GDPR PRIVACY and DATA POLICY

Client (the “Data Controller”) will use Uniglobe Prestige Business Travel (“the Processor”) to process profile data of Client and their staff.  By Providing the Services related the Processor, Uniglobe Prestige Business Travel may process Personal Data.

This document (“Privacy Protection Policy”) describes how we collect, use and protect the personal information of travellers and other persons who may have dealings with us. Please read this Privacy Protection Policy carefully. 

What is “personal information”?

The personal information that we are concerned with in this Privacy Protection Policy is the private information of individuals such as birth dates, passport numbers, travel dates and destinations, health information, travel and meal preferences, frequent flyer and other membership numbers, personal e-mail addresses and financial information related to personal credit cards, bank accounts and other payment methods. Personal information does not include an individual’s name, title, business address, business telephone, fax or cellular phone numbers. 

Why do we collect, use and disclose your personal information?

We will only process your information where, the processing is necessary to provide services to you and the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information for the sole propose of arranging travel.

 We collect relevant personal information when you ask us to provide you with information or travel related services (such as air, ground and sea transportation, hotel and other accommodation, tours, meals, services and insurance products) that are sold or reserved through us (the “Travel Services”). We use and disclose the personal information in order to provide you with the requested information or Travel Services and for purposes ancillary and additional to that. In particular your personal information may be used –

• To identify you and your preferences;
• To research and suggest Travel Services to meet your communicated needs
• To make airline, hotel, car, tour and other reservations on your behalf;
• To obtain travel insurance policies on your behalf;
• To obtain credit card or other financial approval for payment;
• To compile statistics and conduct market research; 
• To compile reports for the suppliers of your Travel Services and for regulatory and industry agencies;
• To compile business travel reports for your employer related to destinations travelled, costs, classes of service, hotels used and duration of stay and car rental companies used and duration of rentals;
• To comply with the law;
• For purposes ancillary to the above.

Unless permitted by law, your personal information will not be used for a purpose other than the purposes mentioned above (“the Identified Purposes”) without obtaining additional consent from you.

How do we collect your personal information?

The following are the sources that we may use for gathering personal information. We will use only those required for the Identified Purposes. We may gather information –

• From you when you request information or Travel Services either orally or in writing;
• From your agent, family member, employer, employee or authorised representative when such person is seeking information or Travel Services on your behalf or otherwise representing you;
• From personal travel profiles you have completed;
• From our records relating to previous requests or reservations you have made;
• From the computerised reservation or other systems used to make your travel reservations now or in the past;   
• From credit card issuers, credit bureaux or other consumer reporting agencies;
• From the airlines or other suppliers of Travel Services to you at any time

Who will we disclose your personal information to?

We act as the agent or intermediary for or in respect of the suppliers (‘the Suppliers”) of the Travel Services. Accordingly, personal information relevant to the sole purpose of providing your Travel Services will be disclosed to the Suppliers of such Travel Services. It may also be disclosed to:    

• The third parties referred to above in connection with the Identified Purposes or referred to as sources of your personal information; or   
• Other parties or organisations who may acquire the whole or portion of our business and who are obliged to protect your personal information in terms of this Personal Information Policy or the Laws.
• Responsibility for personal information provided to us remains under our control, including personal information that has been transferred to Suppliers.

Lawful Basis

We may process your or your employees’ personal data that are provided in the course of the use of our services (“service data”) and such given your consent to such processing which you can with draw at any time.

We may process information contained in any enquiry that you or your employees submit to us regarding products and/or services (“enquiry data”). The enquiry data may be processed for the purpose of providing an agreed service to you. The legal Basis for this processing is legitimate interest.

We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication (e.g. your travel policy). The legal basis for this processing is legitimate interest.

