This Privacy Policy has been defined by TourCompass Ltd. (collectively referred to as “TourCompass Ltd.”, “we”, “us” or “our” in this Privacy Policy) and applies to all our customers, suppliers and partners.
1. Introduction
As part of our business, TourCompass Ltd. collects and processes personal data for the purposes described in this Privacy Policy. TourCompass Ltd. is data controller with regard to the processing of personal data for these purposes.
When we use terms such as “personal data”, “controller”, “transfer” and “legitimate interests”, they take their meaning from the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
If you have any questions about this Privacy Policy or our processing of your personal data, please contact us here:
TourCompass Ltd.
Endeavour House, 3rd Floor
Coopers End Road
Stansted
CM24 1SJ
E-mail: info@tourcompass.co.uk
2. Data security is important to us
For us, responsible handling of personal data collected in connection with the operation of our business is crucial to our business goals and reputation. This Privacy Policy explains how your personal data is collected and used when you are a customer, supplier or partner of TourCompass Ltd. and how you can gain access to your personal data.
3. What is personal data?
Personal data is any information relating to an identified or identifiable natural person. By “identifiable natural person” we mean a person who can be identified, directly or indirectly, among other things by an identification number or one or more factors specific to that person’s identity.
4. What kind of personal data do we process about you and why?
The information we collect about you will be used for various purposes in connection with your customer relationship and the operation of TourCompass Ltd.’s business. The information collected may vary depending on whether you are a customer, supplier or partner, but it will generally be information regarding customer administration, supplier administration, and information regarding TourCompass Ltd.’s rights and obligations.
Failure to provide personal data on your part may mean that TourCompass Ltd. will be unable to fulfil its obligations in connection with your customer or supplier relationship.
TourCompass Ltd. only collects and processes ordinary personal data. However, in specific cases when booking a holiday, it may be necessary for us to process what is known as “special category data”, or “sensitive personal data” (e.g. information about special dietary requirements on your flight or information about the need for special assistance on your holiday), as well as your passport details (e.g. in connection with obtaining a copy of your passport for use for a visa application) in order to organise the desired holiday for you.
TourCompass Ltd. will typically collect the following information:
4.1 Information about our customers
Information provided by you when you book a holiday or create a travel profile with us, e.g. online via the website or when you contact our customer service, including contact details (first name, middle name(s), last name, address, telephone number, e-mail address and job title, if relevant), passport number (for visa applications, local tours), bank details, credit card information, information that you give us in relation to your special preferences on the holiday (e.g. information regarding dietary requirements, the need for special assistance in connection with disability or illness, etc.), health information (for use for treatment holidays, sports holidays, etc.), information about height, weight, clothes and shoe size (for use when booking equipment for skiing holidays, sports holidays, etc.), the purpose of the holiday, information about which languages you speak, citizenship, bonus card numbers, contact details of your next of kin, information that you give us about your preferences in relation to marketing or communication, as well as information you provide if you contact us with a question or to report a problem or when you contact us in connection with your customer relationship with us.
4.2 Information about our suppliers and partners
Information you provide in connection with the conclusion of a supply or cooperation agreement, including contact details (work, job title, first name, middle name(s), last name, address, telephone number and e-mail address), information you provide about your preferences in relation to marketing or communication, as well as information you provide if you contact us with a question or to report a problem, or when you contact us as part of our cooperation.
5. What do we use your personal data for?
TourCompass Ltd. processes your personal data for the purposes listed below. Please note that not all of the stated purposes, categories of information, recipients of information or types of data processing apply to you in all cases.
TourCompass Ltd. only processes your personal data to the extent necessary for your customer, supplier or partner relationship (taking into account any interests in each case) or under applicable law.
