- • We collect information in order to organise your school trip, to communicate with you and supply the products or services requested as part of your trip. We also need this information to complete administrative and legal obligations as part of running your trip.
- • We don’t sell your data to other companies and we only share your data with other companies where necessary, for example, with airlines, ferries, coach companies and accommodations that are part of your trip.
- • Any personal data we collect, we process and store this information with the utmost care and security in mind. We only store your data as long as is necessary and where it's a legitimate business requirement.
- • We collect information when you voluntarily complete customer surveys, provide feedback and participate in competitions. Website usage information is collected using cookies and we may use this to help improve your online experience.
- • We may use your data to help personalise the communications we send you in order to include any preferred destinations or subjects. You have a right at any time to stop us from contacting you for marketing purposes. If you wish to unsubscribe from our marketing please email us at email@example.com
- • You have control of your data and if we hold incorrect information on you, please inform us and we will update it. You also have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please email or write to us.
1. What data we collect
- • Details about you or your party (name, email address, gender (for accommodation), date of birth, dietary requirements, height, weight, etc.)
- • Identification documents (for example, passports or identity cards)
- • Service provision (details of excursions booked through us, insurance or special assistance required)
- • Sensitive data (to provide our services, in some circumstances we may collect sensitive information relating to religious beliefs, ethnic origin, mental or physical health. For example, providing specific dietary requests can reveal religious beliefs or requesting accommodation with special facilities may reveal medical information).
- • Direct interaction (Information about interactions with us and our employees, for example enquiries, comments, complaints or feedback to us. If you are applying for a career with us, your CV, references, employment history, education and roles).
- • Your use of our systems and services (Details of the way in which you use our websites or social media pages. We may process data about your use of our website. This ‘usage data’ may include your IP address, browser type and version, geographical location, operating system, referral source, website visit length, page views and navigation paths to the website, as well as information about the timing, frequency and pattern of your service use. We source this via our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services to provide you with the very best customer experience possible.)
The information we collect about you will depend on how you interact with us and what services we are providing to you. The following list is not exhaustive but we collect information in any of the following ways:
- • When you browse our websites and/or social media pages
- • When you book or search for a tour or other service via our site
- • When you apply for a job with us by email or via the site;
- • When you contact us via our head office, social media, post, email, web chat or instant messenger;
- • When you request a brochure, sign up to receive email updates, participate in any of our promotions, surveys or market research;
- • When you provide us with information about an accident, illness or incident that occurred in connection with your booking;
- • Direct or indirect (via a 3rd party) complaints; and/or
- • When you attend any events we host, or we attend your event as requested by you.
2. The lawful bases for processing
As set out in the General Data Protection Regulation (GDPR) there are certain lawful bases for processing information. At least one of these must apply whenever we process your personal data:
- • Consent: You have given clear consent for us to process your personal data for a specific purpose (e.g. ticking a box to receive newsletters).
- • Contract: the processing is necessary for the performance of your contract with us and the provision of our services to you (e.g. collecting your address details in order to send you btrip information).
- • Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- • Legitimate interests: the processing is necessary for our legitimate interests (this means a reasonable expectation of running our business) unless there is a good reason to protect the individual’s personal data, which overrides those legitimate interests. (e.g. we may use your past booking information to send personalised offers to you. We may use your address details to send you direct marketing information by post, to inform you about products or services that might be of interest to you.)
You have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the services you have requested for your trip.
3. Why and how we use personal information
In order for us to deliver the best possible customer experience we may combine the data we collect and then use this to offer promotions on our products or services most likely to be of interest to you. The GDPR allows this (under our legitimate interest) to understand our customers and provide the best possible customer service.
We use personal information for the following purposes:
- • To manage your trip (When you enquire or book a trip with us, we use your information to provide services to you, e.g. arranging transportation, tours, accommodation, etc.)
- • To process your job application (whether directly or via a 3rd party).
- • To communicate directly with you regarding services you have requested (we need to contact you via email for administrative or operational purposes, e.g. sending booking confirmation or payments receipts).
- • To meet our legal obligations (where required, such as court orders or subpoenas, or our obligation to provide your information to border control agencies).
- • To deal with requests, via phone, online web-forms or social media channels (we use the communications you exchange with us and the feedback you give to manage our relationship with you as our customer and to better our customer services and experiences).
- • To improve a personalised customer experience (We may record calls, review digital correspondence (email, webchat) for training and for general operational purposes. We may also use personal information in order to tailor our services to your preferences, thereby providing you with an improved and more personalised customer experience. E.g. if you tell us your preferred destination, subject area or position in school, we will be able to send you communications relevant to your preferences. We may also gather data about how you use our websites, such as which of our website pages you visit most, which destinations or products you search for and what products you book, in order to understand what you like. We may use this information to tailor the content and offers that you see on our website).
- • To update you about trips linked to your preferred destination or subject area (when providing your personal information through our websites or if it is available in the public domain, e.g. on a school website, we may use this data for our legitimate business interests, which is to provide educational tours. For example, to ensure digital or postal marketing is relevant for you, determined by your transactional history, your job role or known subject or destination preferences. We will also hold information about you so that we can respect your preferences for being contacted by us. When processing personal information for our legitimate interests, we always consider any potential impact on you and your rights under data protection and other relevant laws. Our legitimate business interests do not automatically override your interests – we will 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 also choose to opt out from receiving marketing communications at any time, by clicking on the relevant unsubscribe link at the bottom of any marketing related email you may receive from us. You can also inform us of your preference not to receive marketing communications by emailing us at firstname.lastname@example.org.
