Dated 21 May 2018
1. Introduction & Scope
1.1. Just Fly Business Ltd is committed to protecting the privacy and security of your personal information (collectively referred to as “the Company”, “we”, “us” or “our”).
1.2. This Privacy Notice (“Notice”) describes how we collect and use personal information about you during and after your relationship with us, in accordance with the General Data Protection Regulation (“GDPR”).
1.3. This Notice applies to all past, present and prospective customers of the Company (collectively referred to as “Customers”, “you” or “your”) as well as certain third parties to your bookings such as your family members, friends or other representatives. This Notice does not form part of any contract to provide services you may have with the Company from time to time.
1.4. It is important that you read this Notice, together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.
1.5. We reserve the right to amend this Notice at any time without notice to you so, if required, please check to ensure that you are referring to the latest copy of this Notice. We may also notify you in other ways from time to time about the processing of your personal data.
2. Data Controller
2.1. Just Fly Business Ltd of Cambridge House, 180 Upper Richmond Road, London, England, SW15 2SH is a “data controller” for the purposes of the GDPR. This means that we are responsible for deciding how we hold and use personal information about you.
2.2. We have appointed Alex Way of Cambridge House, 180 Upper Richmond Road, London, England, SW15 2SH (Tel: 0203 802 1724) to oversee compliance with this Notice (“the Director”). If you have any questions about this Notice or how we handle your personal information, please contact the Director.
2.3. You have the right to make a complaint at any time to the ICO (www.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.
3. Data protection principles
3.1. We will comply with data protection law. This says that the personal information we hold about you must be:
3.1.1. Used lawfully, fairly and in a transparent way.
3.1.2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3.1.3. Relevant to the purposes we have told you about and limited only to those purposes.
3.1.4. Accurate and kept up to date.
3.1.5. Kept only as long as necessary for the purposes we have told you about.
3.1.6. Kept securely.
4. The kind of information we hold about you
4.1. 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). There are also “special categories” of more sensitive personal data which require a higher level of protection.
4.2. We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:
4.2.1. Identity Data includes first name, maiden name, last name, marital status and dependents, title, date of birth, gender, occupation, photographs, driving licence and passport details;
4.2.2. Contact Data includes billing address, home address, registered office address, email address, telephone numbers, next-of-kin and emergency contact information;
4.2.3. Financial Data includes bank account details and payment card details;
4.2.4. Booking Data includes (but is not limited to) details about your and/or your family’s holiday and travel bookings whether with us or with third party tour operators, itineraries, preferences, special needs, dietary requirements, visa/immigration information and complaint and grievance information;
4.2.5. Sensitive Personal Data includes information relating to your physical or mental health and information about criminal convictions and offences;
4.2.6. Technical Data includes information about your use of our information and communications systems (including our website) such as your internet protocol (IP) address, your login data, browser type etc., CCTV footage and any other information obtained through electronic means;
4.2.7. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses; and/or
4.2.8. Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
5. How is your personal information collected?
5.1. We will collect personal information about you and any relevant third parties during the enquiry and booking process, either directly from you or sometimes from your family and friends or permitted agents and representatives. This includes personal data you provide when you:
5.1.1. make booking enquiries;
5.1.2. create an account on our website;
5.1.3. subscribe to our service or publications;
5.1.4. request marketing to be sent to you;
5.1.5. enter a competition, promotion or survey; or
5.1.6. give us some feedback.
5.2. We will also automatically collect personal information about you as you interact with our website including data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
5.3. 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 Technical 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 treat the combined data as personal data which will be used in accordance with this Notice.
5.4. We may also collect additional information about you from third parties within the Hays Travel Independence Group, a consortium of independent travel agencies to which we are a member, and from other businesses or contacts in the industry that recommend you to us or book through us as agent.
5.5. Additional personal information may be collected during the course of your booking with us and any subsequent bookings we may receive.
6. How we will use information about you
6.1. We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
6.1.1. Where we need to perform the contract we have entered into with you.
6.1.2. Where we need to comply with a legal obligation.
6.1.3. 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.
6.2. We may also use your personal information in the following situations, which are likely to be rare:
6.2.1. Where we need to protect your interests (or someone else’s interests).
6.2.2. Where it is needed for official purposes.
7.1. Generally, we do not rely on consent as a legal basis for processing your personal data and 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. However, we do require your consent to contact you from time to time with sales offers and information about our business and services.
7.2. We will obtain your consent to contact you as part of the initial booking process or when you subscribe to our newsletters. At that time, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your booking with us that you agree to any request for consent from us. You can update your marketing and communication preferences at any time by clicking the “update preferences” link at the bottom of all marketing emails and you will be able to withdraw your consent at any time (see below). You may also unsubscribe from our email marketing lists by following this link here. Please note that if you unsubscribe, you will no longer receive latest news on special offers or sale fares.
8. Situations in which we will use your personal information
8.1. We need all the categories of information in the list above primarily to allow us to perform our agreement with you and to enable us to comply with our legal obligations. In some cases we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests.
