Unforgettable Travel Company (“UTC”, “Unforgettable Croatia”) Privacy & Cookie Statement
2.Who We Are
Here are the details that the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, known as General Data Protection Regulation (GDPR) says we have to give you as a ‘data controller’:
- Our site address is unforgettablecroatia.co.uk
- Our company name is Unforgettable Travel Company
- Our registered address is 86-90 Paul Street, London EC2A 4NE
- Our Company registration number is 9738411
- Our nominated representative is the Marketing Manager and they can be contacted at firstname.lastname@example.org
3.What we may collect
We may collect and process the following data about you:
- Information you put into forms or surveys on our site at any time
- Information you put into competitions or surveys managed and initiated by us on third party sites
- A record of any correspondence between us
- Details of transactions you carry out through our site
- Details of your visits to our site and the resources you use
- Information about your computer (e.g. your IP address, browser, operating system, etc.) for system administration and to report aggregate information to our advertisers
- Subscription and demographic information such as preferences, interests, age and family information.
- Information relating to your holiday such as reviews, blogs, image or video uploads, questionnaire data, holiday enquiries and brochure or marketing requests
- Information relating to quoting and booking a travel service, including information regarding family and travel companion(s) such as names, emergency contacts and special service needs, such as any disability or medical or dietary restrictions (which may disclose your religious beliefs), passport information, dates of birth, insurance information, visa information, nationality and country of residence.
- Telephone information including phone numbers, call duration and on occasion call recordings that we use for training and quality control.
- Third party information about you from other sources which we may add to our account information. For example we update address information using data from the Royal Mail “Change of Address” File, which we may use to correct our records.
Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
- a) you have given consent to the processing of your personal data for one or more specific purposes;
- b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
- c) processing is necessary for compliance with a legal obligation to which we are subject;
- d) processing is necessary to protect the vital interests of you or of another natural person;
- e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
- f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party such as our credit card payment processing, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
All Cookies used by and on our website are used in accordance with current English and EU Cookie Law.
A few of the cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the site and will last for longer.
All cookies used on our site are set by us.
Most computer and some mobile web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can prevent the setting of cookies by adjusting the settings on your browser. Please note however, that by blocking or deleting cookies you may not be able to take full advantage of the site.
Our cookies will be used for:
Essential session management
- recognising when a user of the site has visited before allowing us to identify the number of unique users we receive to the site and make sure we have enough capacity for the number of users that we get;
- recognising if a visitor to the site is registered with us in any way;
- we may also log information from your computer including the existence of cookies, your IP address and information about your browser program in order to allow us to diagnose problems, administer and track your usage of our site.
- customising elements of the promotional layout and/or content of the pages of the site.
Performance and measurement
- collecting statistical information about how our users use the site so that we can improve the site and learn which parts are most popular to users.
5.How we use what we collect
We use information about you to:
- Present site content effectively to you.
- Provide information, products and services that you request, or (with your consent) which we think may interest you.
- Carry out our contracts with you.
- Allow you to use our interactive services if you want to.
- Tell you our charges.
- Tell you about other goods and services that might interest you.
- Internal record keeping, auditing and regulation purposes.
- We may use your information to contact you for market research purposes.
If you are already our customer, we will only contact you about things similar to what was previously sold to you.
If you are a new customer, you will only be contacted if you agree to it.
If you don’t want to be contacted for marketing purposes, please email us at email@example.com or follow the unsubscribe link from any marketing emails.
In some cases, the collection of personal data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you if you don’t provide your personal data in these cases.
6.Where we store your data
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your booking and deal with payment.
By giving us your personal data, you agree to this arrangement. We will do what we reasonably can to keep your data secure.
Payment will be encrypted. If we give you a password, you must keep it confidential. Please don’t share it. Although we try to provide protection, we cannot guarantee complete security for your data, and you take the risk that any sending of that data turns out to be not secure despite our sincere efforts.
7.Disclosing your information
In order to respond to your holiday request or booking we may need to disclose some of your information to our partners including:
- Delivery companies we use to send our your travel bookings such as Royal Mail and their affiliates
- Travel companies such as hotels, airlines, ground handlers and car hire companies.
We only pass on information that is required in order to fulfill the booking or enquiry, such as name and address to delivery companies and name and passport information to airlines.
We are also allowed to disclose your information in the following cases:
- If we want to sell our business, or our company, we can disclose it to the potential buyer.
- We can disclose it to other businesses under the umbrella of The Unforgettable Travel Company
- We can disclose it if we have a legal obligation to do so, or in order to protect other people’s property, safety or rights.
- We can exchange information with others to protect against fraud or credit risks.
We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. These are the third parties that have access to your information:
Third Party Couriers
Third Party Web / Software Developers and Website Optimisation Consultants.
Please be aware that due to the nature of our business and of the internet, information and data you provide may be transferred outside the country where it is submitted to us. If you are submitting information or data from a country within the European Economic Area (EEA) it is possible that it may be transferred outside the EEA, where data privacy regulations may differ from within the EEA.
Advanced Passenger Information (API) is required by many countries prior to arrival (or departure). API information includes personal identity information such as name, passport details, visa information, nationality, transit and destination data. Airlines and transport companies are required to transmit this information by law and data entry is requested at the time of ticket issue. To comply with these regulations Unforgettable Travel Company (“UTC”, “Unforgettable Croatia”) passes the relevant information to the transport companies who transmit the information to the relevant authorities.
Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under GDPR and the law.
You can ask us not to use your data for marketing. You can do this by indicating your preferences on our forms, or by contacting us at any time at firstname.lastname@example.org.
Under the GDPR, you have the right to:
- request access to, deletion of or correction of, your personal data held by us at no cost to you;
- request that your personal data be transferred to another person (data portability);
- be informed of what data processing is taking place;
- restrict processing;
- to object to processing of your personal data; and
- complain to a supervisory authority.
You also have rights with respect to automated decision-making and profiling as set out in section 11 below.
9.Links to other sites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our site. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
- Automated Decision-Making and Profiling
11.1 In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from us.
11.2 The right described in section 11.1 does not apply in the following circumstances:
- a) the decision is necessary for the entry into, or performance of, a contract between the you and us;
- b) the decision is authorised by law; or
- c) you have given you explicit consent.
11.3 Where we use your personal data for profiling purposes, the following shall apply:
- a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
- b) Appropriate mathematical or statistical procedures will be used;
- c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
- d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
12.2 If any such dispute cannot be settled amicably through ordinary negotiations between the parties, or either or both is or are unwilling to engage in this process, either party may propose to the other in writing that structured negotiations be entered into with the assistance of a fully accredited mediator before resorting to litigation.
12.3 If the parties are unable to agree upon a mediator, or if the mediator agreed upon is unable or unwilling to act and an alternative mediator cannot be agreed, any party may within 14 days of the date of knowledge of either event apply to appoint a mediator.
12.4 All negotiations connected with the relevant dispute(s) will be conducted in confidence and without prejudice to the rights of the parties in any further proceedings.
12.5 If the parties agree on a resolution of the dispute at mediation, the agreement shall be reduced to writing and, once signed by the duly authorised representatives of both parties, shall be final and binding on them.
12.6 If the parties fail to resolve the dispute(s) within 60 days (or such longer term as may be agreed between the parties) of the mediator being appointed, or if either party withdraws from the mediation procedure, then either party may exercise any right to seek a remedy through arbitration by an arbitrator.