages, page interesting information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
YOUR RIGHT TO OPT OUT
• You may email info@expressionsholidays.co.uk at any time to unsubscribe; if you unsubscribe we will remove your name from our internet marketing database and you will no longer receive internet marketing communications including E-Newsletters.
HOW EXPRESSIONS HOLIDAYS USES YOUR INFORMATION
1. Using the Website
When using the Website, Expressions Holidays uses your information:
• to provide our services to you through the Website, including brochure and printed information downloads;
• where you have given us your consent to do so, for sending out further information, which we believe will be of interest to you such as news items, special offers and other marketing information.
Through the collection of clients' data and the opportunity to get to know more about you, we are able to provide more pertinent content and hence better service and a more fulfilling online experience.
2. Booking a holiday
Where you contact us in relation to a travel booking or query, we may use your information:
• to provide you with travel and holiday advice;
• to assist you with booking holiday and travel related products and services;
• for the dispatch of electronic and printed information requested by you;
• where you have given us your consent to do so, for sending out further information, which we believe will be of interest to you.
3. General
We may also use your personal data to comply with legal obligations and where necessary in relation to your contract with us (either through accepting our online Terms and Conditions or otherwise) or because you have asked us to do something so that we can enter into a contract with you.
LEGAL BASIS FOR PROCESSING
1. General
Except in relation to direct marketing, we process all personal data either:
• as a legitimate interest of our business to provide our services to you; or
• in order to perform the contract for services entered into with you under our Terms and Conditions.
2. Special Categories
Where we process special categories of more sensitive personal information, we will do so only where you have given explicit consent to the processing of that personal data for one or more specified purpose.
3. Marketing
We will only send you electronic or printed communications where we have received your consent to do so. This consent may be withdrawn by contacting us on the details above. Any ancillary processing required to conduct the marketing, such as internal profiling, is carried out as a legitimate interest of our business as part of our marketing activities.
Please note that there may be a time delay between your notification of withdrawal of consent and removal of your details from our third party mail merger database, in which case you may receive marketing communications from us during this period and we apologise for any inconvenience caused. We promise to action your request as soon as possible following receipt.
4. Sensitive/Special Categories of Personal Data
We may process your personal data, which is either sensitive personal data or special category personal data when you book a holiday through Expressions Holidays, where you have given explicit consent to the processing of such personal data for one or more specified purposes.
DISCLOSURE OF YOUR INFORMATION
We may disclose personal data to third parties in the following circumstances or to the following entities:
1. General
• Legal purposes. Where we are under a duty to comply with any legal obligation under applicable laws.
• Marketing. Where you have consented to receiving marketing communications, we will share your personal data with our mail merging company based in the UK. For more details regarding our mail merging company, please contact us at info@expressionsholidays.co.uk
• Affiliates. Our subsidiaries and parent company and businesses, and other affiliated legal entities and businesses with whom we are under common corporate control. We shall ensure that all of our parent, subsidiary, and affiliated legal entities and businesses that receive your information from us will comply with the terms of this privacy policy.
• Third party purchaser. In the event that we sell or buy any business or assets we will disclose your personal data to the prospective seller or buyer of such business or assets.
• Enforcing our rights. In the event that we are required to take action to enforce the terms of this Privacy or the Terms and Conditions.
2. Booking a holiday
• Advance passenger information. Please note that some or all of the Caricom States listed below have entered into an agreement within the USA whereby advance passenger data required by and provided to Caricom States for border security purposes will be passed to the USA Department of Homeland Security for processing on behalf of those Caricom States listed as follows: Anguilla, Antigua and Barbuda, The Bahamas, Barbados, Belize, Bermuda, British Virgin Islands, Cayman Islands, Dominica, Grenada, Guyana, Haiti, Jamaica, Montserrat, Saint Lucia, St Kitts and Nevis, St Vincent and the Grenadines, Suriname, Trinidad and Tobago, Turks and Caicos Islands, collectively members or associate members of 'Caricom'.