5.1 Customer management
TourCompass Ltd. processes your personal data in connection with the creation and ongoing management of your customer relationship with TourCompass Ltd. as part of the operation of our company, including the booking of holidays and the supply of our other products (such as visa applications, travel insurance, transfer services, etc.), maintenance of our customer records, billing, debt collection, marketing, statistics, etc. All statistics and analyses are prepared in anonymous format and do not therefore contain information that can be directly ascribed to you as a person.
5.2 Management of supplier and partner relationships
TourCompass Ltd. processes your personal data in connection with the management of supplier and/or partner relationships where you are a supplier or partner, or the contact person of a supplier or partner that TourCompass Ltd. cooperates with in the operation of our company, including maintenance of our CRM register with information about our suppliers’ and partners’ contacts.
5.3 Email Newsletters
On our website, and other marketing platforms, we offer the opportunity to subscribe to our newsletter. When you sign up, we ensure that you are fully informed about the content and purpose of the newsletter. It is important to us that you explicitly give your consent by accepting our terms before the subscription becomes valid. To enhance the level of security, we send a confirmation email that requires your approval. This step helps to ensure that it is indeed you behind the specified email address.
You have the right to withdraw your consent at any time. This can be done easily and conveniently by clicking on the ‘unsubscribe from newsletter’ link found in all the newsletters we send out, or by directly contacting us.
Upon signing up, we register information such as your name, your email address, and any specific preferences you indicate. These details are stored carefully and used only as long as you subscribe to the newsletter. Should you choose to unsubscribe, we will delete your information 12 months after the date of unsubscription. Should you wish to have your information deleted before this deadline, you are always welcome to contact us.
5.4 Compliance with applicable laws and regulations
TourCompass Ltd. processes your personal data in compliance with laws and regulations that TourCompass Ltd. is subject to in connection with the operation of the company or to fulfil various reporting or disclosure obligations in accordance with applicable laws and regulations.
TourCompass Ltd. does not use your personal data to make decisions based solely on automatic processing, including profiling.
TourCompass Ltd. strives to ensure that all personal data we process is correct and up to date. We therefore ask you to notify us of any changes to your personal circumstances (e.g. change of address or payment details) so that we can ensure that your personal data is always correct and up to date.
6. Lawful bases for processing your personal data
As a rule, TourCompass Ltd. processes the information about you on one of the following bases: (1) Your consent, (2) conclusion or performance of your contract with TourCompass Ltd., (3) for the purposes of TourCompass Ltd.’s legitimate interests, i.e. the purposes described above, (4) compliance with a legal obligation that TourCompass Ltd. is subject to, (5) protection of your or any other natural person’s vital interests, (6) processing is necessary for establishing, exercising or defending legal rights, and (7) processing is required to comply with TourCompass Ltd.’s or your labour, health and social law obligations under national or EU law. There may, in addition, be situations where we process your personal data on grounds of the legitimate interests of a third party with regard to the purposes described above, unless your interests carry greater weight.
7. Sharing personal data
TourCompass Ltd. only discloses information to the extent necessary for the operation of our business, including to supply your holiday and the other products you have purchased from us in connection therewith.
TourCompass Ltd. will typically disclose personal data to the following recipients in connection with the booking of a holiday and related products:
7.1 Global Distribution Systems (GDS)
A GDS is an IT network system owned or operated by a company that enables transactions between the travel industry’s service providers, mainly airlines, hotels, car rental companies and travel agents. A GDS connects services, prices and booking by consolidating products across the three travel sectors, i.e. flight reservations, hotel reservations and car rental.
TourCompass Ltd. uses the following GDSs as part of our business: Amadeus
7.2 Airlines
TourCompass Ltd. discloses personal data to airlines when booking your holiday. For the purpose of booking your flight, we will typically provide information about your first name, middle name(s), surname, departure airport, destination, departure and return date, bonus card number, special wishes in connection with your holiday, including special dietary requirements during the flight and the need for special assistance on the aircraft or at the airport of the given airline.
In connection with travel to special destinations, we may also disclose your passport number to the airline. We also disclose telephone numbers to some airlines for the purposes of their customer management.
