GDPR - Level 2

Our Website - B2C eCommerce - Online Services - Single controller Policy 

About Us
This is our Privacy Notice and we control the personal information you give us. We are Luxury Leisure Travel. We also trade as Barbados Luxury Travel. We share some or all of your personal data with others.Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements. The following is a list of other parties we use and share your data with:
  • TTNG – Bonding Company 
  • Coldwell Compton Accountant – Accounting Services
  • Facebook, Instagram, Twitter - Social Media Platforms 
  • Microsoft 365 - Cloud and email solutions provider
  • Active IT – IT company
The Personal Data we collect from you
We collect the personal data you provide us when you fill in the blanks in the website forms. A full list can be found clicking this link.

We also collect the following personal data from you:

- order details of any services you order from us online
- information you provide when you telephone us about your order or any other reason
- the information in your emails to us
- from cookies you permit to collect personal data or which are needed to make the site work.
- information you provide when you text us about your order, or any other reason
- information you provide when you whatsapp us about your order, or any other reason
- information you provide face to face when we meet you to discuss your order, or any other reason
- information you provide when you contact us on social media about your order, ask any questions, or any other reason

The PreContract Checks we do
We use your personal data to carry out these checks (which will involve us obtaining information from the relevant agencies or providers of that data):

- to check your age to check you are over 14 years of age
- we are legally obliged to use it to identify and prevent money laundering unless you can provide us with other acceptable proof of identity. Law enforcement bodies may use this information. 
- to check your identity to ensure we are dealing with the right person and prevent fraud

Using your data to fulfil the Contract
To fulfil the contract we use your data to decide whether to enter the contract, allocate you goods, manage and track your order, update you on progress, generate delivery notes and invoices, process payments and administration generally. We may have to use third parties to help us achieve these aims in accordance with our legitimate interests (see below).

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements.

Sharing with others to deliver the contract and for legitimate interests
To help us fulfil the contract we share your data with these parties for the reasons below as it is in our legitimate interests to do so having taken into account all relevant factors around your privacy. If we do not engage these external contractors our prices would have to increase as we would have to engage more staff and buy more infrastructure. We require them to be GDPR compliant and enter data processor contracts with us or ensure their contracts make appropriate statements.

We share data with the third party we buy the Services from to supply to you.

We share personal data with the third party (affiliate, agent or reseller) who has passed you to us so we can provide the ordered service to you. You know who they are as you will have placed your order through them for our service.

We use an external payment processor on the site to process your payment. 

We use an external email provider which we use so we can confirm your order by email and handle any enquiries. They are a data processor for this purpose but also their own data controller. 

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements. The following is a list of other outside parties we use and share your data with:
  • TTNG – Bonding Company 
  • Coldwell Compton Accountant – Accounting Services
  • Facebook, Instagram, Twitter - Social Media Platforms 
  • Microsoft 365 - Cloud and email solutions provider
  • Active IT – IT company
We analyse your use of the site and products you buy or view so we can promote similar or related products, sites or services to you.

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements. The following is a list of the outside parties we use:
  • TTNG – Bonding Company 
  • Coldwell Compton Accountant – Accounting Services
  • Facebook, Instagram, Twitter - Social Media Platforms 
  • Microsoft 365 - Cloud and email solutions provider
  • Active IT – IT company
Who else we share your personal data with for legitimate interest reasons

We share your personal data with the following parties for reasons of legitimate interest:

- we use an outside party to bill and collect.
- we use agents, advisers or others involved in running accounts and services for you and your business or collecting what you or your business owe; 
- we use Third party vendors who help us to manage and maintain the IT infrastructure, website, shopping cart or payment services; 
- we use Logistics and delivery providers who enable us to deliver products you order on our websites; 
- we use professional advisors, such as lawyers, accountants, debt collectors and consultants; 
- we use Companies who assess faults and repair products on our behalf; 

Your data will be shared with the tour operator, airline, transfer company, cruise line and any other third parties relevant to your travel arrangements.

Cookie Policy
You can adjust your cookies preferences using the popup at the bottom of the website.
We analyse your use of our site to present useful adverts to you.

