GDPR - Level 4

Our Website - B2C eCommerce - Online Services - Single controller Policy 

About Us
This Privacy Notice relates to the personal data you give over this website and other data we collect. We are the data controller named in the Contact Us section. We also trade as Barbados Luxury Travel. We share some or all of your personal data with other businesses. Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements. The following is a list of other parties we use and share your data with:
  • TTNG – Bonding Company 
  • Coldwell Compton Accountant – Accounting Services
  • Facebook, Instagram, Twitter - Social Media Platforms 
  • Microsoft 365 - Cloud and email solutions provider
  • Active IT – IT company
The Personal Data we collect from you
We collect the personal data you provide us when you fill in the blanks in the website forms. A full list can be found clicking this link.

We also collect the following personal data from you:

- the details of other services or products you order from us online and aggregate your orders to manage your account
- information you provide when you telephone us about your order, ask any questions, make a complaint or any other reason
- the information you put in any emails to us for any reason including your email address
- information you provide when you text us about your order, ask any questions, make a complaint or any other reason
- information you provide when you whatsapp us about your order, ask any questions, make a complaint or any other reason
- information you provide face to face when we meet you to discuss your order, ask any questions, make a complaint or any other reason
- information you provide when you contact us on social media about your order, ask any questions, make a complaint or any other reason

We use cookies to improve the performance of our site and give you the best experience we can. Cookies are small files, placed onto your device's memory, or hard drive when visiting most websites. They help the site 'remember' if you've been there previously. In some cases it means it can put on screen things of interest to you. We use cookies for these types of activity: Experience - to track visitors on our website (where they've come from, how long they stay and what they look at when on our site). Security - to protect your personal data and prevent fraudulent activity. Choices - during our signup process these allow you to choose and order our services. Marketing - to see how our campaigns are working. This helps us improve our website design, experience and offers. Information - We use third parties to collect anonymous user information, sometimes through cookies and web beacons. Video - Flash cookies which assist media player functionality without which some video content may not render correctly. Note: Our cookies don't store financial information, or personal details, e.g. your name or address. You can turn cookies off but if you do this you may not be able to use all services on our websites and you might see more pop-ups and other intrusive advertising, as we won't be able to limit what you see using cookies. You may be able to use some of the site. Some of the cookies are set by business partners (e.g. analytics companies) to track and collect browsing behaviour Others are used to show specific content to you. (We don't control how these cookies are set). If you register for our website, turning off cookies will mean you cannot use this service.

The PreContract Checks we do
We use your personal data to carry out the following types of searches or checks which will involve us obtaining information from the relevant agencies or providers of that data):

We make age checks to ensure that you are over the age of 18 years as we do not wish to collect the personal data of anyone under that age in relation to these products and these uses. We take are legally obliged to check our obligations seriously and do not intend or seek to provide these products to children. If you are under 16 years and accidentally are allowed to acquire these products contact us immediately on the number below.

We do age checks to ensure you are over the age of 14 years as we do not wish to obtain personal data of anyone under this age for these products. Where you are under 16 years of age you must provide parental consent. We will not display the personal data of anyone under 16 years of age without specific written parental consent and subject to safeguards. To ensure any content remains age appropriate we may monitor and moderate any information. If there are any concerns please contact us immediately on the Child Helpline number 0151 342 7080. This is in our legitimate interest and contractually necessary.

We are legally obliged to use it to identify and prevent money laundering unless you can provide us with other acceptable proof of identity. Law enforcement bodies may use this information. Details of the agencies we use are available by writing to us. The agency may charge you a fee to obtain a copy of the information they hold on you.

We need to check your legal identification documents in order to prevent fraud, terrorism and other issues. We need this for contractual purposes, and for the legitimate interest of protecting the public, the financial system and society.

Using your data to fulfil the Contract
To fulfil the contract we use your data to decide whether to enter the contract, allocate you goods, manage and track your order, update you on progress, generate delivery notes and invoices, process payments and administration generally. We may have to use third parties to help us achieve these aims in accordance with our legitimate interests (see below).

