Privacy policy & statement on cookies

WHAT INFORMATION MIGHT WE COLLECT ABOUT YOU?

We do our best to keep the information we collect about you to the minimum necessary.

The information we collect depends upon how you are interacting with us. For example, if you’re booking a holiday or tour with us we are likely to ask for more information than if you’re only requesting a brochure or browsing our website. We may collect, use, store and transfer different kinds of personal information about you, which we have summarised in the box below.

• Details about you: Your first and last name, marital status, title, gender, e-mail address, telephone number, date of birth, loyalty membership details, your reasons for travel, meal and other travel preferences or dietary requirements.
• Payment details: Your bank details and payment card details when making a booking with us.Details about payments to and from you and other details of products and services you have purchased from us.

• Identification documents: If you are travelling on a routerequiring advance passenger information, your passport or identity card details including your passport number, the country in which your passport was issued and the expiry date. 
• Details about your booking with us: Details such as where you are flying from and to, your booking information (including anyone else on the booking), any onward travel details if relevant, details of experiences or excursions booked through us, baggage requirements, upgrade information, lounge visits, seat preferences, meal preferences or requirements, details of any special assistances required and any other relevant information so that we can provide you with the travel or other service you have arranged with us.

• Details from your interactions with us: Information about interactions or conversations with us and our staff, including when you make enquiries, comments, complaints or submit feedback to us. This could also include username and password and your interests, marketing preferences and survey responses.

• Your use of our systems and services: Thisincludes how you use our site, app, retails stores, call centres and/or social media pages, IP addresses and information you may post on social media.  
• Job applications: If you apply for a job with us, your CV, work history, educational details and the role you are applying for.

• Special types of data: In some circumstances we may need to collect information from you that is deemed sensitive. For example, we might collect:

• Data about your health. Knowing your dietary requirements and any medical conditions you have will ensure that the trip is suitable for you and any necessary adjustments are made.
• Information about your religion (for example if you specify a meal preference that indicates a particular religion, such as a kosher or halal meal).

We try to limit any sensitive personal data we collect to the minimum possible. Unless we have a specific lawful reason to use this information, we will ask for your consent to collect it. 

HOW DO WE COLLECT YOUR INFORMATION AND WHY?

Depending upon your interactions with us, we might collect information in the following ways:

Direct Interactions: You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone and email or otherwise, This includes personal data you provided when you:

• book or search for a holiday or other service (such as a flight, cruise, hotel lounge access, transportation or special assistance) via one of our websites, any apps we use, retail stores, our call centre;
• fill in part of the booking information on our site but do not complete the booking;
• request a brochure, sign up to receive email updates, participate in any of our competitions, promotions (for example via any social media channels, email or our site), surveys or market research;
• create an account on our website and enter information onto online forms;
• provide us with information about an accident, illness or incident that occurred or some other feedback;
• apply for a job with us by email or via the site;
• contact us via our call centres, press office, social media, post, email or instant messenger. Our interactions with you may be recorded and monitored for the purposes of improving customer service, quality assurance, training, security and general business purposes; or
• attend any of our events.

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 for further details.

Third parties or publicly available sources

 We may receive personal data about you from various third parties as set out below:

a)         airlines, hotel providers or other parties we work with if you make a complaint to them;

b)         analytics providers

WHAT DO WE USE YOUR INFORMATION FOR?

Under data protection laws we are allowed to use personal information only if we have a proper reason to do so such as:

• to fulfil a contract we have with you or;
• when it is our legal duty or;
• when it is in our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interested or
• when you consent to it

Generally we do not rely upon consent as a legal basis for processing your personal data other than in relation to sending our own or third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. 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.

• To manage your booking with us: We will use your information to provide you with any travel or event services that you request or purchase. This entails booking your flights, accommodations, organising tours, transportation and car hire and providing you with your tickets (on the basis of performing our contract with you) and providing you with any special assistance you require (where you give us your consent). 

• To contact you with information about your bookings and support services: We will use your contact detailsto send you communications which relate to your booking or services you have requested.The types of information usually included would be: e-mails responding to enquiries, providing you with tickets, alerting you to changes in itineraries or responding to any complaints you have. We do these things in order to fulfil our contract with you and on the basis of our legitimate business interest of providing you with customer service.

• To provide assistance with online bookings: We may collect information when you enter it into forms on our websites but do not complete your booking. We do so in order to offer assistance in case you are experiencing difficulties using our websites.

• To enable you to partake in a prize draw, competition or complete a survey: We do this to perform our contract with you or for our legitimate events of studying how customers use our services, develop them and grow our business.

