Data Protection Privacy Policy
What is the purpose of this privacy policy?
This privacy policy is to tell you what personal data we collect from you and why and what we will do with this data. It also
tells you about some of the key rights which you have under data protection laws. From 25 May 2018 onwards, you and your
personal data will be protected by the EU General Data Protection Regulation (which is otherwise known as GDPR) and a new
UK Data Protection Act 2018. In this privacy policy, we refer to this legislation as data protection laws.
We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are
otherwise permitted to do in accordance with data protection laws.
When we refer to “you” in this privacy policy, we mean the party leader, anyone else we communicate with in respect of an
enquiry, quote or booking (for example, the person by or through whom payment is made if not the party leader), the
students and accompanying staff who travel or are intended to travel on one of our trips and the parents / guardians of the
students and for adult groups, the persons who travel or are intended to travel on one of our trips.
What is our role in relation to your personal data?
For the purposes of data protection laws, we, Sports Tours Limited, are a data controller in respect of the personal data you
provide us with.
What is my personal data and what do you mean by process?
When we refer to personal data, we mean any information which relates to an identified or identifiable individual.
Where we refer to process or processing, we mean anything which we may do with your personal data including collecting,
storing, using, disclosing to third parties and erasing it.
What personal data will we collect from you and why?
In order to respond to an enquiry, provide a quote, administer and fulfil your booking or send you a brochure or other
promotional material, we need to process personal data we obtain from you.
Where you wish to make a booking, the personal data we need to collect and process at various stages is likely to include;
- name and job title of the party leader
- contact details for the party leader including their home and work e-mail and postal addresses and telephone number(s)
- if different to the party leader, the point of contact for financial arrangements / payments including their email and postal addresses and telephone number(s)
- names and dates of birth of all persons travelling
- passport information for all persons travelling
- dietary information for all persons travelling
- emergency UK contact details (names and telephone numbers) for all persons travelling
- for homestay trips, cultural, medical, physical and dietary requirements of the students
- for skiing trips, height, shoe size and weight of all persons skiing
- for concert tours, photographs of persons travelling and musical biographies of key performers
- information in respect of any medical condition, disability or reduced mobility which may affect anyone travelling – this comes within special categories of personal data (see below)
For an enquiry, the personal data we will need to process is likely to include the name and contact details of the person
making the enquiry.
For a booking or booking enquiry, we will process your personal data (other than any data which comes within special
categories of personal data – see below) on the basis that this is necessary for the performance of your contract with us or to
enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply
with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency
situation).
If you wish to receive brochures or other promotional material from us, we will need your name and the contact details
applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail,
we will need your e-mail address.
We do not use any personal information for marketing purposes other than the names and applicable contact details of the
person who has consented to receive such material.
What are special categories of personal data?
Personal data which concerns your health or which reveals your racial or ethnic origin or your sexual orientation are special
categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the
booking and provision of travel arrangements.
Generally speaking, the processing of special categories of personal data requires the explicit consent of the person
concerned.
Accordingly, information concerning any disability, medical condition, restricted mobility or other health related issue (and
related requirements) as well as dietary restrictions which disclose your religious beliefs or any health issue are special
categories of personal data. We will ask for your consent to our processing this information at the time you make your
booking or your booking enquiry or whenever you otherwise provide or indicate that you intend to provide such information.
This consent should be provided to us by the party leader on behalf of the person concerned who must authorise the party
leader to do so.
In the case of special categories of personal data which relates to children and young people under the age of 18 when the
consent is required, consent will need to be provided by the party leader on behalf of the individual’s parent or legal guardian
who must authorise the party leader to do so.
Who may we provide your personal data to?
Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen
arrangements together with any other third party who needs this information so that we can arrange for your tour to be
provided. Suppliers and other third parties are likely to include the following depending on the arrangements booked;-
- airlines
- Eurostar
- ferries and eurotunnel
- coach operators and other transport providers
- accommodation centres
- hotels and other forms of accommodation
- homestay hosts
- overseas ground agents
- tour managers and guides
- excursion and activity operators
- travel insurance providers
- concert venues
- sports fixture organisers
- ski schools
- ski hire shops
- credit card companies / banks in respect of payments
- feefo in respect of post tour feedback
The information may also be provided to government / public authorities such as customs or immigration if required by them,
or as required by law.
