“Travelshooters” (referred to as “we”, “us”, “our” or “Travelshooters” in this policy) in this policy primarily refers to Travelshooters Limited and, where appropriate, to other entities over which Travelshooters exercises management control. Travelshooters Ltd is the “data controller” of all personal information that is collected and used about Travelshooters customers for the purposes of the General Data Protection Regulation. Travelshooters is registered in England with registration number 07597209 and registered offices at Farren House, Farren Court, The Street, Cowfold, Horsham, West Sussex, England, RH13 8BP.

Personal data means any information relating to you which allows us to identify you, such as your name, contact details, booking reference number, payment details and information about your access to our website.

We may collect personal data from you when you book a tour with us, use our website, or when you contact us.

Specifically, we may collect the following categories of information:

• Name, home address, e-mail address, telephone number, passport or other recognised personal ID card numbers and details, credit/debit card or other payment details;
• Passport details, which include your name, nationality, date of birth, gender, passport or ID number, expiry date and country of issue;
• Medical conditions for clients who have special medical requirements and/or dietary requirements;
• Information you provide about your and your fellow travellers’ travel preferences;
• Information about your use of our website;
• The communications you exchange with us or direct to us via letters, emails, chat service, calls, and social media.

Personal details about your physical or mental health, alleged commission or conviction of criminal offences are considered “sensitive” personal data under applicable data protection laws. We will process any such data only if you have given your explicit consent, or it is necessary (for instance if you request special assistance), or you have deliberately made it public.

Your data may be used for the following purposes:

• Providing products and services you request: we use the information you give us to perform the services you have asked for in relation to your tour;
• Contacting you in the event of an itinerary change or cancellation: we send you communications about the services you have asked for and any changes to such services. These communications are not made for marketing purposes and cannot be opted-out of;
• Credit or other payment card verification/screening: we use your payment information for accounting, billing and audit purposes and to detect and / or prevent any fraudulent activities;
• Administrative or legal purposes: we use your data for statistical and marketing analysis, systems testing, customer surveys, maintenance and development, or in order to deal with a dispute or claim. Note that we may perform data profiling based on the data we collect from you for statistical and marketing analysis purposes. Any profiling activity will be carried out with your prior consent only and by making best endeavours to ensure that all data it is based on is accurate. By providing any personal data you explicitly agree that we may use it to perform profiling activities in accordance with this Privacy Policy;
• Immigration/customs control safety: we may be obliged to provide your information to border control agencies;
• Security, health, administrative, crime prevention/detection:  we may pass your information to government authorities or enforcement bodies for compliance with legal requirements;
• Customer Services communications: we use your data to manage our relationship with you as our customer and to improve our services and enhance your experience with us;
• Provide tailored services: we use your data to provide information we believe is of interest to you, prior to, during, and after your travel with us and to personalise the services we offer to you, such as special offers to your favourite destinations or deals;
• Marketing: from time to time we would like to contact you with information regarding promotions and ancillary products via e-communications. You will have the choice to opt in or opt out of receiving such communications by indicating your choice at the booking stage. You will also be given the opportunity on every e-communication that we send you to indicate that you no longer wish to receive our direct marketing material.

We will only process your personal data where we have a legal basis to do so. The legal basis will depend on the reasons we have collected and need to use your personal data for.

In most cases we will need to process your personal data so we can enter into our contract to deliver tour services for you.

We may also process your personal data for one or more of the following:

• To comply with a legal obligation (e.g. Immigration or customs requirements);
• You have consented to us using your personal data (e.g. for marketing-related uses);
• To protect your vital interests or those of another person (e.g. in case of a medical emergency);
• It is in our legitimate interests in operating as a tour operator (e.g. for administrative purposes).

Only children aged 16 or over can provide their own consent. For children under this age, consent of the children’s’ parents or legal guardians is required.

We will not retain your data for longer than is necessary to fulfil the purpose it is being processed for. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the purposes for which we process it and whether we can achieve those purposes through other means.

