Welcome to The Travelway Limited’s privacy notice.
Travelway Limited respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) in order to purchase travel arrangements from us. It will also inform you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below. Alternatively, you can download a PDF version of the policy here.
Please also refer to the Glossary that we have set out at the end of the policy if there is any terminology used in this privacy notice that you are unfamiliar with or do not fully understand.
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. HOW WE DISCLOSE YOUR PERSONAL DATA
6. WHEN WE TRANSFER YOUR DATA OVERSEAS
7. HOW WE SECURE YOUR DATA
8. HOW LONG WE RETAIN YOUR DATA FOR
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. Important Information and Who We Are
Purpose of This Privacy Notice
This privacy notice aims to give you information on how Travelway collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you book travel arrangements with us, sign up for our newsletter, take part in a competition, fill out an online customer service request form, use our online Live Chat function, register an online account with us, or contact us via social media channels, etc.
This website is not intended for children, and the only circumstances in which we collect data relating to children are when you make a booking for travel services and you have children in your party.
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 and is not intended to override them.
Controller
Travelway Limited is the controller and is responsible for your personal data, a company registered in England & Wales with company registration number 4512846 and a registered office address of Office No. 14, Rockware Business Centre, 5 Rockware Ave, Greenford, UB6 0AA. Travelway Limited is the data controller and is responsible for your personal data (collectively referred to as "Travelway," "we," "us," or "our" in this privacy notice).
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: Travelway Limited
Name of Data Privacy Manager: Abdirahman Osman
Email address: info@travelwayltd.com
Postal address: Office No. 14, Rockware Business Centre, 5 Rockware Ave, Greenford, UB6 0AA
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 (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 version was last updated in October 2024, and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us change during your relationship with us.
Changes to the Privacy Notice, Third-Party Links, and Your Duty to Inform Us of Changes
This 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 and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website 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 (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you, which we have grouped together as follows:
(A) Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, and gender.
(B) Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address, and telephone numbers.
(C) Financial Data
This includes data relating to your means and methods of payment, such as your bank account and payment card details.
(D) Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
(E) Technical Data
This includes more technical data that we may obtain when you use our website, such as your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
(F) Usage Data
This includes information about how you use our website, products, and services.
(G) Marketing and Communications Data
This includes your preferences regarding whether or not you want to receive marketing from us and our third parties, as well as your communication preferences.
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. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data, which will be used in accordance with this privacy notice.
Special Categories of Personal Data
We may collect the following special categories of personal data about you:
• Details about your dietary requirements, which may disclose your religious or philosophical beliefs.
• Health information.
We collect and process the above data only where it is strictly necessary to deliver the travel arrangements that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data if you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we will not be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.
If you consent to our use of your sensitive personal data, you may withdraw your consent at any time. However, please be aware that this will prevent us from providing the travel arrangements you have booked. We will treat any withdrawal of consent as a cancellation of your booking, and the cancellation charges in the relevant Booking Terms & Conditions will become payable.
If You Fail to Provide Personal Data
Where we need to collect personal data by law or under the terms of a contract, we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.
In other words, if we require details from you to provide your chosen travel arrangements and you do not provide us with the necessary details, we will not be able to provide the services you have booked or are attempting to book.
In this case, depending on when you fail to provide the necessary data, we may either be unable to process your booking or may have to cancel your booking. In such a situation, we will treat this as a "cancellation by you" in accordance with the relevant Booking Terms & Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.
3. How Your Personal Data is Collected
We use different methods to collect data from and about you, including through:
(A) Direct Interactions
You may give us your Identity, Contact, and Financial Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
• Make a booking for travel arrangements.
• Request a quote for travel arrangements.
• Request marketing to be sent to you.
• Enter a competition, promotion, or survey.
• Provide us with feedback.
(B) Automated Technologies or Interactions
As you interact with our 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 here for further details.
(C) Third Parties
We may receive personal data about you from various third parties, as set out below:
• Technical Data from the following parties:
i) Advertising networks such as Facebook based outside the EU;
ii) Search information providers such as Google and Bing based outside the EU.
• Contact, Financial, and Transaction Data from providers of technical, payment, and delivery services such as Barclaycard and Ingenico based inside the EU.