• To send you marketing communications: Wewill use your information to contact you in order to keep you up to date with the latest news, offers, events, sales, brochures, promotions and competitions that we consider may be of interest or relevant to you. We will usually only do this when we have your consent to do so or on the basis of our legitimate interest to provide you with customer service. Please see the Marketing section below for more information.

• To personalise your customer experience and improve our service: Weuse your informationto provide you with a more personalised service.This might include personalising the communications we send to you with preferences, sending you only with advertising that we think you might like and/or enhancing your holiday experience (on the basis of our legitimate interests to present you with the right kinds of products and services).We may alsorecord and/or monitor calls in order to improve our customer service.

• To ensure security and protect our business interests: In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);

• To process your job applications: We will use your information to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);

• To optimise our sites and app: If you use our sites or apps, we will use your information to ensure that the content from our websites are presented in an effective manner for you and your device, to provide you with access to our site and app in a manner that is effective, convenient and optimal, and to provide you with content that is relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you (on the basis of our legitimate interests to operate and present an effective and convenient website to our website users); 

• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences: This is 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 conduct research: We use your information to carry out aggregated and anonymised research about general engagement with our services and systems, or if you choose to participate in customer surveys, consumer focus groups and research (on the basis of our legitimate interests to improve our products, services and customer service); and

• To comply with our legal obligations: In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or subpoenas (on the basis of our legitimate interests to comply with a legal obligation).

WHAT ABOUT OUR MARKETING PRACTICES?

When we will get in touch with you

One of the other reasons we sometimes collect your information is so that we can form a view on what we think you may want or need, or what may be of interest to you. With this information we decide which products, services and offers may be relevant for you and what marketing you may be interested in.

We keep you up to date with our latest offers, partnerships, sales, promotions, competitions (or those of our partners such as other members of the Travelopia group) that we think might be of interest/relevance to you.

We will only contact you in this way if:

• You have signed up to receive marketing communications from us or one of the other Travelopia companies and have not later told us that you don’t want to hear from us.

• You have made a booking with us and have not told us that you do not want to hear from us.

What if I don’t want to receive marketing?

We never want to send our marketing to someone who isn’t interested in receiving this content. If you have decided that you no longer wish to hear from us, you can unsubscribe from marketing by clicking on the ‘unsubscribe’ link included in all of our e-mails or by contacting us.

Third parties and marketing

We do not pass your information to other parties for marketing purposes unless you agree to us doing so. We will get your express opt-in consent before we share your personal data with any company outside the Travelopia group of companies for marketing purposes.

Sometimes we may use 3rd parties to send the communication to you on our behalf. We use a third-party provider, BP Travel Marketing Ltd to deliver our brochures. We use a third-party Provider HubSpot Inc. to deliver our email marketing. However, these companies do not have the right to send marketing to you for their own purposes.

The marketing material we send to you we may occasionally also include information about selected business partners who provide services closely related to our own product.

YOUR PERSONAL DATA RIGHTS

What are your rights?

We want you to feel reassured that you have control of your personal information. With this in mind, we have explained below the rights you have in relation to the personal information we hold about you:

• The right to be advised of how we will use your personal information. This is set out in this privacy policy and we do our best to provide you with as much information as we can at the point at which you pass us your data.

• The right to ask us to correct any information you believe is incorrect.

• The right to ask us to not to use your information for marketing purposes.
• The right to receive a copy of the personal data we hold about you or to request that we transfer this to another service provider.
• In certain circumstances, the right to ask us to stop using information about you.

• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

• The right to withdraw consent that you have provided to us to use your personal information.

How can you exercise your rights?

You can exercise these rights over your data by contacting us or by checking the applicable boxes on forms where we collect your information or to tell us that you don’t want to participate in marketing. You can also unsubscribe from any marketing circulation lists you are on by scrolling to the bottom of the e-mail and clicking the ‘unsubscribe’ link.

We will comply with your requests, unless we have a lawful reason not to do so. We may need you to provide additional details to confirm your identity in order to process your request.

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.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will only keep your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal accounting or reporting requirements.

We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time we hold it for.

By law we have to keep basic information about booking and our customers for six years for legal claims and tax purposes.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

California Residents – Your Privacy Rights

This section is applicable to residents of California. If you are a resident of California, you have certain rights described below.

1.      Rights Provided by California Civil Code Section 1798.83

A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by mailing us at Exodus, Attn: Legal Department, D S T House, St Mark’s Hill, Surbiton KT6 4BH, United Kingdom, or emailing us at datateam@exodus.co.uk. Please note that we are only required to respond to two requests per California Customer each year under Code Section 1798.83.

