Welcome to the Abercrombie & Kent privacy notice.
Abercrombie & Kent respects your privacy and is committed to protecting your personal data. This privacy notice will inform you how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone – regardless of where you contact us from) and tell you about your privacy rights and how the law protects you.
Please also use refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how A&K collects, manages and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel arrangements through us or otherwise provide personal data to us.
This website is not intended for children. The only circumstances in which we collect data relating to children is when you make a booking of arrangements and there are children in your party.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Abercrombie & Kent Limited is the controller and in certain circumstances a processor and responsible for your personal data (collectively referred to as "Abercrombie & Kent", “A&K”, "we", "us" or "our" in this privacy notice).
We have appointed a data protection compliance manager, who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data protection compliance manager using the details set out below.
Our full details are:
Full name of legal entity: Abercrombie & Kent Limited
Name: Data protection compliance manager
Email address: [email protected]
Postal address: St George's House, Ambrose Street, Cheltenham, GL50 3LG
You have the right to make a complaint at any time. There are many data protection supervisory bodies around the world however, we would suggest that you make any complaints to the United Kingdom data protection supervisory body, the Information Commissioner's Office (ICO), ico.org.uk. This would allow us to handle your complaint more effectively and quickly. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 17 April 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change during the course of your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:
(A) Identity data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, or similar identifiers, marital status, title, date of birth and gender.
(B) Contact data
This includes data relating to how you may be contacted, such as your home address, business address, email address and telephone numbers.
(C) Financial data
This includes data relating to your means and methods of payment, such as your bank account and payment card details. We don't retain or store credit card details unless authorised to retain as a security deposit.
(D) Transaction data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
(E) Technical data
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
(F) Profile data
This includes the data that we receive if and when you create a profile on our website and make use of that profile, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
(G) Usage data
This includes information about how you use our website, products and services.
(H) Marketing and communications data
This includes your preferences in relation to whether or not you want to receive marketing from us and also your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data which we may use for various reasons. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
Special categories of personal data
During our interactions, we may collect special categories of personal data about you as detailed below. This may be because you want us to have the information, or we may obtain this inadvertently as result of a group you travel with. It may also be because we need to know certain personal data about you, which is special category data, in order that we can provide you with the best possible service and advise you whether a trip is suitable for you. Health is one of the best examples of this.
E.g. If we receive a group booking from a specific religious association we will inadvertently have details of religious beliefs of those individuals. The same can be said for groups from political associations and trade union associations.
E.g. We are sometimes asked whether certain medication is allowed to be taken into certain jurisdictions, which discloses certain medical conditions.
Other special category of personal data, which we may end up receiving from you include details about your:
• dietary requirements which may disclose your religious or philosophical beliefs
• race or ethnicity
• sex life or your sexual orientation
• political opinions
• trade union membership
• genetic and biometric data
We collect and process the above data only where it is strictly necessary to do so. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time.
3. How your personal data is collected
We use different methods to collect data from and about you including through:
(A) Direct interactions
You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• make a booking of arrangements
• request a quote for arrangements
• subscribe to our newsletter or other publications
• request marketing
• enter a competition, promotion or survey
• give us some feedback
• use our online payment and client portals
(B) Automated technologies or interactions
(C) Third parties
We may receive personal data about you from various third parties, as set out below:
Travel Agents, your travel agent may book travel on your behalf through our Site, in which case your travel agent would supply us with your Identity, Contact and Financial Information. Or, you may interact with a third-party destination management company once you reach your travel destination, in which case they may provide your Personal Information to us in the course of fulfilling your holiday
Technical Data from the following parties:
(i) analytics providers, such as Google, which is based outside the EU
(ii) advertising networks, such as adnxs.com, which is based inside the EU
From time to time, we may run competitions with third parties where we would collect data about you; however, all participants have the option to opt-in or out to receive any information from us.
We have in the past shared client data with Mintel for profiling research purposes. In the future we may share client data with Mintel or another research agency to identify the profile of our client base.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at [email protected].
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
There may be more than one lawful basis on which we may process your personal data depending on the specific purpose for which we are using your data. Please contact us at [email protected] if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.
|Purpose/Activity/Type of Data||Lawful basis for processing including basis of legitimate interest|
Register you as a prospect and initial profile creation
Type of data:
|Necessary for our legitimate interest|
Creation of itinerary and trip planning, which includes the transfer of data to other jurisdictions
Type of data:
|(a) Performance of a contract with you
(b) Necessary for our legitimate interest
To process and deliver your booking including:
(a) Putting final itinerary together and adding additional requests
(b) Transfer of further data to other jurisdictions as requested by the guest
(c) Manage payments, fees and charges
(d) Collect and recover money owed to us
Type of data:
(e) Marketing and Communications.