Special Category Data
We collect Sensitive or Special Category Personal data of the type set out below and the reasons for its necessity:

- about your mental and/or physical health. We need this information so we can provide you with the relevant and appropriate arrangements for your individual travel needs subject to availability. If you are unable to give your consent we will not be able to fulfil your holiday requirements with regards to any specific physical needs. 
- your religious or other beliefs. We need this information so we can provide you with the relevant and appropriate arrangements for your individual travel needs subject to availability. If you are unable to give your consent we will not be able to fulfil your holiday requirements with regards to any specific religious needs.
- your sex life or gender orientation. We need this information so we can provide you with the relevant and appropriate arrangements for your individual travel needs subject to availability. If you are unable to give your consent we will not be able to fulfil your holiday requirements with regards to any specific sexual or gender orientation needs.

We require these details in order to ensure we provide you with the correct goods and services ordered.

We may need to share it with outside parties (see list above) in order to get the goods or services delivered to you.

We may also need to provide it to other firms who provide us with services our business needs.

Adding Data Together
We aggregate the following data we collect from different sources and put it together:

- any paper based documents you have or do provide us with
- data you provide over the telephone (including any text or other messages),
and other sources.

Retention of Data
We will keep your data for 7 years after the year you order it so we can comply with contract law issues, product liability issues, insurance issues, company law obligations, record keeping for accounting and tax audits. If there are any complaints or questions on product liability or insurance issues we will keep your data for 6 years after the matter is dealt with. We may hold onto data were there are legal reasons to retain it.

Where we process your personal data to fulfil:

- a contract with you, we will process such personal data until we fulfil that contract and for so long thereafter as may be necessary to keep a record of that contract, which will typically be for 6 years, and to deal with any complaints or claims relating to that contract, which will be until the final resolution of such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or
- a legal obligation (such as anti-Money Laundering, tax and accounting obligations), we will process such personal data for so long as necessary to fulfil that obligation; or
Where we process your personal data based on: 
- our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them); or
-your consent, for example, to send you marketing information, we will process such personal data until you withdraw that consent. Please bear in mind that it may take a short time to process any withdrawal of your consent. We aim to do this as soon as reasonable after receipt of your request, although you may still receive emails that are already in process around the time of your withdrawal. 

Marketing
We will use your personal data only to market to you inline with your permissions given to us.

- by email. We may promote our goods and services to you by email until you unsubscribe. The unsubscribe option will be present in any marketing email we send. We may send you our marketing by email as you have bought goods from us.
- by telephone. Please help us by telling us of any changes to your contact numbers.
-by text and picture message. Please help us by telling us of any changes to your numbers.
- by post to the address we have at any time

We may send you offers from selected third parties from time to time if you have given us permission. You can withdraw your consent at any time.

International Data Transfers
Your personal data maybe processed in a country outside the protection of the EEA or those deemed of adequate protection but we take steps to ensure it is properly protected.
If any party we use to process or share your data with is based in a country not deemed of adequate security under the rules we make sure that they apply appropriate security processes to keep it secure.

Your rights regarding your personal information
Data privacy laws provide you with a number of rights over your personal information. 
You may be entitled to: 

ask us for access to the personal information we hold about you; 

request the correction and/or deletion of your personal information; 

request the restriction of the processing of your personal information, or object to that processing; 

withdraw your consent to the processing of your personal information (where we are processing your personal information based on your consent); 

request for the receipt or the transfer to another organisation, in a machine-readable form, of the personal information that you have provided to us; and

complain to your local data protection authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your personal information. 

If you would like to exercise your rights, please let us know by getting in touch with us as set out in the Contact us section below. 

Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. 

Contact Us
If you have any questions please contact us: 
By filling out the contact us form
Call: 07768740219 
By Postal address: 94 Downham Road South, Heswall, Wirral, CH60 5SE
You can contact Information Commissioner's Office Wycliffe House Water Lane Wilmslow Cheshire SK9 5AF Telephone: 0303 123 1113 Fax: 01625 5245
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