2.      Rights under the California Consumer Privacy Act

This section of our Privacy Policy provides California residents with a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and the rights of California consumers regarding their personal information under the California Consumer Privacy Act (“CCPA”). “Personal Information” under this section has the same meaning as defined in the CCPA. This section applies to all California residents (but not including legal entities, such as companies). The section will not apply, however, if we do not collect any Personal Information about you or if all of the information we collect is exempt from the statute (for example, the CCPA does not protect information that is already protected by certain other privacy laws, and it does not protect information that is already publicly available).

With whom do we share your information?

The above sections describe how we collect, use, and disclose your Personal Information.

Sale of Personal Information

We do not sell your Personal Information.

You have a right to access and disclosure.

You have the right to request disclosure about what categories of Personal Information we have used or disclosed for a business purpose about you and the categories of third parties to whom the Personal Information was used or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.

The categories of Personal Information that we have collected about you:

• The categories of sources from which we have collected the information
• The business or commercial purpose for collecting or selling the Personal Information
• The categories of third parties with whom we share Personal Information
• The specific pieces of Personal Information we have collected about you
• The categories of Personal Information that we have disclosed about you for a business purpose
• The categories of Personal Information that we have sold about you, as well as the categories of third parties to whom we sold the information

When you make a request under your Right to Know, you can expect the following:

1. We will verify your identity in order for us to verify that you are who you say you are.
2. We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at datateam@exodus.co.uk.
3. We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
4. In certain cases, a Request to Know may be denied, for example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.

If you would like to exercise your right to request disclosure, please contact us using the information below under “How to contact us”. Our privacy team will examine your request and respond to you as quickly as possible.

You have a right to request deletion. 

You have the right to request that we delete any Personal Information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the information would create problems with the completion of a transaction or compliance with a legal obligation. 

If you would like to exercise your right to request disclosure, please contact us using the information below under “How to contact us”. Our privacy team will examine your request and respond to you as quickly as possible. 

When you make a request for deletion, you can expect the following:

1. After you request deletion, you will need to confirm that you want your information deleted.
2. We will verify your identity.
3. We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage listed below.
4. We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
5. In certain cases, a request for deletion may be denied, for example, if we cannot verify your identity, the law requires that we maintain the information or if we need the information for to provide you with a service you requested. If we deny your request, we will explain why we denied it and delete any other information that is not protected from deletion. 

You have a right to non-discrimination.

We will not discriminate against you (e.g., by denying you goods or services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

OTHER PRIVACY INFORMATION 

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 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.

Third-party Links

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.

Changes to this privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 2nd July 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

HOW TO CONTACT US

We have appointed a Data Champion 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 Champion using the details set out below.

Data Champion

Exodus Travels Ltd

DST House 

St Marks Hill

Surbiton, Surrey

KT6 4BH

datateam@exodus.co.uk

Please contact us in the first instance if you have any concerns. If we are unable to resolve your concern, you have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) or the relevant data protection authority where you live.

For data protection laws applicable in Member states of the European Union, please contact to the address or email below.

GDPR Officer

Sawadee Reizen

Sarphatistraat 650

1018 AV Amsterdam

privacy@sawadee.nl

OTHER PRIVACY INFORMATION

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 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.

Third-party Links

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.

Changes to this privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 2nd July 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

COOKIES

You can set your browser to refuse all or some browser 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 not function properly. For more information about the cookies we use, please see our Cookies Policy.

STATEMENT ON COOKIES

By using our website, you agree to our Website Terms & Conditions. Take a look at our Privacy Policy to find our more on how we collect and use personal data. When you visit our websites we use cookies. Cookies allow us to identify the computer or device you’re using to access our websites – but we can’t identify you personally. You can set up your web browser to refuse cookies, but this means you won’t be able to book on our website or use all of its features.

What we use cookies for

• Storing what’s in your shopping basket: This allows you to buy holidays with us.
• Collecting information: This means we can learn more about how you use our website so we can improve our products and online experience.
• Tailoring your experience: Cookies allow us to provide you with information, products and services that we think you’ll find interesting.
• Making our marketing relevant: We can show you relevant offers and promotions on our own websites and through our advertising networks.
• Email newsletters: If you receive our email updates, we tailor the information we send you based on the data our cookies have collected from your recent visits to our website. You can opt-out of this in any email we send.

Types of cookies we use

Here are the types of cookies our websites use and some more details about what they’re used for:

Application cookies

These cookies allow us to make sure you get the best possible experience on our website. They’re essential for you to be able to search and buy online with us.

Behavioural cookies

Behavioural Cookies help us provide you with an online experience that’s tailored to your needs. They help us show you the most relevant content, based on your preferences.

