3.1 Our customers
Our privacy policy sets out how we process personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

3.2 Examples of who this policy covers
We include in this privacy policy personal information we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organizations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organization, employees or individuals who are acting as representatives of that business or other organization, and individuals connected to that business or other organization, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online sites operated by us or our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.

3.3 When we are an information processor only
This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

3.4 Terms used in this policy
When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to "process" or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

4. Information we collect

We commit to use your personal information only for the purposes listed below and for as long as it is necessary to achieve these purposes.

6.1 Operate our website
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customizing your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

6.2 Provide information and respond to enquiries
to provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

6.3 Bookings and other contracts
To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorized or made with us which relate to you.

6.4 Payments
To collect and make payments due and administer our accounts.

6.5 Communication with customers
To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

6.6 Record keeping
To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

6.7 Manage and improve our business
To analyze, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyze the results; to run promotions and competitions;
To undertake product or customer research/ development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes, including by sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;

To carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

6.8 Direct marketing
To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you. We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 7 for the types of products we may market to you this way.

6.9 Advertising
To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

6.10 Advertising
For any purpose which we have obtained your consent to.

7. Use of your personal information for Direct Marketing

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

A. Identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
F. Internet or other similar network activity.
I. Professional or employment-related information.

We disclose your personal information for a business purpose to the following categories of third parties:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have sold personal information for direct marketing purposes, where you have given your prior consent.

We transfer your personal information to third parties in the following circumstances:

8.1 Credit Checks
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

8.2 Bookings and performance of contracts
We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.)

8.3 Suppliers of travel and other services
We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third-party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

8.4 Insurance
If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

8.5 Business Function Outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

8.6 Public forums etc.
Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility), then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

8.7 Legal Requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

8.8 Direct Marketing by third parties
We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

8.9 Customer Representatives
If our customer is a business or organization, and we are holding your personal information in your capacity as an associate of that business or organization (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

8.10 Business acquirers
If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

9. You rights and choices

Where we provide your personal information to a third party one of the following two circumstances will apply:

10.1 Processing on our behalf
In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

10.2 Processing on their own account
In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

11. Location of your personal information

1.1 Transfer of personal information overseas
We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.
Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

11.2 Counties to which your personal information is transferred
The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.