7.3 Hotels
TourCompass Ltd. discloses personal data to the hotels you will be staying at on your holiday. For the purpose of booking your hotel accommodation, we will typically provide information about your first name, middle name(s), surname, destination, departure and return date, room category, bonus card number, special wishes in connection with your holiday, including special dietary requirements during your stay at the hotel and the need for special assistance during your stay due to disability or illness.
7.4 Car rental companies
TourCompass Ltd. discloses personal data to car rental companies if you will require a vehicle during your holiday. For the purpose of booking your rental car, we will typically provide information about your first name, middle name(s), surname, pick-up location, rental period, vehicle category, bonus card number, special wishes in connection with the rental of the vehicle, including special requests relating to disability or illness, child seats, etc.
7.5 Coach operators
TourCompass Ltd. discloses personal data to coach operators if you will be travelling by bus as part of your holiday (e.g. for day trips to well-known tourist attractions, etc.). For the purpose of booking your bus trip, we will typically provide information about your first name, middle name(s), surname, pick-up spot, date and time of bus trip, destination and any special wishes in connection with the bus trip, including special dietary requirements during the bus trip and the need for special assistance during the trip due to disability or illness.
7.6 Shipping companies
TourCompass Ltd. discloses personal data to shipping companies if you will be travelling by boat as part of your holiday (e.g. for day trips to well-known tourist attractions, cruises, etc.). For the purpose of booking your boat trip, we will typically provide information about your first name, middle name(s), surname, destination, route, departure and return date and time, and special wishes in connection with your boat trip, including special dietary requirements during your trip and the need for special assistance during the trip due to disability or illness.
7.7 Bedbanks
A bedbank is an IT network system owned or operated by a company that enables transactions between the travel industry’s service providers, mainly hotels and travel agents or the end customer. TourCompass Ltd. discloses personal data to bedbanks to book the hotels you will be staying at on your holiday. For the purpose of booking your hotel accommodation through a bedbank, we will typically provide information about your first name, middle name(s), surname, destination, departure and return date, room category, bonus card number, special wishes in connection with your holiday, including special dietary requirements during your stay at the hotel and the need for special assistance during your stay due to disability or illness.
7.8 Travel agents
If you will be participating in excursions or you need a transfer on your holiday, TourCompass Ltd. may disclose personal data to travel agents. The travel agent is responsible for arranging the excursion or transfer by booking the desired services with local suppliers at the destination. For the purpose of booking your excursions, transfers, etc., we will typically provide information about your first name, middle name(s), surname, date and time of arrival and/or departure, type of vehicle, destination and any special wishes in connection with the transfer or excursion, including special dietary requirements and the need for special assistance due to disability or illness.
7.9 Insurance companies
When you book your holiday with us, you have the option to purchase travel and/or cancellation insurance. If you wish to purchase such insurance, we will disclose personal data to the insurance company to enable them to underwrite the insurance policy. For the purpose of taking out travel and/or cancellation insurance, we typically provide information to the insurance company about your first name, middle name(s), last name, e-mail address, destination, departure and return date, and type of holiday.
7.10 Equipment rental companies
As part of booking your holiday with us, you will be able to rent any equipment you may need on your holiday, e.g. skiing equipment, diving equipment and the like. If you wish to rent such equipment, we will disclose your details to the company at your destination through whom you will be renting the equipment. For use in connection with equipment rental, we typically provide information to the rental company about your first name, middle name(s), surname, type of equipment, pick-up location, rental period and information about your height, weight, clothes and shoe size.
7.11 Qualified offers
When you choose TourCompass Ltd., we give you the option of a qualified offer on a holiday. A qualified offer is a form of offer whereby a preliminary booking of the desired holiday is made when the offer is prepared. This allows you to reserve a place on the desired departures before deciding whether a ticket should be issued for the preliminary reservation or whether it should be cancelled.
