Privacy Policy

Cheekytrip Privacy Policy - Updated 24th May 2018

Privacy Policy

HDC Travel Ltd “Cheekytrip” is committed to protecting your personal data. This privacy policy is produced in accordance with applicable European General Data Protection Regulation (EU 2016/679) (“GDPR”). It will inform you how we look after your personal data collected from you when you visit our website or platforms (“Platforms”), such as (but not limited to), mobile applications, email, text messages, chat channels and social media accounts, or that you provide to us directly. It will also tell you about your privacy rights and how the law protects you. By visiting our website, or other platforms you are accepting and consenting to the practices described in this policy.

Cheekytrip may at any time modify these Terms and Conditions. Cheekytrip will notify you of any changes to these Terms and Conditions either by emailing you) and/or by posting a notice on the website. By continuing to use the website after changes to these Terms and Conditions are made and notified to you, you agree to be bound by such changes.

About Us

Cheekytrip is a trading name of HDC Travel LTD, 7th Floor Trinity Gate, Trinity Square, 32 West Street, Gateshead, Tyne and Wear, NE8 1AD a registered company in England & Wales.

Contact Us

Cheekytrip is committed to providing a high standard of service to all its customers, if you would like to leave any feedback on our site or would like to report a problem please email [email protected]

What are your rights?

You have several rights in relation to your personal data. These include accessing your data, correcting any mistakes, having your data erased, restricting the processing of your data, objecting to the processing of your data, data portability, and rights relating to automated decision making and profiling. In most cases there are conditions attached to these rights. Please see the relevant sections below if you want to find out more.

To exercise your rights please contact our Data Protection Officer at: [email protected] or, to make a request to access your data, follow the instructions below.

You can withdraw consent at any time for us to process your Personal Data to direct market to you by; clicking UNSUBSCRIBE or other opt-out urls on any marketing email you receive from us.

i) Accessing your data (Subject access requests)

You can ask us to confirm if we are processing your personal data and to give you a copy of that data along with further information about how we may use your personal data.

To make a request to access your data please send us your request in writing detailing any information which may help us identify you, such as telephone number used to ring an agent, which agent you have called and you IP address. Please signed and date the written request and send it to the address below along with a photocopy of your passport or driving licence so that we can verify your Identification.

Please send your request to: HDC Travel LTD, 7th Floor Trinity Gate, Trinity Square, 32 West Street, Gateshead, Tyne and Wear, NE8 1AD

You do not have to pay a fee for a copy of your information unless your request is unfounded, repetitive or excessive, in which case we will charge a reasonable amount in the circumstances. We aim to respond to you within 1 month of receiving your request.

ii) Correcting your data

You can ask us to correct any data which is inaccurate or incomplete.

iii) Erasing your data

This right is sometimes referred to as "the right to be forgotten". This is not an absolute right but you have the right to have your data erased, free of charge, in certain circumstances. There are some exceptions to this right which we will explain if applicable.

iv) Objecting to the processing of your data

Objecting to the processing of your data is free of charge. It is not an absolute right but you can object to our processing of your data where it is:

• based on the legitimate interests ground; or
• for the purposes of scientific/historical research and statistics.

You can require us to stop using your data for direct marketing purposes. We will process your request as soon as it is received but it may take up to 14 days for this to be effective.

v) Restricting the processing of your data

 

You can ask us to restrict the processing of your personal data. If processing is restricted, we can store the data and retain enough information to make sure the restriction is respected, but we cannot further process your data.

vi) Data Portability

Request the transfer of your Personal data to another party.

Further information on these rights are available at the Information Commissioner's Office; https://ico.org.uk.

Contact and complaints

If you have any questions about this policy or about how we use your personal data please contact the Data Protection Officer at: [email protected]

If you are unhappy about how we are processing your data or how we have responded to a request or complaint, you have the right to make a complaint to the UK's data protection regulator, the Information Commissioner's Office https://ico.org.uk.