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements.

Sharing with others to deliver the contract and for legitimate interests
To help us fulfil the contract we share your data with these parties for the reasons below as it is in our legitimate interests to do so having taken into account all relevant factors around your privacy. If we do not engage these external contractors our prices would have to increase as we would have to engage more staff and buy more infrastructure. We require them to be GDPR compliant and enter data processor contracts with us or ensure their contracts make appropriate statements.

We share data with the party (introducer, affiliate, reseller, agent or other relationship) who you ordered our Service through and they may be one of a number we deal with and/or may change from time to time. You will know who they are at the time you order via their website or other method.

We use an external payment processor on the site to process your payment. 

We share data with the third party we order the Services from to match to your order, and to track their supply to us and, if they also organise delivery to you the fact of such delivery.

Our external email provider processes all our incoming and outgoing emails. Email is how we confirm and manage your order, manage the security of access and passwords on your account and deal with any enquiries and complaints.

We (and third parties under contract with us) use customer contact information to personalise the types of information you receive from us, to determine customer satisfaction with products and/or services we have provided and to improve the operation of our services to you.

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements. The following is a list of other parties we use and share your data with:
  • TTNG – Bonding Company 
  • Coldwell Compton Accountant – Accounting Services
  • Facebook, Instagram, Twitter - Social Media Platforms 
  • Microsoft 365 - Cloud and email solutions provider
  • Active IT – IT company
This may change from time to time so if you continue to use us or keep in contact with us you will be dealing with us on our updated Privacy Notice. We will endeavour to notify you of any changes but this may not be possible. We will set out on our current Privacy Notice the date it came into force.

Who else we share your personal data with for legitimate interest reasons
We share your personal data with the following parties for reasons of legitimate interest:

- we use an outside party to bill and collect who are acting as our data processor. They will identify themselves to you as acting on our behalf but if you have any concerns about their activity or behaviours please contact us.
- we use agents, advisers or others involved in running accounts and services for you and your business or collecting what you or your business owe; 
- we use Third party vendors who help us to manage and maintain the IT infrastructure, website, shopping cart or payment services; 
- we use professional advisors, such as lawyers, accountants, debt collectors and consultants; 
- we use Companies who assess faults and repair products on our behalf; 

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements. The following is a list of other parties we use and share your data with:
  • TTNG – Bonding Company 
  • Coldwell Compton Accountant – Accounting Services
  • Facebook, Instagram, Twitter - Social Media Platforms 
  • Microsoft 365 - Cloud and email solutions provider
  • Active IT – IT company
Cookie Policy
You can adjust your cookies preferences using the cookies control at the bottom of the website.

We use online behavioural advertising (OBA) which allows us to deliver targeted advertising to visitors. As you browse our site, some of the cookies used are advertising cookies, so we can understand what sort of pages you are interested in. It then generates adverts which we believe may interest you based on your use of our site. The OBA techniques we use will not collect personal information such as your name, email address, postal address or phone number. We may also share anonymised behavioural data with advertising partners. This may mean that when you are on other websites, you will be shown advertising based on your behaviour on our website. We may also show you advertising on our site based on your behaviour on other sites you have visited and where you appear to have given permission. This is known as Behavioural retargeting and is another form of OBA that allows us and some of our advertising partners to show you ads based on your browsing patterns and interactions with other sites. You can opt out of this form of marketing, but you will still see adverts when you visit our site, they just will not be personal for you

Special Category Data
We collect Sensitive or Special Category Personal data of the type set out below and the reasons for its necessity:

- about your mental and/or physical health. We need this information so we can provide you with the relevant and appropriate arrangements for your individual travel needs subject to availability. If you are unable to give your consent we will not be able to fulfil your holiday requirements with regards to any specific physical needs. 
- your religious or other beliefs. We need this information so we can provide you with the relevant and appropriate arrangements for your individual travel needs subject to availability. If you are unable to give your consent we will not be able to fulfil your holiday requirements with regards to any specific religious needs.
- your sex life or gender orientation. We need this information so we can provide you with the relevant and appropriate arrangements for your individual travel needs subject to availability. If you are unable to give your consent we will not be able to fulfil your holiday requirements with regards to any specific sexual or gender orientation needs.