In order to provide a qualified offer, we disclose information about you and the desired reservation to a GDS (as mentioned above), which makes the preliminary booking with the airline, hotel, etc.
As information about you is disclosed to several new independent data controllers (GDS, airlines, hotels, etc.) in connection with obtaining the qualifying offer, your information may be retained by these recipients after expiration of the offer – even in the event that the offer is cancelled.
TourCompass Ltd. may, in addition, disclose and/or transfer your personal data to other suppliers and/or service providers in connection with the normal operation of our company, for example in connection with external administration of our IT systems, analyses, marketing projects, debt collection, credit rating, auditing, legal assistance, etc.
For further information about our suppliers and partners’ processing and protection of your personal data, please refer to their privacy policies and terms.
TourCompass Ltd. endeavours to limit to the extent possible the disclosure of personal data in personally identifiable format to limit the cases where information ascribable to you personally is disclosed.
TourCompass Ltd. will not disclose your personal data unless necessary to perform our business or meet your needs or if we are required to disclose such information by law
8. International transfers of your personal data
Due to the nature of TourCompass Ltd.’ business, your personal data may be transferred to countries outside the UK when booking a holiday with us. In order to be able to provide our services to you, we are in some cases required to use partners and suppliers outside the UK.
Without the possibility of transferring your information to recipients outside the UK, TourCompass Ltd. would be unable to supply the desired holiday to you. This applies if the booking of your holiday requires that information is sent to recipients outside the UK for the purpose of booking flights, hotels, etc. at your travel destination.
Data protection legislation in these countries will differ from that in the UK. In some cases, for instance in respect of the EU/EEA, the UK has assessed the level of protection as adequate, and this means that we can transfer personal data to those countries without having to enter into any special arrangements. But in other cases, no such “adequacy” assessment exists.
Where that is the case, in most cases the transfer of your personal data will be based on the standard contractual clauses agreed by the UK.
However, in certain cases, it will not be practically possible for TourCompass Ltd. to enter into standard contractual clauses as a legal transfer basis. In such cases, the transfer of the data will be carried out pursuant to Article 49 1(b) of the UK GDPR, as the transfer of your personal data to the country concerned is necessary for the purpose of fulfilling the contract between you and TourCompass Ltd. (the booking of your holiday) or for the purpose of implementing measures taken at your request prior to the conclusion of such a contract (e.g. in connection with the submission of a qualified offer as mentioned above under section 7).
If you do not want TourCompass Ltd. to send your personal data to recipients outside the UK when booking your holiday(s), please inform us of this when booking your trip. However, we may not be able to meet all of your requirements if this is the case.
TourCompass Ltd. does not, in any event, disclose your personal data to recipients outside the UK unless necessary to perform our business or meet your needs, e.g. supplying you with the desired holiday unless we are required to do so by law.
9. Data integrity and security
Personal data is retained for no longer than necessary to fulfil the purpose for which it has been collected unless the retention is required to comply with national legal requirements, including statutory retention periods in connection with accounting, etc.
It is TourCompass Ltd.’s obligation to protect personal data by taking adequate technical and organisational security precautions. When your personal data is no longer required, we will ensure that it is deleted in a secure manner.
10. Your rights
Under current data protection law, you have the right to exercise your rights at any time. You may, for example, request access to the personal data that TourCompass Ltd. holds on you and object to the processing of the information. Additionally, you may request correction or deletion of any incorrect information about you, withdraw consent for the processing of your personal data, and request to exercise your right to data portability.
If you wish to exercise one or more of your rights, please contact us at info@tourcompass.co.uk. Your request will be treated in accordance with the data protection legislation currently in force.
Complaints regarding TourCompass Ltd.s’ processing of your personal data can be made to:
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Website www.ico.org.uk
11. Updates
TourCompass Ltd. continuously evaluates and updates this Privacy Policy. You should therefore check this Privacy Policy on a regular basis for any changes that may affect the way we process your personal data.
12. Cookies