• Identity, Contact, Financial, and Transaction Data from our retail travel agents based within the United Kingdom.
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the EU.
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 we need to perform the contract we are about to enter into or have entered into with you.
• 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, except in relation to sending direct marketing communications to you via email or text message. 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, along with the legal bases we rely on to do so. We have also identified our legitimate interests 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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of Data Lawful Basis for Processing Including Basis of Legitimate Interest
To register you as a new customer. (a) Identity; (b) Contact. Performance of a contract with you.
To process and deliver your booking, including: (a) Manage payments, fees, and charges; (b) Collect and recover money owed to us. (a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications. (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you, which will include: (a) Notifying you about changes to our terms or privacy policy; (b) Asking you to leave a review or take a survey. (a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications. (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
To enable you to partake in a prize draw, competition, or complete a survey. (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications. (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, and to grow our business).
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data). (a) Identity; (b) Contact; (c) Technical. (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud, and in the context of a business reorganization or group restructuring exercise); (b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications; (f) Technical. Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business, and to inform our marketing strategy).
To use data analytics to improve our website, products/services, marketing, customer relationships, and experiences. (a) Technical; (b) Usage. Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business, and to inform our marketing strategy).
To make suggestions and recommendations to you about goods or services that may be of interest to you. (a) Identity; (b) Contact; (c) Technical; (d) Usage; (e) Profile. Necessary for our legitimate interests (to develop our products/services and grow our business).
Marketing
We strive to provide you with choices regarding certain uses of your personal data, particularly in relation to marketing and advertising. To help you manage your data, we have established the following personal data control mechanisms:
Promotional Offers from Us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what products, services, or offers may be relevant to you. This is how we determine what might be of interest to you (referred to as marketing).
Third-Party Marketing
We will obtain your explicit opt-in consent before sharing your personal data with any company outside the Southall Travel group of companies for marketing purposes.
Opting Out
You can ask us, or third parties, to stop sending you marketing messages at any time by following the opt-out links on any marketing messages you receive, or by contacting us directly.
Please note that opting out of marketing messages will not affect the processing of personal data you have provided to us in the context of a purchase of travel services or other transactions.
Cookies
You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or may not function properly.
Change of Purpose
We will only use your personal data for the purposes for which it was collected, unless we reasonably consider that we need to use it for another purpose that is compatible with the original one. If you would like an explanation as to how processing for a 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 explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law, and in compliance with the relevant legal rules.
5. Disclosures of Your Personal Data
We may need to share your personal data with the parties listed below for the purposes outlined in paragraph 4 above:
• Internal Third Parties, as described in the Glossary.
• External Third Parties, as described in the Glossary.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens within our business, the new owners may use your personal data in the same manner as outlined in this privacy notice.
We require all third parties to respect the security of your personal data and to handle it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes. They are only permitted to process your personal data for specified purposes and in line with our instructions.
6. International Transfers
Many of our external third parties are based outside the EEA, meaning their processing of your personal data will involve transferring data outside the EEA.
Where you have requested a booking for travel arrangements located or fulfilled outside the EEA, we will need to transfer your personal data to the suppliers fulfilling those arrangements in order to process your booking. In cases where we cannot rely on the safeguards outlined below when transferring data to suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR, as the transfer relates to the performance of a contract for your benefit. By requesting these services, you permit us to make such transfers. You also acknowledge that data protection controls in non-EEA countries may not be as comprehensive as the legal requirements within the EEA.
For other transfers, when your personal data is transferred outside the EEA, we ensure a similar degree of protection by implementing at least one of the following safeguards:
• We will only transfer your personal data to countries that have been deemed by the European Commission to provide an adequate level of data protection. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use specific service providers, we may employ contracts approved by the European Commission, which guarantee the same level of data protection as within Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• When using providers based in the US, we may transfer data to them if they are part of the Privacy Shield, which requires them to offer a similar level of protection for data shared between Europe and the US. For more details, see European Commission: EU-US Privacy Shield.
Please contact us if you would like further information about the specific mechanisms we use when transferring your personal data outside the EEA.
7. Data Security
We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, accessed, altered, or disclosed in an unauthorised way. Access to your personal data is restricted to employees, agents, contractors, and third parties who have a legitimate business need to know. They will only process your data in accordance with our instructions and are bound by a duty of confidentiality.
