Skytours & Discount Travel Privacy Notice
1. Background
This Privacy Notice (“Notice”) sets out how Skytours Travel Ltd T/A Skytours travel, skytours.ie Discounttravel.ie, America Direct, golfbreaks.ie, or any other trading names (the Company), whose registered office is at 75 Talbot Street Dublin protects the privacy of your personal information.
Skytours Travel needs to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
We will be a “data controller” for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) for any personal information you provide to us in connection with our relationship.
By providing personal information to us, you agree that this Notice will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Notice. If you do not agree with any part of this Notice, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Notice, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveller's full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.
2. What personal information do we collect?
Personal information has the meaning given under GDPR regulations. Personal information generally means information which relates to a living individual who can be identified from that information, Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements or products on your behalf.
We therefore typically process the following types of personal information about you:
• contact information (such as name, residential/mailing address, telephone number, email address);
• payment account information (credit/debit card details, including card type, card number, security number and expiry date);
• passport details;
• information about your dietary requirements and health issues (if any); and
• other details relevant to your travel arrangements or required by the relevant travel service provider(s) (e.g. airlines and accommodation or tour providers).
When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us. We also collect information that is required for use in the business activities of Skytours including for example, financial details necessary in order to process various transactions. Video surveillance footage used for security purposes, and other relevant personal information you may elect to provide to us.
In some circumstances, we may collect personal information from you which may be regarded as sensitive information under GDPR. Sensitive information may include (without limitation) health information. We will only collect sensitive information in compliance with GDPR for, or directly related to make travel arrangements.
3. How do we collect personal information?
We will only collect personal information in compliance with GDPR laws. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.
Generally, this collection will occur:
• when you deal with us either in person, by telephone, letter, email;
• when you visit any of our websites; or
• when you connect with us via social media.
We may collect personal information about you:
• when you purchase or make enquiries about travel arrangements or other products and services;
• when you enter competitions or register for promotions;
• when you subscribe to receive marketing from us (e.g. e-newsletters);
• when you request brochures or other information from us; or
• when you provide information, or use our services, on social media.
In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you.
4. How do we use your personal information?
We will only process your information, where:
• you have given your consent to such processing (which you may withdraw at any time, as detailed at section 8 below);
• the processing is necessary to provide our services to you;
• the processing is necessary for compliance with our legal obligations; and/or
• the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information (as detailed in sections 5 and 6 below).
In detail: Where you contact us in relation to a travel booking or query, the purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Notice (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc.).
When you book or otherwise arrange travel related products and services through us, we usually act as an agent for the relevant travel service providers (e.g. for a hotel). In this case, we process your personal information as necessary so as to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Notice and for the travel service provider for whom we act as agent (e.g. to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.
We may therefore share your information with our travel service providers such as hotel, airline, car rental, or other providers, who fulfill your travel bookings. Please note that these travel service providers also may use your personal information as described in their respective privacy policy and may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or provide you with your requested services. We encourage you to review the privacy policies of any third-party travel service providers whose products you purchase through us. We will provide you with copies of all relevant travel service provider terms, conditions and privacy policies on request.
We will only use your personal information to send electronic marketing materials to you (including e-newsletters) if you have opted-in to receive them.
5. Is personal information disclosed to third parties?
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Notice. and, in particular, as set out below, and in accordance with your local data protection laws. Note that, in this Notice, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.
Your personal information may be disclosed to the following types of third parties:
• our contractors, suppliers and service providers, including without limitation:
o in each of the circumstances set out in section 4 (“How do we use your personal information?”);
• government agencies and public authorities to comply with a valid and authorised request, including a court order or other valid legal process;
• enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life,
6. Is personal information transferred overseas?
We may disclose your personal information to certain overseas recipients, as set out below. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards as required by GDPR
(a) Travel service providers located overseas
In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers (eg Hotels Transport providers etc.
7. Security of information
We are committed to safeguarding and protecting personal information and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal information provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal information transmitted, stored or otherwise processed. Skytours has implemented various physical, and electronic procedures in order to protect the personal information it holds from loss and misuse, and from unauthorised access, modification, disclosure and interference.
8. Your rights in relation to the personal information we collect
If you wish to:
• update, modify, delete or obtain a copy of the personal information that we hold on you; or
• restrict or stop us from using any of the personal information which we hold on you, including by withdrawing any consent you have previously given to the processing of such information; or
• where any personal information has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such personal information in a suitable format
you can request this by emailing us at info@skytours.ie.
You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us.
9. Social media integrations
Our websites and mobile applications may use social media features and widgets (such as “Like” and “Share” buttons/widgets) (“SM Features”). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.
Your interactions with these SM Features are governed by the privacy policy of the third party company providing them. For more information about the data practices of these third party companies, and to find out more about what personal information is collected about you and how the third party uses such personal information, please refer to their privacy policy directly.
10. Feedback / Complaints / Contact
If you have any enquiries, comments or complaints about this Notice or our handling of your personal information, or wish to inform us of a change or correction to your personal information, would like a copy of the information we collect on you or would like to raise a complaint or comment, please contact us using the details set out below:
Email: info@skytours.ie
Post: Data Protection Officer
Skytours Travel,75 Talbot Street, Dublin 1
11. Changes to our Notice
We may amend this Notice from time to time. If we make a change to the Notice, the revised version will be posted on our website.
This Privacy Notice was last updated May 2018