• Travel arrangements. In order to provide the services we may need to pass your personal data to suppliers of your travel arrangements, including airlines, transport companies and hotels. We may also need to supply it to security companies, and to public authorities such as customs and immigration.
• Provision of services. To provide you and our other customers with the services in accordance with this Privacy Policy and our Terms and Conditions we may share information with our third-party E marketing and printing providers, all based in the UK. For more information about our third-party providers please contact us at info@expressionsholidays.co.uk
HOW EXPRESSIONS HOLIDAYS PROTECTS YOUR INFORMATION
All personal data is stored on secure databases and authorised staff are permitted access. We also use a Firewall (security software) to safeguard stored personal data. Clients also have a legal right to view the data that Expressions Holidays holds about them.
This means that personal data submitted can only be exchanged between you and Expressions Holidays.
Until 25 May 2018, Expressions Holidays has notified as a data controller under the United Kingdom Data Protection Act 1998. Registration Number PZ6813170.
TRANSFERS OUTSIDE THE EEA
1. Using the Website
As a result of disclosing your personal data to a third party listed above, we may transfer your personal data outside the European Economic Area (the "EEA") when you use the Website.
To ensure that your personal information receives an adequate level of protection we ensure that appropriate safeguards are in place, as detailed in the processing agreement between Expressions Holidays and the third party. The safeguards may included passing down the EU Model Contract Clauses or ensuring U.S. Privacy Shield certification.
2. Booking a holiday
If your holiday involves travelling outside the EEA, we will transfer your personal data outside the EEA. Where the destination outside the EEA has not been approved by the European Commission as having adequate data protection legislation in place or where there are no appropriate safeguards in place, a transfer of personal data outside the EEA shall take place only on one of the following conditions:
• you have explicitly consented to the proposed transfer, after having been informed of the possible risks of such transfer due to the absence of an adequacy decision and appropriate safeguards;
• the transfer is necessary for the performance of a contract between you and Expressions Holidays or the implementation of pre-contractual measures taken at your request; or
• the transfer is necessary for the conclusion or performance of a contract concluded in your interest between Expressions Holidays and another natural or legal person.
WHEN WE DELETE YOUR 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. 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.
All personal data held will be reviewed every 10 years, whereby we remove inactive accounts.
In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
RIGHTS OF ACCESS, CORRECTION, ERASURE AND RESTRICTION
1. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your working relationship with us.
2. Your rights in connection with personal information
Under certain circumstances, by law you have the right to:
• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below). Where we delete your information pursuant to this right, we may keep anonymised information relating to your bookings for internal business purposes and/or to comply with regulatory requirements.
• Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.
If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact us at info@expressionsholidays.co.uk
EXPRESSIONS HOLIDAYS' USE OF COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.
THIRD PARTIES
Expressions Holidays will not sell your personal information to any third parties.
CONTACTING EXPRESSIONS HOLIDAYS
If you have any queries pertaining to our Website or Privacy Policy, or consider that Expressions Holidays has not adhered to this Privacy Policy, please advise us via email at info@expressionsholidays.co.uk, by telephone on 01392 441200 or in writing to: Marketing, Expressions Holidays, Lynx House, Pynes Hill, Exeter, Devon, EX2 5JL.
RIGHT TO COMPLAIN
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
This version was last updated on 18 May 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
COOKIE POLICY
Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them below:
Cookie name: Joomla (e.g. b51cfab5aa5bbf93de7faad8644e8c55) Duration: Session Purpose: Preserves the visitor's session state across page requests
Cooke name: zenbase_tpl Duration: 1 year Purpose: Supports the site template
Cookie name: _gat, _gtag, _UA3142467_13, _gid, _ga Duration: 2 years Purpose: Used by Google Analytics
Cookie name: rstbox_637a0a56160de4b4b09b48d4edeac0e9_1, nrid Duration: Session Purpose: Exit and other popups
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
Except for essential cookies, all cookies will expire after 2 years.