We must also consider periods for which we might need to retain personal data in order to meet our legal obligations or to deal with complaints, queries and to protect our legal rights in the event of a claim being made.

When we no longer need your personal data, we will securely delete or destroy it. We will also consider if and how we can minimise over time the personal data that we use, and if we can anonymise your personal data so that it can no longer be associated with you or identify you, in which case we may use that information without further notice to you.

We follow strict security procedures in the storage and disclosure of your personal data, and to protect it against accidental loss, destruction or damage. The data you provide to us is protected using SSL (Secure Socket Layer) technology. SSL is the industry-standard method of encrypting personal information so that it can be securely transferred over the Internet.

We do not request payment details (e.g. credit/debit cards) at any time. All payments we receive from our clients are done by inter-bank transfer using the security provisions of the international banking system. We do not hold any information about your bank account or credit cards.

We may disclose your information to trusted third parties for the purposes set out in this Privacy Policy. We require all third parties to have appropriate technical and operational security measures in place to protect your personal data, in line with Irish and EU law on data protection rules.

Travelshooters is based in the UK. We deal with service providers who are not located in the European Economic Area (EEA), in countries such as India, Myanmar, Thailand and others. While countries outside the EEA do not always have strong data protection laws, we require all services providers to process your information in a secure manner and in accordance with EU law on data protection. We utilise standard means under EU law to legitimise data transfers outside the EEA.

We make every effort to limit any personal data so transferred to be the minimum necessary to deliver our services to you.

We will not share your personal data outside Travelshooters Ltd for marketing purposes.

We may share your personal data with the following third parties for the purpose described in this Privacy Policy:

• Government authorities, law enforcement bodies, regulators, fraud screening parties, airports and airlines in your itinerary or to which your flight may fly over for compliance with legal requirements;
• Trusted agents and suppliers strictly necessary to the purposes of your tour with us: for example, we may give your chosen accompanying photographer your phone number or email to facilitate communications relating to that tour, or a local tour partner so that they can provide the services we have contracted with them to provide on your behalf while on tour;
• Legal and other professional advisers, law courts and law enforcement bodies in all countries we operate in in order to enforce our legal rights in relation to our contract with you;
• Social media: You may be able to access third party social media services through our website or before coming to our website. When you are registered with your social service account, we may obtain the personal information you choose to share with us through these social media services pursuant to their privacy settings in order to improve and personalize your use of our website. We may also use social media plugins on our website. As a result your information will be shared with your social media provider and possibly presented on your social media profile to be shared with others in your network. Please refer to the privacy policy of these third-party social media providers to find out more about these practices.

This site uses cookies. Please see our separate Travelshooters’ Cookie Policy for more about cookies and how we use them.

Having regard to the limited scope and scale of personal data processing carried out by Travelshooters, we consider Travelshooters to meet the exemption provisions of GDPR regarding the appointment of a Data Protection Officer.

Under certain circumstances, by law you have the right to:

• Request information about whether we hold personal information about you, and, if so, what that information is and why we are holding/using it.       
• 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.
• 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.
• 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).
• 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.
• Object to automated decision-making including profiling, that is not to be subject of any automated decision-making by us using your personal information or profiling of you.
• 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.
• Request transfer of your personal information in an electronic and structured form to you or to another party (commonly known as a right to “data portability”). This enables you to take your data from us in an electronically usable format and to be able to transfer your data to another party in an electronically usable format.
• 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. 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 want to exercise any of these rights, then please submit a completed online request form [download], or contact us at Travelshooters Data Protection Administration, ALB Secretarial Limited, Farren House, Farren Court, The Street, Cowfold, Horsham, West Sussex, England RH13 8BP.

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.

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.

Our Privacy Policy may change from time to time and any changes to the statement will be communicated to you via e-mail or a notice on our website.

Change history:

• First GDPR draft published 22-May-2018