Our aim at Exclusive Golf Travel is that all customers that travel with us have the best possible experience from start to finish. In order to make this possible, we will need to ask you for some personal information. We do of course understand that your personal data is very important to you and the safety and security of this is our paramount concern. We will always be completely open and transparent with the way that we collect and keep your personal information.
We will need to request information from you such as your name and contact information as well as your email address. If you make a travel booking with us, we will also require your passport details. This personal data is collected for the following reasons:
•To provide you with the best possible experience depending on whether you are using the website or our mobile and tablet apps.
•So that we are able to get in touch with you if required or if you request information from us.
•To make sure that we are able to make the correct travel arrangements for you.
When you make a booking with us, we may also need to ask you to tell us about any health conditions that you have in order for us to be able to fulfil any special requirements that you might have.
How we share your personal information
We will only ever ask you directly for any personal information or obtain this information from website or app tracking with your permission. Your data is never shared with any third parties for the purposes of marketing.
Whenever your information is shared, it is always for the purposes of providing you the best possible travel experience.
Keeping your personal information safe
Please be assured that your personal information is kept securely and only ever for the appropriate amount of time. If you no longer wish to receive our email marketing, you can opt out at any time by selecting the unsubscribe link at the bottom of the email.
Your rights pertaining to your personal information
In addition to this, you are also free to contact the UK Information Commissioner’s office by telephone on 0303 123 1113 or visit their website at https://ico.org.uk/ for further information.
1. About us.
1.1 Exclusive Golf Travel is fully committed to protecting your personal information and respecting your personal privacy whilst providing you with the best possible booking and travel experience. We take every possible step to ensure that your data is safe and as such, we comply with all data protection legislation. We understand that it is also very important for you as our customer to understand how your personal information is used.
1.3 As with all companies that collect and use personal information, we have a legal requirement to protect your information under both the Data Protection Act 1998 (also the UK Data Protection Bill) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”). For the purpose of the DPA and GDPR, we (Acetrip Limited) are the data controller (in simple terms, this means that we are the organisation responsible for determining how your personal information is used) and we are located at 8 Marlborough business centre, 96 George lane, London, E18 1AD. You can find our contact details in section 10 below.
2. Personal information that we collect, how this is used and our lawful basis for processing this information
2.1From time to time we may need to collect and use various types of personal information. You can find details of this information, together with an overview of the way that we use it and our lawful bases for the processing in each case are set out below:
Enquiries and bookings
(a)When you make a telephone or website enquiry and/ or when you make a booking with us, we will need to collect some personal information from you. This information will include your name and contact information and any other necessary information in order to be able to fulfil your enquiry or booking. We may also need to ask you details of when and how we should contact you and your reasons for contacting us. This information will be used solely for the purposes of contacting you and providing you with the requested information or to contact you as indicated.
Your information will also be used where there is a legitimate interest in order to be able to help you find your preferred holiday component e.g. flight, hotel, package etc. When using your data in this way, your rights will continue to be protected.
(b)When you make a booking with us we will need to request that you provide certain details to us. This information may include your passport details, information about emergency contacts, your personal preferences and specific requirements, travel insurance information, frequent flyer information and various other travel specific information.
This information is used to enable us to provide you with a seamless travel experience and so that you receive all products and services as requested.
For repeat customers, we may retain some of this personal information in the legitimate interest of improving your booking experience for future purchases.
Information collected via the websites, apps, marketing and advertising
(c)We will collect certain technical information about you when you visit our website. This information may include details such as your service provider, your IP address or other information that identifies your device, the type and version of browser that you use (for example, Chrome, Firefox, Internet Explorer or other), the type of operating system that you use (e.g. Windows, Mac, Linux or other), the screen resolution of your device, the dates and times when you access our website, the full URLs of the pages you visit and the websites or links that you use to access our website, login information, details of products or services that are viewed and the length of visits to certain pages of the website. This information will be collected using cookies.
The technical information collected is used for effective site management and security (for example, to allow us to detect and solve technical problems) and to improve the website experience. No attempt to identify individual website users is made using this information. The raw data logs that are generated are retained only temporarily and are used solely for effective management of the website.
•This information is collected solely for the purposes of fulfilling our legitimate interests as a business. This includes ensuring that the website works as intended, that all products and services are appropriately displayed and that relevant information is displayed to customers. We also rely on our legitimate interest in measuring customer satisfaction and troubleshooting any website issues. Where required by law, we may also seek and rely on your consent.
(d)When you use our mobile or tablet apps, we will collect and use information about you. The information collected is likely to include the following; identity data, contact data, transaction data, device data, usage data, location data (if you wish to use this particular feature, you will be asked to consent to your data being used for this purpose and you can withdraw your consent at any time by disabling location data in your settings).
•We have a legitimate interest to collect and use this information either directly, or through our app solution provider, to fulfil our contract with you or in order to enhance your experience with Acetrip. Where we rely on our legitimate interests, we will always ensure that your rights are protected.
(e)Data collected for the purposes of marketing and advertising of our services may be collected from various sources. The information that we collect may include your contact details and marketing preferences in order to be able to contact you with certain marketing messages (e.g. marketing e-mails). In order to offer you the best experience, your data may also be used in order to help measure the effectiveness of our advertising and to provide you with marketing information that best suits your requirements.
•According to the various data protection laws, Exclusive Golf Travel relies on your consent in order to provide you with marketing about our products and services. Where we rely on our legitimate interests for the purposes of providing relevant marketing and advertising to you, we will always ensure that your rights are fully protected. If at any time you decide that you no longer wish to receive our email marketing, you can opt out at any time by selecting the unsubscribe link at the bottom of the email.