Who is the controller of your data?

When you use our website or subscribe to one of our services or contact us for any other reason, HDC Travel Ltd is the controller of your personal data.

The products and services advertised are provided by third parties. These partners will be the controllers of any information about you that they process in connection with the products and services they provide, and you should read the privacy policy which is available on each of their websites to find out how they will use your data.

The types of Personal Data we collect

When you use or visit our Platforms, we collect information from you. Some of it may be Personal Data. This information includes:

• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your holiday preferences.
• Contact Data includes email address and telephone numbers.
• Technical Data includes [internet protocol (IP) address, your login data, access times, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, settings and platform and other technology on the devices you use to access this website screen resolution, referring URL; (If you are using a mobile device) data that identifies your device, your settings and your location.
• We will collect your email address and holiday details you are enquiring about but only do so if you specifically use this service.
   

Due to the way that our website works we do not collect any information beyond pseudonymous information or that described above.

Where and how we collect Personal Data

From you - Most of the data that we process will be data that we collect from you directly when you use the website. Most of this is pseudonymous meaning it is very difficult to know who you are personally.

Passively We also collect data about you based on your actions, for example we collect data about how and when you use the Website. We, and our partners collect some of this data by using cookies, web beacons and pixel tags. A cookie is a small file that is placed on your device, which enables a server to identify that device and allows us to offer the best services possible by allowing us to recognise you as a unique user and provide us with information about how you use our website. Cookies are commonly used on the Internet and do not harm your computer system. Web beacons and pixel tags are similar to cookies and allow us to collect information about how you use our website and help us to offer you the best service. This data is pseudonymous meaning it is very difficult to know who you are personally.

From third parties Analytics providers such as Google, advertising networks such as DoubleClick & Intent Media and search information providers such as Intent Media. In the case of Intent Media who provide personalized shopping experiences and advertising and use online identifiers to identify visitors, you can review their privacy policy & options to Opt out at http://intentmedia.com/privacy-policy. Occasionally when investigating issues raised by the consumer themselves, we may request to review the call or communication undertaken to assist the consumer. We will ask for your consent to review this data.
In the case of Google, you can find more information on how they use your data by viewing their privacy policy here.
 

Why we collect this data;
We only collect the relevant data needed to enhance and personalise your experience while using our website, to investigate any complaints you may raise with is or to send you the services you have told us you want to receive.

Legal grounds for processing your personal data

Data protection laws require us to tell you what legal basis we use for processing your personal data. These bases are set out in the applicable data protection law. We generally use the following grounds:

• the processing is necessary to perform a contract with you, or to take steps requested by you before entering into this contract;
• the processing is in our or someone else's legitimate interests, and these interests are not overridden by your interests or rights in the protection of your personal data;
• you have given your consent to the processing of your data; or
• the processing is necessary to meet a legal obligation which applies to us.
   

Personal Data shall only use your Personal Data for the purposes outlined below and we shall not keep the Data longer than is necessary to fulfil these purposes.

Detailed information

Purpose	Type of data/ processing activity	Legal Ground relied on
Marketing of holidays	Email Address	Consent
Sending specific Enquiries to our agents via email form	Name, Address, Email address, Telephone number, holiday enquiry details	Consent
Answering customer complaints and queries.	Name, Address, Email address, Telephone number	Consent
To conduct satisfaction surveys with customers.	Email Address, IP Address	Legitimate interest
To understand the users of our Platforms and services and improve our Platforms and services, including the provision of relevant or tailored advertisements and how users use our websites	Email Address, IP Address, search data, Management information, other statistical information	Legitimate interest

Sharing Personal Data

Partners (third parties or Service Providers): We may need to share your Personal Data with our travel Partners (Agents), for example, any feedback on their services, in which case we will obtain your consent beforehand. The types of third party service providers who we share your data with include companies which help us understand our customer behaviour or help improve our website. We may also share anonymous aggregated usage information with others. We also share data about specific holiday enquiries as requested by yourself, with the agent intended.

