Adaptable Travel Limited (“Adaptable Travel,” “we,” “our,” or “us”) is committed to protecting your privacy and respecting your personal data. This Privacy Policy explains how we collect, use, and protect your information when you interact with us through our services, website, and other means of communication. This policy applies to all individuals whose personal data we process in connection with our business activities.
1. Scope and Purpose
This Privacy Policy applies to all personal data that we process in relation to our travel services, including the collection of information necessary to organise tours, bookings, work placements, and other travel-related arrangements.
2. Information We Collect
a. Booking and Travel Arrangements
To organise and manage your travel experience, we collect and process the following types of personal information:
- Contact Details: Full name, address, email address, and phone number.
- Travel Documents: Passport details, visa information, and other relevant travel documentation.
- Health and Dietary Requirements: Information such as allergies, medical conditions, or specific dietary needs to ensure your comfort and safety.
- Payment Information: For processing transactions and confirming bookings.
- Additional Traveller Information: Information about other travellers (e.g., group members or minors under 18) provided with appropriate consent.
b. Website and Technical Data
When you visit our website, we may collect information about your usage patterns and preferences to improve your experience:
- Cookies and Analytics: Usage data collected through cookies or similar tracking technologies to understand website traffic and enhance functionality.
- Device Information: IP address, browser type, and settings to optimise your browsing experience.
c. Social Media and User-Generated Content
If you interact with us on social media platforms or share user-generated content, we may collect information such as your username, profile picture, and any other publicly available information. This data allows us to respond to your comments, conduct marketing activities, and improve our services.
3. When and How We Collect Your Personal Data
We collect your personal data in the following situations:
- When you request a quote for a tour or visit.
- When we fulfil a contractual obligation related to a confirmed booking.
- When you provide a service to Adaptable Travel, including but not limited to:some text
- Accommodation bookings
- Coach and transport services
- Ferry and transport bookings
- Event or attraction bookings
- When you request that we arrange specific experiences, such as work placements or language courses.
- When you join our mailing list through our website or at events, conventions, or exhibitions.
- When you fill out an enquiry form on our website.
- When you download resources from our website.
- When you apply for a job with us or in connection with your employment, if applicable.
- When you contact us by phone. Please note that calls may be recorded for training and customer service purposes, except when making a payment over the phone, in which case recordings are paused.
We may also collect information about you from third parties in certain cases:
- To fulfil contractual obligations for a booked tour, such as when you are included on a passenger or guest list.
- When you provide services on behalf of Adaptable Travel, such as when working as a coach driver for a tour we have organised.
4. How We Process Your Personal Data
a. Tour and Group Booking Enquiries
At the enquiry and quoting stage, we may collect and process the following personal data:
- Your name
- Your address
- Your email address and telephone number
We use this data to:
- Create and personalise quotations tailored to your group’s requirements
- Ensure that quotations reach you directly
- Communicate with you regarding your enquiry up to the point of confirming your booking
If you decide not to proceed with a booking, we will cease processing your data for this purpose.
b. Confirmed Bookings for Tours or Group Visits
Once a booking is confirmed, we collect and process the following data to fulfil our contractual obligations:
- Your name
- Your address, email address, and telephone number
- Full passenger list, including:some text
- Names as per passport
- Passport numbers and expiry dates
- Dates of birth
- Gender
- Nationality
- Medical information, including allergies and conditions needing specific assistance (special category data)
- Dietary requirements (special category data)
We use this data to:
- Issue invoices, ATOL certificates, and travel insurance
- Book transport, accommodation, and specific activities or attractions
- Communicate medical and dietary needs to service providers, such as airlines, hotels, and restaurants
- Contact you post-tour to collect feedback and, if agreed, to submit photos for our “Photo Competition”
We will cease processing your data for these purposes following the completion of your tour, feedback collection, and any remaining financial settlements.
