Constant Travel understands and respects the importance of your privacy. This Privacy Policy (the “Policy”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in respect of your relationship with us as a customer or a potential customer.

This information may be collected via our websites (“Sites”), our call centres, our networks of Sales Agents (defined below), or our social media channels (collectively, our “Services”). Please read the following information carefully.

You are responsible for ensuring that the other members of your party are aware of the content of this Privacy Policy and that you have checked with them that they agree to their personal data being passed to us to make a booking or other purchase on their behalf.

By making a booking/purchase or otherwise submitting your personal data to us, we will transfer, store, or process it as set out below. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

WHO DOES THIS POLICY APPLY TO

This Privacy Policy applies to the holidays, travel products, and services offered by Constant Travel acting as sales agents for Hays Travel.

When we say “Constant Travel”, “we”, or “us” in this Policy, we’re generally referring to the separate and distinct companies that make up Hays Travel (depending on the context of the Services you use).

This Policy applies to personal data processed by the following companies, including data collected when you make bookings, purchases, and enquiries with them.

For the purpose of this Policy, the independent travel agents and self-employed contractors shall be collectively referred to as “Sales Agents”.

Each independent travel agent may publish its own supplementary privacy policy to explain how it will process and handle any additional personal data it collects from you. Any such supplementary policies apply in addition to this Policy.

WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT YOU AND WHY DO WE COLLECT IT

We will collect certain personal data about you and about any other person you include on your booking. The sort of personal data we collect will be information that you provide to us, that we collect from you or observe about you, or that we obtain from other sources.

PERSONAL DATA YOU GIVE TO US

When you make a booking/purchase or enquiry, we will ask you for your name, address, email address, telephone number, date of birth, and personal travel preferences. We need to collect this information in order to arrange the travel and other services you are requesting.

When you request to make a booking, we will ask you for personal data such as information concerning dietary requirements, medical conditions, disabilities, and special requirements. We need to collect this information so as to be able to consider your particular needs in relation to a booking and, where those needs can be met, we may have to share that data with our third-party suppliers and transfer it outside the European Economic Area (EEA), as described in this Privacy Policy.

If you do not want to provide this information to us, or once you have provided us with this information you ask us or our data compliance department to stop processing it, it may mean we won’t be able to provide all or parts of the services you have requested. If we have to cancel your booking/purchase as a result, you may incur a cancellation charge.

If you enter a competition or promotion, complete a survey, or report a problem with any of our Services, we will collect your name and relevant contact information. We may ask to see and retain a copy of your passport details and other identification documents if, for example, you are purchasing foreign currency or completing a money transfer.

If you contact us, we may keep a record of your email or other correspondence. If you call us by telephone, we may monitor and/or record phone conversations for training and customer service purposes.

If, when using our Services, you make a holiday enquiry with one of our travel consultants and provide personal data (including telephone number or email address) but do not make a booking/purchase, we will retain and use the data you’ve provided for a limited time and purpose, as mentioned below.

To help us keep your information current, accurate, and complete, please ensure you tell us if anything needs to be changed.

PERSONAL DATA WE COLLECT AND/OR OBSERVE ABOUT YOU

Based on how you have used our Services in the past and your activity on our website and social media channels, we collect the following personal data about you:

• Details of the services we have provided to you in the past, including your previous travel arrangements (such as holidays and other purchases), and matters related to those arrangements (such as your requirements or complaints)

• Images of you taken on our or our Sales Agents’ CCTV systems at our premises

PERSONAL DATA OBTAINED FROM SALES AGENTS

We might also receive your personal data from third-party sources who collect information about you on our behalf. This includes:

• If you tell a subcontractor that you would like to receive marketing communications from Freedom Travel, they will securely transfer your contact details and marketing preferences to us

• If you book a holiday through a Sales Agent, certain personal data (such as your name, date of birth, or any special requirements) will be passed to us to provide the services you have requested

WHERE IS YOUR DATA STORED AND WHO IT’S SHARED WITH

Your personal data is held on a combination of our own systems and systems of the suppliers we use to provide our Services.

When you provide your personal data to us, some of it will need to be passed to, processed, and stored by relevant third parties, such as technology partners, airlines, airports, hoteliers, insurance companies, and ground handling agents, so that they can provide your travel arrangements.

Some of these third parties may be based outside of the European Economic Area (EEA). Organisations outside the EEA may not be subject to the same level of data protection laws. We aim only to transfer your data where appropriate safeguards are in place or where it is necessary to fulfil your contract.

We may also be required to disclose your personal data to government authorities, including those responsible for immigration, border control, security, and anti-terrorism.

We may also share your data to prevent fraud or unauthorised payments.

HOW DO WE USE YOUR INFORMATION

We process your data in different ways depending on the legal basis:

• To administer your booking and communicate with suppliers

• To send booking confirmations and travel documents

• To improve customer experience and website functionality

• To prevent fraud and protect our business

• To conduct research and improve our services

• To assist in emergencies

• To send marketing communications where permitted or consented

• To comply with legal obligations

MARKETING COMMUNICATIONS

If you have made an enquiry or booking, your data may be used to contact you with relevant offers by post, email, text, or phone, unless you opted out.

If you have not made a booking, we will only contact you if you have opted in.

We will not share your data with third parties for marketing unless you have agreed.

YOUR RIGHTS

You have rights under data protection law, including:

• Accessing your personal data

• Correcting inaccurate data

• Withdrawing consent

• Objecting to processing

• Requesting deletion or restriction

• Requesting a copy of your data

We may require proof of identity before processing requests.

HOW TO CONTACT US

Compliance Dept:
Constant Travel c/o Hays Travel
25 Vine Place, Sunderland
Tyne & Wear SR1 3NA

We will respond within 30 days.

COMPLAINTS

If you wish to contact us about this Privacy Policy, you can email or write to the Hays Travel Data Protection Officer using the contact details above.

DATA RETENTION

Where you’ve made a booking or purchase, your data will be retained to provide customer service and meet legal and audit requirements.

DATA SECURITY

We take data security seriously. While we take reasonable steps to protect your data, transmission over the internet is not completely secure. Once received, your data is stored on secure servers.

THIRD-PARTY LINKS

Our Sites may include links to third-party websites. These sites have their own privacy policies, and we are not responsible for them. Please check their policies before submitting personal data.

COOKIES POLICY

A cookie is a small text file downloaded to your device when you visit our website. Cookies help:

• Improve your browsing experience

• Remember preferences

• Analyse website traffic

You can disable cookies via your browser settings.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to update or amend this Privacy Policy at any time.

October 2024 v5