Sale or Reorganisations: If we sell or buy any business or assets, we will disclose your personal data to the prospective seller or buyer of such business or assets, and if we or part of our business is acquired by a third party, personal data about our customers will be transferred to that third party.

As required by law: In order to assess and defend any legal claims made against us, we may share your personal data with our legal advisors and claims handlers. We may also share your information with law enforcement and government agencies where this is reasonable for the prevention and detection of crime or if we believe a claim is being made fraudulently.

Storing and protecting your Personal Data

All of the data described above are stored directly on our Servers which are located within the UK or the EU and is protected by firewalls and only accessible by employees with delegated authority. Although we take all means within our control to ensure data provided over general use of the internet is secured, we cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.

If we need to transfer your Personal Data outside the EU to a third party as described above, we will ensure that your personal data is kept securely, is only used for the purposes set out in this Privacy Policy and is afforded equivalent protection as it would be if it were processed in the UK by including relevant contractual clauses.

How long we keep your Personal Data

We'll only keep your personal data as long as we need it and ensure it is securely destroyed when it is no longer required. We will only keep your Personal Data for the purposes outlined in this Policy. If you have withdrawn your consent for us to use your Personal Data and we have no other lawful basis to use such data, we will remove the data as requested.

Frequency of communication and content via our Newsletter

If you sign up to our newsletter to receive offers, you are entitled to unsubscribe from our newsletter and can do so at any time either via our unsubscribe links or by contacting us directly.

When signing up to our newsletter you may receive emails containing the following information:

• Newsletters
• Further information about the services we offer
• New product launches by HDC travel limited or our group companies.

Cookies and tracking tools

Cookies

We use cookies to improve your web browsing experience on this website. This is a commonly used feature on most websites you visit.

Cookies are small files of information which are stored on your device which enable us to improve our site and provide a personalised service to you. Some cookies may only last for the duration of your session on the site whilst others may remain on your device that is designed to remember you for your next visit. We may collect your IP address, browser type and search criteria for statistical information; however, this does not identify any individual.

You can read more information at http://www.allaboutcookies.org.

You may refuse to accept cookies via your browser settings by disabling the storing of cookies.. However, if you select this option, certain sections of the site may not function correctly or display the relevant information. You can only use this site and refuse cookies by this method; otherwise, by using this website, we will automatically issue cookies.

Why we use cookies?

• Increase the speed of the search
• To customise our site relating to your searches
• Give us usage patterns to analyse
• Recognise you when you return to our site
• Collect Information from the forms you select when searching for holiday offers
• To display the correct details for the purposes of our marketing
• To remember previous holiday searches, making it more efficient for you

Visiting this website with your browser settings adjusted to accept cookies, informs us that you consent to our usage of cookies.

Cookies may also be used by third parties who are included on the website in order to display targeted advertising or services. We do not provide any personal information to any of these third parties.

Our site may contain links to and from partner sites or networks. Please note, these websites have their own cookies policies and we do not accept any responsibility or liable for their policies.

Tracking tools

We use several common tracking tools on the Platforms and those platforms of our advertisers and partners. We use these tools in order to:

• Collect demographical and interest data about you, which enables us to improve our website and deliver relevant information. This is typically done so by using google analytics which is common internet practice
• We work with other online advertising companies to display targeted advertising on our website or when you leave our website to visit a similar platform. This will only be you search data and or IP address.
• We may also use other tracking methods such as pixels for the purpose of determining who has seen and engaged with the promotion newsletter and often serves to reduce communication where engagement is not occurring.

Third-party websites

Our website may direct you to one of our partner website or to another third party who offer a similar service or product to us. We suggest that you review their privacy policy upon use of these websites and although we undertake diligence to ensure that the third parties are operating similar procedures to ourselves but we cannot be held legally responsible for any third party failures.

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