c. Work Experience and Language Courses Abroad
When arranging work experience or language courses, we may collect additional data:
- Your name, address, email address, and telephone number
- Full passenger list, including details as outlined above
- Parent or next of kin contact details
- Student GP information, in case of emergencies
- Payment information from parents, where applicable
- Passport photos for identification
- Student language levels, course details, intended career, and hobbies
This data allows us to:
- Ensure travel and medical insurance is provided
- Arrange accommodations and activities tailored to student needs
- Notify relevant parties of medical or dietary requirements
- Enable contact with guardians or GPs in emergencies
- Confirm payment details for records and ensure course suitability
We will retain this information for the duration of the placement and for a brief period afterward to process feedback and manage any outstanding matters.
d. Marketing Communications
If you subscribe to our email list or request information, we may use your contact details for marketing purposes:
- Name
- Email address
We use this data to:
- Send you information on our services, brochures, events, and promotions tailored to your interests or location
You have the right to opt-out at any time, as detailed in Section 12.
e. Service Providers for Tours
When you provide or tender for services for a tour, we may collect:
- Coach Travel: Contact information for transport managers and drivers
- Hotels and Agents: Manager details and contact numbers for those responsible for public liability and health and safety
- Attractions or Tour Reps: Contact information, including bank details, for personal guides
We use this data to:
- Communicate with you during the tour, including in emergencies
- Meet regulatory requirements, such as the School Travel Forum
- Manage payments for your services
Following the tour, we will retain necessary records for compliance and future tender requests.
f. Employment and Recruitment
For recruitment and employment purposes, we collect data such as:
- Applicant information: Name, contact details, CV, and relevant health information (special category data)
- Employee details: NI number, bank details, emergency contacts, pension details, performance records, leave requests, and health and safety records
We use this data to:
- Manage recruitment and employment processes, including salary, benefits, performance, and health and safety compliance
- Contact emergency contacts if needed
Employment data is retained for the necessary duration of employment and as required for regulatory purposes.
5. Special Category Data
Adaptable Travel will process special category data, such as medical information, dietary requirements, religious beliefs, and racial or ethnic origin, only when necessary to fulfil our contractual obligations, provide tailored support for your tour, or offer specific assistance (e.g., accessibility accommodations).
We will handle this data in compliance with UK GDPR regulations and only with your explicit consent, obtained through:
- A signed booking form confirming your tour with us
- A signed employment contract if you join Adaptable Travel as an employee
This data will only be used for the purposes specified, such as making suitable travel and accommodation arrangements, fulfilling any medical or dietary needs, and ensuring a safe and comfortable experience for you or your group. Once the purpose of processing this data is complete, we will cease processing it in accordance with our data retention policy.
6. Data Sharing and Security
We may share your personal data with the following:
- Service Providers: Third-party suppliers such as airlines, hotels, and transportation companies involved in organising your travel.
- Technology Partners: Website hosting providers, payment processors, and analytics platforms.
- Legal and Regulatory Authorities: Where required by law or for safety and security purposes.
Adaptable Travel takes your data security seriously. We have implemented physical, electronic, and managerial measures to protect against unauthorised access, alteration, disclosure, or destruction of your personal data.
7. Data Retention
We retain your personal data only as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting requirements. The typical retention periods are as follows:
- Booking and Travel Data: We retain data related to confirmed bookings, such as passenger lists and travel details, for up to 6 years after the completion of the tour, to comply with our legal obligations and for accounting and audit purposes.
- Medical and Dietary Information (Special Category Data): This data is retained only for the duration of the tour and is deleted or anonymised shortly after the tour’s conclusion, once any necessary post-tour follow-ups are completed.
- Enquiry Data: Data collected at the enquiry and quoting stage (if no booking is made) is retained for up to 1 year for record-keeping and follow-up purposes.
- Marketing Data: Contact details for individuals who have consented to receive marketing communications will be retained until you withdraw consent, after which it will be promptly deleted or anonymised.
- Employment and Recruitment Data: Applicant data is retained for up to 1 year if the application is unsuccessful. Employee data is retained for up to 6 years after the end of employment to comply with employment laws and for potential reference requests.
Once these retention periods have elapsed, we securely delete or anonymise personal data, ensuring it cannot be restored or linked back to you.