8.2. The situations in which we will most commonly process your personal information are listed below:
8.2.1. facilitating your holiday and travel bookings including (but not limited to) creating itineraries, booking your travel and accommodation, administering your bookings, assisting with the application for travel visas and providing emergency assistance whilst abroad;
8.2.2. responding to, or following up on, your comments and questions, and otherwise providing customer service;
8.2.3. any other reasonable purpose connected with your booking with us and notified to you in advance or as otherwise agreed with you from time to time;
8.2.4. contacting you from time to time with information about our sales offers and services generally;
8.2.5. complying with health and safety obligations;
8.2.6. dealing with insurance claims;
8.2.7. updating and enhancing client records;
8.2.8. analysis for management purposes and the improvement of our services;
8.2.9. administering and protecting our business and website;
8.2.10. asking you to leave a review or take a survey;
8.2.11. enabling you to partake in a prize draw, competition or complete a survey;
8.2.12. to monitor your use of our information and communication systems to ensure network and information security, including preventing unauthorised access to our computer and electronic communications systems;
8.2.13. delivering relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve you;
8.2.14. using data analytics to improve our website, products, services, marketing, customer relationships, and experiences,
8.2.15. crime prevention; and/or
8.2.16. legal and regulatory compliance.
8.3. Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information.
9. If you fail to provide personal information
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 this case, we may have to cancel the booking you have with us but we will notify you if this is the case at the time.
10. Change of purpose
We will only use your personal information 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 information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
11. How we use particularly sensitive personal information
11.1. “Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information.
11.2. We may process special categories of personal information in the following circumstances:
11.2.1. In limited circumstances, with your explicit written consent.
11.2.2. Where we need to carry out our legal obligations.
11.2.3. Where it is needed in the public interest.
11.3. We may use sensitive personal information about your physical or mental health, or disability status, to ensure your health and safety and to assist in providing access in connection with your bookings (i.e. disability and mobility assistance).
11.4. We may also hold sensitive personal information about criminal convictions or offences as disclosed by you in connection with any relevant visa application or other travel permits.
11.5. Less commonly, we may process this type of information where it is needed in relation to legal claims or where it is needed to protect your interests (or someone else’s interests) and you are not capable of giving your consent, or where you have already made the information public. We may also process such information about Customers in the course of our legitimate business activities with the appropriate safeguards.
11.6. We do not need your consent if we use special categories of your personal information in accordance with our written policy to carry out our legal obligations or exercise specific legal rights. In limited circumstances, we may approach you for your written consent to allow us to process certain particularly sensitive data. If we do so, we will provide you with full details of the information that we would like and the reason we need it, so that you can carefully consider whether you wish to consent. You should be aware that it is not a condition of your booking that you agree to any request for consent from us.
12. Automated decision-making
Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention. We do not envisage any decisions will be taken about you by automated means, however we will notify you in writing if this position changes.
13. Data sharing
13.1. We may have to share your Data with third parties. We will only share your Personal Data with third parties where required by law, where it is necessary to administer your booking with us or where we have another legitimate interest in doing so.
13.2. “Third parties” includes third-party service providers such as Hays Travel Limited (of whom we are an Accredited Body Member ATOL 5534), tour operators, hotels and other accommodation providers, airlines and other transport providers, visa and immigration authorities and other parties connected with your booking. We may also need to share your personal information with a regulator or to otherwise comply with the law.
13.3. We will not pass on any personal information where it is not connected to part of your travel arrangements or our internal business management unless we are legally obliged to do so. Your tour operators or other principals may pass information onto their own suppliers once we have provided it to them. We are not responsible for personal data that is used by your tour operators or other principals in their capacity as independent or joint ‘data controllers’. We would urge you to review their privacy policies in conjunction with our own to ensure you are fully informed of all data processing activities connected with your bookings.
13.4. Such third parties in the United Kingdom and the EU are subject to the provisions of the GDPR or similar regulations in relation to your personal data.
13.5. Our third-party service providers are required to take appropriate security measures to protect your personal information and we do not allow our third-party service providers to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions.
13.6. We may also be required to transfer your personal data outside the EU. The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. We transfer personal data originating in one country across borders when we transmit, send, view or access that data in or to a different country.
13.7. We may transfer Personal Data outside the EEA if one of the following conditions applies:
13.7.1. the European Commission has issued a decision confirming that the country to which we transfer the personal data ensures an adequate level of protection for the data subjects’ rights and freedoms;
13.7.2. appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism;
13.7.3. you have provided explicit consent to the proposed transfer after being informed of any potential risks; or
13.7.4. the transfer is necessary for one of the other reasons set out in the GDPR including the performance of your contract with us, reasons of public interest, to establish, exercise or defend legal claims or to protect your vital interests where you are physically or legally incapable of giving consent and, in some limited cases, for our legitimate interest.
14. Third-party links
Our 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.
We use our own and third-party cookies to enhance your browsing experience, serve personalised ads or content, and analyse our traffic.
Google will use your personal data when you’ve given consent on our site. See Google’s Privacy & Terms site here.
16. Data security
16.1. The GDPR requires us to put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. We ensure that reasonable security measures are taken against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.
16.2. We have also put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
16.3. If you have any questions about our current organisational and technical security procedures, please contact the Director.
17. How long will you use my information for?
17.1. We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
17.2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
17.3. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from the Director.
17.4. In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.
Rights of access, correction, erasure, and restriction
18. Your duty to inform us of changes
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.
19. Your rights in connection with personal information
19.1. Under certain circumstances, by law you have the right to:
19.1.1. Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
19.1.2. Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
19.1.3. Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
19.1.4. Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
19.1.5. Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
19.1.6. Request the transfer of your personal information to another party.
19.2. If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact the Director in writing.
20. No fee usually required
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
21. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
22. Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact the Director. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
If you have any questions about this Notice, please contact the Director.
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