Privacy Policy

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Holiday Footprint collects and processes your personal data through your use of our Website or App, including any data you may provide through our Website when you sign up to our newsletter or set-up a user account.

The Website is not intended for children (i.e. individuals aged 18 or under) and we do not knowingly collect data relating to children.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices we give and is not intended to override them.

Controller

Holiday Footprint is the controller and responsible for your personal data (referred to as “Holiday Footprint”, “we”, “us” or “our” in this privacy notice).

This privacy notice is issued on behalf of the Holiday Footprint so when we mention “Holiday Footprint”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Holiday Footprint responsible for processing your data.

We have appointed a data privacy manager 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 data privacy manager using the details set out below.

Contact details

Our full details are:

Full name of legal entity: Holiday Footprint

Email address: holiday@footprintcom

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 privacy policy was last updated on 21/05/2018 and historic versions can be obtained by contacting us using the contact details in the paragraph above.

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.

THIRD-PARTY LINKS

The 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 or apps and are not responsible for their privacy statements. When you leave our Website we encourage you to read the privacy notice of every website or app you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (i.e. anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below.

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, age and gender, your photograph (where you sign-up to an account with us and choose to include your picture on your account).
• Contact Data includes email address and telephone numbers
• Technical Data includes mobile device ID, internet protocol (IP) address), your login data, browser type (for website use), time zone setting and location, operating system and platform and other technology-related information about the devices you use to access the Website. If you use our Website from a mobile device, that device will send us data about your location based on your phone settings. We will ask you to opt-in before we use GPS to identify your precise location
• Profile Data includes your username and password, your location, feedback and survey responses. When you log in with us via Facebook, we will receive (unless you change your settings within Facebook), your public profile information (i.e. your name and profile picture), your birth date, a list of your friends which also use your current city listed in your Timeline
• Usage Data includes information about how you use the Website (including your content viewing habits), products and services.
• Marketing includes your preferences in receiving marketing from us and our third parties.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website feature or content. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • contact us regarding products or services we offer on our Website;
  • create an account on our Website;
  • subscribe to our newsletter;
  • opt-in to receiving marketing emails from us;
  • enter a competition, promotion or survey; or
  • give us some feedback.

• Automated technologies or interactions. As you use the 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:

  • Technical Data from the following parties:

    • analytics providers such as Google, Facebook and Salesforce DMP to collect standard internet log information and details of Website visitors’ behaviour patterns.
    • affiliate networks (such as Amazon UK, Amazon US, AvantLink, Commission Junction, Performance Horizon, Rakuten, Skimlinks, Affiliate Window, Viator, Affilinet, Impact Radius, Webgains, Tradedoubler, Viglink) where you click on an affiliate link featured in our content.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, 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. We have also identified what our legitimate interests are where appropriate.

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.

5. Opting out of personalised content and adverts

So that we can provide you with a great user experience, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need. This is how we decide which adverts and content may be relevant for you. You will only receive marketing communications from us by email if you provided us with your express opt-in consent.

We strive to provide you with choices regarding certain personal data uses, particularly in marketing and advertising and providing you with personalized content. We have established the following personal data control mechanisms:

How to opt- out of a personalised website experience

Opting out for Website users who are logged into their Holiday Footprint Account:

If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, go to profile->settings and uncheck the ‘Personalisation’ checkbox. If you change your mind and would like to receive a personalised experience, you can simply re-check the box.

Opting out for Website users who do not have a

Holiday Footprint Account:

If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, please click to opt out from personalisation. If you change your mind and would like to receive a personalised experience, you can simply click. If you click the link to opt-out, we will place a ‘do not track’ cookie on your browser. Please note that if you delete all cookies on your browser, or if you use a different browser to access the Website you will have to click this link again in order to stop us personalising your experience on our Website.

Tracking and advertising

We use products offered by Google and Salesforce in order to show you adverts which we think are likely to be relevant to you. If you do not want to receive personalised advertising, and marketing please follow these instructions and the instructions in the paragraph below.

If you want to change the personalized advertisement settings you can use the ads settings to manage the Google ads and opt out of interest-based ads by following these instructions. Furthermore, you can elect to reset your mobile device Advertising ID to clear any associated ad targeting or data collection activities. You may do so at the following links: Android / IOS

Marketing emails

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time holiday@footprint.com

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 the Website may become inaccessible or not function properly. For more information about the cookies we use, please see cookie policy.

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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

6. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

• Internal Third Parties as set out in the Glossary.
• External Third Parties as set out in the Glossary.
• 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.

7. International transfers

We share your personal data within the Culture Trip Group. This will involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. 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.

9. Data retention

How long will you use my personal data for?

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.

We retain your personal data while your account is in existence or as needed to provide you the Website. This includes data you or others provided to us and data generated or inferred from your use of our Website.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

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.

10. Your legal rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

If you wish to exercise any of the rights set out above, please contact us by emailing holiday@footprint.com

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

External third parties

We use external third party service providers to help us provide our Website (e.g., maintenance, analysis, audit, marketing and development). They will have access to your information as is necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.