8. International Data Transfers
As part of providing our services, your personal data may be accessed by and processed outside the United Kingdom, including by staff and service providers located outside the European Economic Area (EEA). This may include staff working with our suppliers or agents who are engaged in fulfilling bookings, organising travel arrangements, and providing support services. We are committed to ensuring that your personal data is handled securely and in compliance with applicable data protection regulations, even when it is processed outside the UK.
When your personal data is transferred outside the UK, we take the following steps to ensure an adequate level of protection:
- Adequacy Decisions: We may transfer your data to countries that have been formally recognised by the UK government as providing an adequate level of data protection, meaning that your data will be treated with the same level of security and care as within the UK.
- Standard Contractual Clauses (SCCs): Where we use service providers in countries not covered by an adequacy decision, we implement Standard Contractual Clauses (SCCs), approved for use in the UK. These contractual obligations require non-UK entities to protect your data to UK standards.
- Additional Safeguards: In cases where SCCs are used, we also implement additional safeguards where necessary, such as data encryption and pseudonymisation, to further protect your personal data.
If you have further questions about how your data is protected when transferred outside the UK, please contact us using the details provided below.
9. Cookies and Similar Technologies
Adaptable Travel uses cookies and similar technologies on our website to improve user experience, analyse site traffic, and support our marketing activities. Cookies are small text files placed on your device to store information, which may be used to recognise your device on future visits.
We use the following types of cookies:
- Essential Cookies: These cookies are necessary for the operation of our website and enable you to navigate and use our services. Without these cookies, certain features (such as secure login) may not function.
- Performance and Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. We use this information to improve website performance and user experience. Examples include Google Analytics, which tracks page views and user interactions.
- Functionality Cookies: These cookies allow our website to remember your choices, such as language preferences, to provide a personalised experience.
- Marketing and Advertising Cookies: We may use these cookies to display relevant ads and measure the effectiveness of our marketing campaigns. They collect information about your browsing habits to display ads that are more relevant to your interests.
You can manage or disable cookies through your browser settings. However, please note that disabling certain cookies may impact your experience on our website.
10. Your Rights
Under the UK GDPR, you have the following rights regarding your personal data:
- Right of Access: You have the right to request a copy of the personal data we hold about you and to check that we are processing it lawfully.
- Right to Rectification: If any of the data we hold about you is inaccurate or incomplete, you have the right to ask us to correct or complete it.
- Right to Erasure: You may request the deletion of your personal data if it is no longer necessary for the purposes for which it was collected or if you withdraw consent (where applicable) and there are no other legal grounds for processing.
- Right to Restrict Processing: You have the right to request that we limit the processing of your data in certain circumstances, such as if you contest the accuracy of the data or object to its processing.
- Right to Object: You may object to the processing of your data where we are relying on legitimate interests as the legal basis. If you object, we will stop processing your data unless we have compelling, legitimate grounds to continue.
- Right to Data Portability: Where the processing is based on your consent or a contract with you and the data is processed by automated means, you have the right to request that we transfer your data to another organisation or directly to you in a structured, commonly used, and machine-readable format.
11. How to Exercise Your Rights
If you wish to exercise any of your rights, please contact us using the details provided below. We may request specific information to verify your identity before processing your request. We aim to respond to all requests within one month, as required by GDPR, though complex requests may require additional time.
12. Making a Complaint
If you have any concerns about how we handle your personal data, please contact us first to allow us the opportunity to resolve the issue. If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO), the UK’s supervisory authority for data protection matters:
Information Commissioner’s Office
Website: https://ico.org.uk/
Telephone: 0303 123 1113
13. Changes to this Privacy Policy
This Privacy Statement is effective from the 22 August 2024. We may revise this policy to reflect changes in our practices or legal requirements. Any significant updates will be communicated, and we encourage you to review the policy periodically.
14. Contact Us
If you have questions or concerns about this Privacy Policy or wish to exercise your data rights, please contact us at:
Adaptable Travel Limited
Address: The Lodge, Condicote, Cheltenham, GL54 1EYEmail: info@adaptabletravel.co.ukPhone: 01451 832133