We require these details in order to ensure we provide you with the correct goods ordered.

We may also pass it to outside businesses and others to help fulfil the contract, deliver services and other reasons consistent with this Privacy Notice and others.
We may also need to provide it to other firms who provide us with services (such as an IT management firm) to keep our systems running and other services we need. We will take our normal commercial measures to keep your data safe. We will ensure that these parties only process your personal data in accordance with our express instructions.

Adding Data Together
In order to help us to be efficient with the personal data we have about you we will combine the data we get from the following sources or interactions with you or third parties:

- any paper based documents you have or do provide us with
- data you provide over the telephone (including any text or other messages),
- data you provide over text
- data you provide over whatsapp
- data you provide over social media
- data you provide in person
- data you provide over email

Retention of Data
We will keep your data for 7 years after the year you order it so we can comply with contract law issues, product liability issues, insurance issues, company law obligations, record keeping for accounting and tax audits. If there are any compliants or questions on product liability or insurance issues we will keep your data for 6 years after the matter is dealt with. We may hold onto data were there are legal reasons to retain it.

Where we process your personal data to fulfil:

- a contract with you, we will process such personal data until we fulfil that contract and for so long thereafter as may be necessary to keep a record of that contract, which will typically be for 6 years, and to deal with any complaints or claims relating to that contract, which will be until the final resolution of such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or
- a legal obligation (such as anti-Money Laundering, tax and accounting obligations), we will process such personal data for so long as necessary to fulfil that obligation; or
Where we process your personal data based on: 
- our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or
-your consent, for example, to send you marketing information, we will process such personal data until you withdraw that consent. Please bear in mind that it may take a short time to process any withdrawal of your consent. We aim to do this as soon as reasonable after receipt of your request, although you may still receive emails that are already in process around the time of your withdrawal. 

Marketing
Where you have given consent to market you we will send you our marketing and promotional materials for services, products, surveys, competitions, events and other activities we think useful to you.

- by telephone to the numbers provided. We ask that you notify us of any changes to your numbers.
- by text or picture message. Please help us by telling us of any changes to your numbers so we can keep our records up to date and deliver you the relevant service.
- by email. We may promote our goods and services to you by email until you unsubscribe. The unsubscribe option will be present in any marketing email we send. We may send you our marketing by email as you have bought goods from us.
Where permitted we may market you with the products of carefully selected third parties. 

International Data Transfers
When we send your personal data to a country out of the EU, Iceland, Norway, Lichtenstein, Andorra, Argentina, Canada (commercial organisations), Faeroe Islands, Guernsey, Israel, Isle of Man, Jersey, New Zealand, Switzerland and Uruguay or it may have a lower legal standard of data protection to our country. Where this is the case we ensure we put in place measures to ensure a similar standard to that we require at home.

If any party we use to process or share your data with is based in a country not deemed to have adequate data protection laws we make sure that they apply appropriate security processes to keep it secure.

Your rights regarding your personal information
Data privacy laws provide you with a number of rights over your personal information. 

You may be entitled to: 

ask us for access to the personal information we hold about you; 

request the correction and/or deletion of your personal information; 

request the restriction of the processing of your personal information, or object to that processing; 

withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent); 

request for the receipt or the transfer to another organisation, in a machine-readable form, of the personal information that you have provided to us; and
complain to your local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information. 

If you would like to exercise your rights, please let us know by getting in touch with us as set out in the Contact us section below. 

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.

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. 

Contact Us
If you have any questions please contact us: 
By filling out the contact us form.
By email: info@luxuryleisuretravel.co.uk
Call: 07768740219 
By Postal address: 94 Downham Road South, Heswall, Wirral, CH60 5SE
You can contact Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113 Fax: 01625 5245

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