- • To deal with any queries, refund requests or complaints (We may keep a record of these communications to inform any other contact we have with you and to show how we communicated to you. We do this on the basis of our legal obligations, our contractual obligations to you and our legitimate interests in providing the best customer service).
- • To complete administrative duties and ensure the security of our services, premises, employees, and customers (The use of your data can include accounting purposes, billing and audit, card payment verification, investigations, fraud deterrence, unauthorised or illegal activities, safety, security and legal purposes, statistical and marketing analysis, customer feedback requests, systems testing, maintenance and development).
4. Requesting access to your personal information
You have specific rights in respect of the personal information we hold and process about you and we fully respect your right to control your data. Your rights include:
- • Right to rectification - you are entitled to request that we correct any inaccuracies in the personal information we have about you.
- • Right to withdraw consent - you have a right to withdraw your consent, at any time, to our processing of your personal data which is based on your consent. Where you exercise this right, our processing of your personal data prior to your withdrawal of consent will remain valid.
- • Right to erasure - in certain circumstances, you have the right to request that we erase your personal data. For example, you may wish to exercise this right when your personal data is no longer necessary in relation to the purposes for which it was collected or processed by us. Please note that if we require your personal information in order to comply with a legal obligation or in connection with legal proceedings or if we store your personal information for statistical purposes, we may not be able to comply with such a request where it would impair such purposes.
- • Right to restriction – in certain circumstances, you have the right to restrict our processing of your personal information. For example, if you feel the personal information we hold about you is inaccurate. This restriction will be in place for a period to enable us to verify the accuracy of your personal data. Where you exercise your right to restrict our processing of your personal information, we will only continue processing this information with your express consent or in connection with legal proceedings or to protect the rights of other people or for reasons of important public interest.
- • Right to data portability - you have a right to receive and transfer the personal information we hold on you in a commonly used and machine readable format. Where you make such a request, we will directly transfer your personal data on your behalf to another controller of your choice (if it is feasible for us to do so).
- • Right to object to processing - In certain circumstances, you have a right to object to our processing of your personal data where we process it on the legal bases of our legitimate business interest or your consent to marketing. We may not be able to comply with such a request where we can demonstrate that there are compelling legitimate grounds for us to process your personal data which override your interests, rights and freedoms or where the processing of your personal data is required for compliance with a legal obligation or in connection with legal proceedings.
- • Right of access - you are entitled to a copy of the information we hold about you. Please note that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request. From the date that we receive ALL the required Information, we have one month in which to process your request. If the nature of the request is complex in nature or numerous, we may require an additional two months. In this instance we will contact you to explain why the extension is necessary within the first month of your request.
The Data Protection Officer
Equity Inspiring Learning Limited
5. Security of your personal data
• We constantly review our security practices to ensure we are keeping your data as safe and secure as possible. We use a number of technical, operational and physical measures to protect against unauthorised access or unlawful use.
• We may in some circumstances share your personal data to third parties where this is necessary for us to process your trip effectively. In this instance, we require that third parties have appropriate technical and organisational measures in place to protect your personal data; however in some instances we may be compelled by law to disclose your personal data to a third party, such as border control agencies, and we have limited control over how it is protected by that party.
• Your personal information may be accessed by and processed outside the European Economic Area - including by staff operating outside the EEA who work for one of our suppliers or agents (this includes staff engaged in, for example, the fulfilment of your enquiry or booking, reps, or the provision of support services). Where your personal data is transferred outside of the EEA, we require that appropriate safeguards are in place.
• We retain information for a reasonable period so that it allows us to process for our legitimate interests, for example, to exercise our legal rights or defend ourselves against claims.
6. Holding of your personal data
• For marketing purposes, to manage our relationship, personalise your customer experience, improve our services and fulfil our administrative purposes, we’ll hold onto your personal data such as name, email address, job title, details of trips taken and destination preferences.
• The personal data we request to help manage your tour booking and provide tour arrangements to you will be held for a reasonable period after your tour return date.
• All our agreements with third parties will include a provision on the process for returning and/or deleting personal data to stress the importance of not holding on to your data for longer than is necessary.
• Where we or third parties who are required to comply with legal obligations, we will hold the data for the period we/they are legally obliged to.
7. Cookies and other tracking technologies
8. Managing cookies
If you'd prefer to restrict, block or delete cookies from this website you can use your browser to do this. Visit www.aboutcookies.org to view full details of how to manage cookies on different types of web browser.
Most web browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. To find out how to manage cookies on popular browsers please visit the browser developer's website. Please note that blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
9. How we share your personal information
We may also share some of your personal information with the following types of third parties:
- • Suppliers that we contract to provide our services to you such as hotels, excursions, transport, authorities, insurance, hire companies etc.
- • Airports, immigration or border control and/or other government authorities
- • Suppliers that we contract to provide marketing services based on your consent and/or our legitimate interests
- • Courts or Advisors. We share information with other third parties (including legal, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
Where we share your information with third parties, we require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).
10. Our Details
This website is owned and operated by Equity Inspiring Learning Limited. We are registered in England and Wales, company registration number 02598164. Our registered office is at Fifth Floor, Crown House, 21 Upper North Street, Brighton, BN1 3FG. You can contact us:
- • by post, using the postal address given above;
- • using our website contact form;
- • by telephone, on the contact number published on our website; or
- • by email, using the email address published on our website.
Dated: 10th June 2019