Analytical cookies

These cookies help us understand how our customers are using the website, so we can make things better.
We also monitor which of our marketing activities generates traffic to our websites using cookies. We use this data to reward our partners if you make a booking with us.

Marketing cookies

Marketing cookies can be used by us and our partners. They allow us to interact with you once you’ve left our website – by showing you adverts for example – to help you find the holiday that’s right for you.

Search engine – Google, Bing etc.

The cookies used for search engines allow us to monitor and enhance the performance of marketing activity. The data collected is anonymous and only used internally.

These cookies provide us with information to monitor the performance of specially selected marketers, advertisers and publishers and help better serve and manage offers and ads across the web.

By using our websites, you agree to us using cookies as set out in our Statement on Cookies.

COOKIES – THE LOWDOWN

Read through this section for all you need to know about what cookies are and how we use them.

What are cookies?

Cookies are small text files placed on your computer by us or our partners. They let us identify the device you’re using – but not you personally. This information is sent back to our systems as you move around our website.

Cookies are unique to the web browser you’re using – so if you’re using a desktop computer as well as a mobile, different data will be collected for each.

You can find more information on the About Cookies website www.aboutcookies.org.

Cookies can be set by the owner of the website you’re on. These are known as 1st Party Cookies. There are also 3rd Party Cookies that can be set by partner websites. Only the owner of the cookie can see the anonymous information it collectsYou can choose to accept all cookies, reject 3rd Party Cookies or reject all cookies by changing your internet browser settings. If you don’t accept cookies, some features of our website won’t work. For example, you won’t be able to make a booking.

How we use cookies

We may use cookies to find out more about how you use our website – like the searches you make and your preferences. We use this information to:

• Make it possible for you to use our website

• Show you information and offers that are relevant to you

• Find out more about how our customers use the site

Buying our products online

When you’re buying something on our website, we need to use cookies to keep track of what you’re booking as you move through each stage of the booking process.

Keeping track of your searches and preferences
Your recent searches and shortlisted holidays are recorded using cookies.

If you’ve searched for a holiday, left our website and then you come back later, the search panel will keep the information you provided before, so you won’t need to fill everything in again.

If you’ve made a shortlist but you haven’t saved it by entering your email address, we’ll store your shortlisted holidays using a cookie, so you’ll be able to see it when you visit us again using the same computer or device.

Improving your experience
We use cookies and software programmes to record, measure and analyse how our customers use our website. We use this information to understand what you want from our website, which helps us when we’re considering future products like flight routes and holidays.
We can also find out how you move around our website, so we can look into any errors stopping you from being able to do what you want. The data we collect from cookies is really important for us to improve your experience.

Making your experience personal
When you’re on our website, we might interact with you or show you personalised information and offers anonymously. Cookies help us to do this by letting us know how you’re using our website on your particular computer or device, which means we can work out what’s most relevant to you.

For example, we’ve got more than one million holidays available at any time, but we can use cookies to suggest things like holidays from your nearest airport, destinations you’ve shown interest in, or products you might like.

Receive our email newsletters? We link information from cookies with your email registration details so we can tailor the information we send you – unless you tell us not to. You’ll be given the chance to opt-out on every email we send you.

Adverts on other websites
If you visit one of our partner sites, you might see an advert that’s relevant to what you searched for when you last visited our own site. We work with advertising networks who use cookies to collect information on your preferences, meaning we can show adverts tailored to you.

Refusing cookies and changing your mind after you’ve accepted.

Refusing cookies

You can change your browser settings to accept or refuse all cookies, choose which cookies you want or don’t want, or ask to be notified when a cookie is set. Use the help feature in your browser to see how.

Changing your mind after you’ve accepted our cookies
If you change your mind after you’ve accepted our cookies, you’ll find an option within your internet browser to clear cookies that have already been set. Use the help feature in your browser to see how. You’ll then need to change your browser settings to refuse cookies in future.

More details on how to refuse cookies
Take a look at the websites of Pinsent Masons law firm www.aboutcookies.org or the Internet Advertising Bureau www.youronlinechoices.com/uk for independent information on cookies – including how to refuse or delete them from your computer or device.

Just so you know, you won’t be able to benefit from all the features of our website and email newsletters or book online with us if you refuse cookies.

Find out more on cookies

Take a look at these websites for more information on cookies:

Independent advice
Pinsent Masons law firm
Internet Advertising Bureau

Information from our agencies and partners
Adobe
Google Analytics
Omniture
Struq
Live Person
HubSpot
Adinsight
Convertro & Tealium
Drupal
Google
Yahoo
MSN
Facebook
Affiliate Window

Exodus Travels,

3131 Elliott Avenue,

Suite 250,

Seattle Washington, United States

98121

Or visit the Contact us page for more contact information.