We have established procedures to handle any suspected personal data breaches. In the event of a breach, we will notify you and any applicable regulators as required by law.
8. Data Retention
How long will you use my personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting obligations.
To determine the appropriate retention period for personal data, we consider several factors: the amount, nature, and sensitivity of the data, the risk of harm from unauthorised use or disclosure, the purposes for processing, and whether those purposes can be achieved through other means. We also take into account any applicable legal requirements.
By law, we are required to keep basic customer information (including Contact, Identity, Financial, and Transaction Data) for seven years after customers cease their relationship with us, for legal and tax purposes.
In some instances, you may request that we delete your data. See the "Request Erasure" section below for more details. Additionally, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. In such cases, we may use this information indefinitely without further notice to you.
9. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Below is a summary of those rights:
• Request access to your personal data (commonly known as a "data subject access request"). This allows you to receive a copy of the personal data we hold about you and ensure that we are lawfully processing it.
• Request correction of the personal data we hold about you. You can ask us to correct any incomplete or inaccurate data, though we may need to verify the accuracy of any new data you provide.
• Request erasure of your personal data. You can ask us to delete or remove personal data where there is no valid reason for us to continue processing it. You can also request erasure where you have successfully exercised your right to object to processing, or if we have processed your data unlawfully or must erase your personal data to comply with local laws. However, we may not always be able to fulfil your request for legal reasons, which we will explain 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 specific to your situation that makes you wish to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may be able to demonstrate compelling legitimate grounds for processing that override your rights and freedoms.
• Request restriction of processing of your personal data. This allows you to ask us to suspend the processing of your personal data in certain scenarios, such as:
o When you want us to verify the data's accuracy;
o Where our use of the data is unlawful, but you do not want us to erase it;
o When you need us to retain the data even if we no longer require it, as you need it to establish, exercise, or defend legal claims; or
o When you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to continue using it.
• Request the transfer of your personal data to you or a third party. We will provide your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where the data was used to fulfil a contract with you.
• Withdraw consent at any time, where we rely on consent to process your personal data. This will not affect the legality of any processing carried out before your consent was withdrawn. If you withdraw consent, we may not be able to provide certain products or services to you. We will advise you if this is the case when you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
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 unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request under such circumstances.
What we may need from you
We may need to request specific information to 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 anyone who does not have the right to access it. We may also contact you for further information to expedite our response.
Time limit to respond
We aim to respond to all legitimate requests within one month. In cases where your request is particularly complex, or if you have made multiple requests, we may take longer. If this happens, we will notify you and keep you updated.
10. Glossary
Lawful Basis
• Legitimate Interest:
This refers to the interest of our business in conducting and managing our operations to provide you with the best service in the most secure way. We always assess and balance any potential impact on you (positive or negative) and your rights before processing your personal data for our legitimate interests. We do not process your personal data for activities where your interests override ours, unless we have your consent or are required/permitted by law. You can request further details on how we balance legitimate interests against potential impacts by contacting us.
• Performance of Contract:
Processing your data is necessary for fulfilling a contract to which you are a party, or for taking steps at your request prior to entering into a contract.
• Comply with a Legal or Regulatory Obligation:
Processing your personal data is required for compliance with legal or regulatory obligations to which we are subject.
Third Parties
• External Third Parties:
These include:
o Suppliers of Travel Services: Airlines, hotels, car hire companies, and transport providers that act as processors. These providers may be located both inside and outside the EEA, and they deliver the travel services included in any booking you make with us.
o Retail Travel Agent Partners: Travel agents who book on your behalf. They act as our agents and may also be controllers in their own right. These partners are based within the United Kingdom.
o Service Providers: Providers that offer IT and system administration services, acting as processors, and may be based within or outside the EEA.
o Professional Advisers: These include lawyers, bankers, auditors, and insurers, acting as processors or joint controllers, who provide consultancy, banking, legal, insurance, and accounting services. These professionals are based within the United Kingdom.
o Regulatory and Tax Authorities: HM Revenue & Customs and other authorities acting as processors or joint controllers, based in the United Kingdom. They may require reporting of processing activities in certain circumstances.