(f)If you participate in any surveys, promotions or competitions that we offer, your contact details may be collected for these purposes.
•We will always ensure that we protect your rights when relying on your consent or our legitimate interests for the purposes of marketing or market research.
(g)In order to be able to effectively communicate with you and respond to questions from you on social media, we may need to collect details such as your name and user name.
• We will always ensure that your rights are protected when relying on our legitimate interests to provide you with the best possible user experience.
Data collected for administrative and/ or other business purposes
(h) When corresponding with you by email, in writing, over the phone, using our live char facility or via social media, we may need to collect and use your personal information to ensure that we provide you with a high quality of service. For example, this may include recording of telephone calls for training purposes, recording of live chat to provide you with appropriate responses etc.
•The information that is collected is used solely for the purposes of providing you with a high quality service and to ensure that are staff are appropriately trained in order to be able to meet your requirements and expectations.
(i)When you contact us for a specific purpose other than those mentioned above – for example, if there is an issue with the website – we may collect certain information in order to be able to deal with your query.
•We will ensure that your rights are protected at all times when collecting your data in our legitimate interests in order to improve your user experience – for example when you report an issue with the website.
2.2 In addition to personal information that we collect directly from you, we will also collect some information from certain third parties – for example, Google Analytics, our mobile and tablet apps etc.
2.3 In order to ensure that we provide you with travel plans that are appropriate for your specific needs, we may at times need to collect and make use of some potentially sensitive and highly personal information such as your health conditions, allergies, dietary requirements etc. We may also need to confirm your explicit consent to be able to use and process this information for this purpose.
3. How Exclusive Golf Travel shares personal information
3.1 From time to time, we may need to share your personal information with certain third parties to ensure the efficient running of our business and to ensure that you receive the expected service. These third parties may include:
(a) Other members in our group of companies, including our subsidiaries where operations are shared.
(b) Certain third party business partners and service providers (for example, hoteliers, airlines and other transport providers) in order to be able to provide you with the services that you have requested and to be able to fulfil our contract with you.
(c) Third parties where we are legally obliged to provide information in order to fulfil agreements – for example, where we are required to provide a mobile telephone contact for a passenger to an airline under IATA Resolution 830d.
(d) Other third parties when explicitly required in order to protect ourselves, you, your safety and your rights or property and/or those of others.
3.2 Acetrip will never share any of your personal information with third parties to use for marketing purposes or for their own purposes.
4. Automated decisions and profiling
4.1 For the purposes of performing some of the above functions, we utilise technology in order to make instant decisions based upon the personal information that you provide. Our systems are designed and tested to ensure that there is no untended bias with regards to this automated decision making.
5. Storage and transfer of personal information
It may be necessary on occasion to process or request a third party to process your personal information outside of the European Economic Area (EEA) where local laws do not provide the same legal protection to you as you would receive within the EEA.
This may, for example, include when you make a hotel booking and we are obliged to share your information to the hotelier or local accommodation or transport provider.
On occasion when we are required to share your information with third parties outside of the EEA, we will take all possible measures to ensure the safety and security of your data according to applicable laws as outlined above and so that the usage of the information provided is limited to the fulfilment of our contract with you.
Your personal data may also be processed by members of Acetrip staff that are located outside of the EEA in order to provide you with the services that you have requested. The same standards of protection that are used in the UK are in place throughout Acetrip.
6. The security of your personal information
6.1 The security of your personal information is our primary concern and we have put in place stringent technical, operational, administrative and physical controls and strategies to ensure that your data is always protected. This is to ensure that we comply with all applicable data protection legislation. These protections are consistently under review to ensure that we continue to provide you with the highest standards of data security.
7. Retention of your personal information
7.1 Your personal information is only ever kept for as long as it is absolutely required for the purposes of processing and providing you with the products and services you have requested. Retention of data will vary depending on the purposed for which it was initially collected. For example, personal contact information will be kept until your trip is complete whereas some transaction information may be required to be held for several years to comply with local taxation obligations.
8. Your rights with regards to your personal information
8.1 As a customer, you have certain rights with regards to the personal information that we collect from you and hold about you. You can find details of these rights below. Should you wish to exercise any of these rights, you can contact us via the Contact and complaints section).
8.2 Your rights:
(a) Access: When requested, we will confirm to you whether or not we are processing and using personal information about you. We will also provide you with access to and a copy of this personal information and any other relevant details to which you are entitled.
(b) Rectification: We will ensure that we swiftly correct your personal information whenever we receive notification from you of any inaccuracies with regards to the information that we hold.
(c) Prevention of processing likely to cause damage or distress: When we are notified by you that the processing of personal data is likely to cause harm or distress to you or third parties, we will cease processing this information with immediate effect.
(d) Deletion of data: Where there is no legitimate reason for us to continue to use your data, we will ensure that this is deleted without delay at your request.
(e) Restriction: If requested, we will comply with requests to restrict the processing of your personal information.
(f) Data portability: If required, we will provide copies of personal information that we hold about you to you or third parties on your behalf in a clear, structured, commonly used and machine readable format.
(g) Objection (including objection to direct marketing): When you object to the use of us processing your personal information for marketing purposes, we will respect your objections and cease this usage.
(h) Automated decisions and profiling: We will respect your rights to require us not to carry out decisions based solely on automated processing, including profiling, which produce legal or similarly significant effects on you.
10. Contact and complaints