We may also make personal data available to other companies who provide services on our behalf, such as mailing brochures
and marketing material.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to
government / public authorities (over whom we have no control), we will take appropriate steps which are intended to
ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes
of providing their services and does not collect any personal data from you in the course performing their services.
Where will we process your personal data?
Your personal data may be processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA
countries are all member states of the European Union together with Norway, Iceland and Liechtenstein.
We may also process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in
the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is
one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is
transferred to a company which is required by our contract with them only to deal with the data in accordance with our
instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are
obliged to provide the personal data to a government / public authority in order to provide your holiday.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of
personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm
that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of
the data to be protected, having regard to the state of technological development and the cost of implementing any
measures.
Can we use your personal data to send you information about our tours and other travel services in the
future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so
or, in relation to e-mail marketing, where we comply with the Privacy and Electronic Communications Regulations 2003
(PECR). PECR permits us to send you e-mail marketing where you have previously provided us with your e-mail address in the
course of entering into a contract with us for tour arrangements or negotiations for such arrangements and we wish to e-mail
you marketing material about our similar services or products. You will of course be given the opportunity to opt out of
receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send
you any e-mail marketing.
You may provide your consent to receiving marketing material from us either on-line or by telephone. You may also choose in
what ways you are happy to receive communications from us. You may, for example, be happy to receive information and
offers by post and e-mail but not by telephone.
Can you withdraw your consent to our processing your personal data?
Yes, you can withdraw your consent to receiving marketing material or other communications from us at any time, either
generally or in any particular way, by e-mailing us at info@sportstours.co.uk. Alternatively you can telephone us.
How can you find out what information we are holding about you?
You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and
to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously
unfounded or excessive or we have previously provided the same information. We promise to respond to your request
without delay and in any event within 1 month unless the request is complex or you have made numerous requests in which
case we may be able to extend our response time by a further 2 months.
What should you do if the personal data we are holding is inaccurate, out of date or incomplete?
If you believe this is the case, please tell us by e-mail as soon as possible. We will rectify the problem within 1 month or within
3 months if the rectification request is complex.
How long can we retain and process your personal data?
We will not process your personal data in a form which enables you to be personally identified for any longer than is
necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.
Where your personal data has been provided for the purpose of the holiday arrangements or other services you have
contracted, we are entitled to retain this data for a period of at 6 years after those arrangements have been completed. In
certain limited circumstances, we may be able to retain it for a longer period.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this
purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and
effective.
Can you ask us to delete your personal data?
Yes, you can ask us to erase your personal data in certain circumstances, for example where you have withdrawn your
consent to further marketing material where the data in question has only been processed for this purpose. However, this is
not always the case. Please see the previous paragraph for further information on the period of time we may retain personal
data.
Can this privacy policy be changed?
Yes, from time to time we may need to make changes to this privacy policy. These may be required as a result of changes in
data protection laws or in the guidance issued by regulators such as the Information Commissioner’s Office (which is usually
referred to as the ICO) or where we make changes to our procedures. The latest version of this privacy policy can be found on
our website www.sportstours.co.uk
Does your website use cookies?
Yes, as is the common practice, our website uses cookies. A ‘cookie’ is a small data file which our website server stores on
your computer in order to collect information about your visit and to remember you when you visit again at a later date. The
main purpose of a cookie is to identify users and to personalise their visit by customising web pages for their use. We may
also use third parties who will collect data which is not personally identifiable to analyse site visits and carry out other similar
activities. In the course of doing so, they may place their own cookies on your computer so that they can collect information
about your visit. You may if you wish disable or delete such cookies through your internet browser. However, doing so may
mean you will be unable to access our website or parts of it, your experience of our website may be adversely affected
and/or you may not receive information which is relevant to your personal interests.
What should I do if I have a complaint about the processing of my personal data?
If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to
dataprotectionofficer@sportstours.co.uk. We will investigate and respond to you as soon as we reasonably can. If you remain
dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see http://www.ico.org.uk/