TRAVELOPIA
OUR PRIVACY POLICY

OUR DATA PROTECTION COMMITMENT

Here at Travelopia we understand the concerns about how data may be stored, sent and used by companies. We are committed to complying with all data protection laws and want you to feel confident in the measures we are taking to uphold your data privacy rights.

Travelopia is made up of different legal entities and brands, details of which can be found here. This privacy policy is issued on behalf of the Travelopia Group so when we mention "Travelopia", "we", "us" or "our" in this privacy policy, we are referring to the Travelopia Group who is responsible for processing your data when you visit our website at www.travelopia.com (regardless of where you visit it from). In it we explain the types of information we collect, how we collect it, what we use it for and who we may share your personal information with. We also let you know what rights you have over your information. Travelopia Holdings Limited is the controller and responsible for this website.

OTHER PRIVACY POLICIES THAT MAY APPLY

Travelopia Brands: If you would like more information on how one of the Travelopia Group subsidiary companies collect and process your personal data please visit our respective brand’s website privacy policy where we will let you know which legal entity will be the controller for your data when you purchase a product or service with us. Each company within the Travelopia Group is responsible for processing the personal data that is related to their respective business.

Travelopia Recruitment: If you would like more information on how we collect and process your personal data for recruitment purposes please visit our separate Travelopia Recruitment Privacy Policy at here.

HOW TO NAVIGATE THIS DOCUMENT

We think this document highlights the most important points to be aware of. However, if you want more detail about a specific topic you can click the links below to be taken to the relevant section.

Quick links to key topics

• What information might we collect about you?
• How do we collect your information and why?
• What do we use your information for?
• When do we share your personal data?
• When do we send your data outside the UK?
• Your personal data rights
• Data Security
• How long do we keep your data for? How to contact us
• Other privacy information
• Cookies

WHAT INFORMATION MIGHT WE COLLECT ABOUT YOU?

We do our best to keep the information we collect about you to the minimum necessary.

We may collect, use, store and transfer different kinds of personal information about you, which we have summarised in the box below.

Your use of our website and social media: This includes how you use our website and/or social media pages, IP addresses and information you may post on social media.

HOW DO WE COLLECT YOUR INFORMATION AND WHY?

Depending upon your interactions with us, we might collect information in the following ways:

Direct Interactions: You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone and email or otherwise, this includes personal data you provided when you:

• provide us with information about an accident, illness or incident that occurred or some other feedback;
• contact us via our press office, social media, post or email. Our interactions with you may be recorded and monitored for the purposes of improving customer service, quality assurance, training, security and general business purposes.

Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our Cookie Policy for further details.

Third parties or publicly available sources

We may receive personal data about you from various third parties as set out below:

1. a)  airlines, hotel providers, other parties we work with or Travelopia Group subsidiary companies if you make a complaint to them;
2. b)  analytics providers

WHAT DO WE USE YOUR INFORMATION FOR?

Under data protection laws we are allowed to use personal information only if we have a proper reason to do so such as:

• to fulfil a contract we have with you or;
• when it is our legal duty or;
• when it is in our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interested.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

• To optimise our website. If you use our website, we will use your information to ensure that the content from our websites are presented in an effective manner for you and your device, to provide you with access to our site in a manner that is effective, convenient and optimal, and to provide you with content that is relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users);
• To use data analytics to improve our website. This is necessary for our legitimate interests (to keep our website updated and relevant);
• To comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or

subpoenas (on the basis of our legitimate interests to comply with a legal obligation).

WHEN DO WE SHARE YOUR PERSONAL DATA?

In order to provide you with the services and on the lawful grounds described above, we may share your personal information with third parties such as:

• Other suppliers that we work with in connection with our business. We share your information with third party suppliers that we use to provide services. This might include IT developers, service providers and hosting providers, third party software companies, site analytics providers;
• Courts or advisors. We may have to share your information with other third parties (such as legal, accountants or other advisors, regulatory authorities, courts and government agencies) to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law; and
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

WHEN DO WE SEND YOUR DATA OUTSIDE THE UK?

We will only send your data outside the United Kingdom (“UK”) to:

• follow your instructions
• comply with a legal duty
• work with our suppliers and third parties who we use to help deliver our services

Some of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. If we do transfer information to parties outside of the UK, we will make sure that it is given a similar degree of protection.

YOUR PERSONAL DATA RIGHTS

What are your rights?

We want you to feel reassured that you have control of your personal information. With this in mind, we have explained below the rights you have in relation to the personal information we hold about you:

• The right to be advised of how we will use your personal information. This is set out in this privacy policy and we do our best to provide you with as much information as we can at the point at which you pass us your data.
• The right to ask us to correct any information you believe is incorrect.
• The right to receive a copy of the personal data we hold about you or to request that we transfer this to another service provider.
• In certain circumstances, the right to ask us to stop using information about you.
• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

How can you exercise your rights?
You can exercise these rights over your data by emailing us at Compliance.Team@Travelopia.com

We will comply with your requests, unless we have a lawful reason not to do so. We may need you to provide additional details to confirm your identity in order to process your request.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will only keep your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal accounting or reporting requirements.

We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time we hold it for.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

HOW TO CONTACT US

We have appointed a Group Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Group Data Protection Officer
Travelopia Holdings Limited
Platinum House, St. Marks Hill, Surbiton, United Kingdom, KT6 4BH
Compliance.Team@Travelopia.com

Please contact us in the first instance if you have any concerns. If we are unable to resolve your concern, you have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or the relevant data protection authority where you live.

OTHER PRIVACY INFORMATION

Change of Purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Third-party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Changes to this privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 10th November 2021.

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.

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.