We will accept any of the following as your consent to our existing use and future collection, use and disclosure of your personal information for the Identified Purposes – 

• The notification to you of this Privacy Protection Policy, unless you advise us that you do not agree with it and that you wish to opt out of all or specified portions of it; 
• The provision of personal information to us either directly or through your agent or representative in connection with a request for information, Travel Services or otherwise;  
• Your written or oral consent as obtained through an application process, contest entry form, survey or similar form of interaction with us including any previous consent that you may have given us; or 
• Your other actions or inactions in relation to personal information as may be regarded as consent under the Laws.     
• In terms of the Laws there may be occasions when your consent is not required or is deemed to have been given. These occasions include, without limitation, police and other investigations, enquiries relating to dispute resolution or litigation or when the personal information is publicly available.
• When you give us the personal information of other persons
• When you share with us the personal information of your travel companions or other persons for whom you are requesting information or Travel Services:   
• You consent on their behalf to the collection, use and disclosure of their personal information in terms of this Personal Information Policy; and 
• You warrant to us that you are authorised to give that consent on their behalf and indemnify and hold us harmless against any claim by such persons in which they allege that you were not so authorised.

Withdrawing Your Consent

You may withdraw your consent at any time upon reasonable notice to us. Withdrawal of your consent is however subject to legal or contractual restrictions. If the withdrawal of your consent would frustrate the performance of a legal obligation, your consent may not be withdrawn unless we have also agreed to it in writing. You should also note that withdrawing your consent may affect our ability to continue to provide you with Travel and other services. Should you wish to withdraw your consent, we will advise you at that time of the implications of such withdrawal.

To withdraw your consent you should contact us at the contact address or telephone number listed below.

How do we protect your personal information? 

Private financial and other sensitive personal information is stored by us in secure areas using physical measures such as filing cabinets that are secured after hours, alarm systems and, in the case of electronic data, in databases that are password protected. Third parties such as Suppliers to whom such information is transferred as contemplated in the above paragraph “Who will we disclose your personal information to?” are also required to protect your personal information in a manner consistent with the Laws.

Exclusion of our Liability in respect of Foreign Suppliers. 

Your particular travel or other arrangements may require the disclosure of your personal information to airlines, hotels and other Suppliers or third parties who are not subject to the Laws for residential, jurisdictional or other reasons. Foreign Suppliers may not be required to protect personal information in the same way or to the same extent as required by the Laws. Our liability for the failure of any such Foreign Supplier to protect your personal information is specifically excluded. If you have any concern about the disclosure of personal information to a Foreign Supplier you should advise us in writing well in advance of any travel reservation or other arrangement being made with or involving such Foreign Supplier on your behalf.

Data Secrecy

The Data Processor represents and warrants that they are aware of, and knows how to implement, applicable privacy rules.  The Data Processor further represents and warrants that any staff involved in the performance of work contemplated herein will be instructed in such rules and held to the duty data secrecy.

How long do we keep your personal information?

 Your personal information is retained only so long as we need it to provide information, Travel Services and other services to you, and for a reasonable length of time thereafter in order to meet any Identified Purpose or other legal or business purpose.

Cookies

A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.

Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

Cookies that we use

We do not use cookies for the performance of our services to you or your employees

Cookies used by our service providers

Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

We use Google Analytics to analyse the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://www.google.com/policies/privacy/.

Your rights in relation to the personal information we collect

With respect to our clients’ rights, we can provide a record of all data we hold upon receipt of a written request as per GDPR guidelines. We will amend any personal data held as instructed, and we will also adhere to anyone’s right to be “forgotten”.

If you wish to:

• Update, modify, delete or obtain a copy of the personal information that we hold on you; or
• Restrict or stop us from using any of the personal information which we hold on you, including by withdrawing any consent you have previously given to the processing of such information; or
• Where any personal information has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such personal information in a suitable format
• Please contact the Data Protection Officer in writing at the address set out below.

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below.

In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of personal information.

Amendments

We reserve the right to amend this GDPR Policy at any time. The Policy will be posted on our website and amendments will take effect from the date of such posting.

Our details

Our website is www.uniglobeprestige.co.uk

You can contact us:

• By email travelsolutions@uniglobeprestige.co.uk

When contacting us, we may require that certain information or requests are submitted only in writing.

Data protection officer

Our data protection officer is Louisa Morrey, contactable on the above email.