(f) Special Categories of personal data
|(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
Type of data:
|(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to partake in a prize draw, competition or complete a survey
Type of data:
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Type of data:
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
Type of data:
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy). To ensure marketing is relevant to your requirements or interests|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
Type of data:
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
To make suggestions and recommendations to you about goods or services that may be of interest to you
Type of data:
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
To process and deliver your booking of travel services where you book a Telegraph Travel reader offer, which will include us sharing your personal data with Telegraph Media Group Limited
Type of data:
|Necessary for our legitimate interests (to allow us to run travel offers with the Telegraph Media Group Limited and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and if you have, in each case, you have opted in to receive that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out unsubscribe links on any marketing message sent to you, by contacting your travel consultant/specialist at any time, or by sending an email to [email protected]
Where you opt-out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of arrangements or other such transactions.
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 at [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that 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.
California Privacy Rights. California residents have certain rights under the California Consumer Privacy Act (“CCPA”) and other state laws. For the purposes of this section personal data is referred to as Personal Information.
- Access Your Personal Information. You may request the following information from us: (1) the categories of personal information we have collected about you; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting or selling (if applicable) your personal information; (4) the categories of third parties with whom we shared personal information; and (5) the specific pieces of personal information we have collected about you.
- Delete Your Personal Information. You may request that we delete your personal information. Note that deletion requests are subject to certain limitations, for example, we may retain personal information as permitted by law, such as for tax or other record keeping purposes, if you have an upcoming reservation or to maintain an active account, and to process transactions and facilitate customer requests.
- Do Not Sell Your Personal Information. Under the CCPA, a “sale” of personal information may occur when personal information is transferred to a third party for any form consideration. The use of certain cookies may be viewed as a “sale” under the CCPA. California residents can request to opt-out of the sale of their personal information to a third party. Abercrombie & Kent do not sell information to third parties however to exercise your “Do Not Sell My Personal Information” right with respect to cookies, you can adjust your Targeted Advertising Cookies and other cookie preferences by visiting https://www.akvillas.com/cookie-settings
Please note that we may continue to share your personal information with our affiliates and service providers for essential purposes such as to: comply with law; investigate / prevent potential security incidents or fraud; facilitate the functionality of the Site; provide information to you related to your safety; enforce contracts between us and you; protect our operations, rights, privacy, safety or property, security, and that of our affiliates; allow us to pursue available remedies or limit the damages that we may sustain.
- Exercising Your Rights. To exercise your access or deletion rights, please contact us by email by [email protected].uk. Note that we will not discriminate against you in service or price for exercising your rights.
- Authorized Agent. Youmay designate an authorized agent to submit a request on your behalf. We will require written proof of your agent’s permission to act on your behalf, and will verify your identity directly.
- Shine the Light. California Civil Code Section 1798.83 permits you to request information regarding our disclosure of your personal information (if any) to third parties for the third parties’ direct marketing purposes. To make such a request, please contact us [email protected].uk.
Nevada Privacy Rights. Nevada law (NRS 603A.340) requires a business establish a designated request address where Nevada consumers may submit requests directing the business not to sell certain kinds of personal information that the business has collected or will collect about the consumer. If you are a Nevada consumer and wish to submit a request relating to our compliance with Nevada law, please contact us as at [email protected].
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
(A) Internal third parties as set out in the Glossary.
(B) External third parties as set out in the Glossary.
(C) Specific third parties, such as Telegraph Media Group Limited (“the Telegraph”). Where you contact us regarding a Telegraph Travel offer and go on to make a booking of travel services with us, we will share the following personal data with the Telegraph:
(iii) Identity Data including name, gender, title and date of birth;
(iv) Contact Data including billing address, telephone number and email address;
(v) Transaction Data including details of the travel which you book with us; and
(vi) Marketing and Communications Data including your preferences for the receipt of marketing materials.
(D) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
6. International transfers
If you are travelling outside the European Economic Area (EEA), we do transfer your personal data outside the EEA in order to satisfy our contract with you.
7. 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us at [email protected].
In addition to the above, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for ten years after they cease being customers for tax purposes.
In some circumstances, you can ask us to delete your data: see request erasure below for further information.
In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this instance, we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
(A) Request access to your personal data
(B) Request correction of your personal data
(C) Request erasure of your personal data
(D) Object to processing of your personal data
(E) Request restriction of processing your personal data
(F) Request transfer of your personal data
(G) Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact us at [email protected].
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You will be required to show your identification at an A&K office in the United Kingdom. Please contact us at [email protected] to determine your nearest location.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
• Legitimate Interest
Means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at [email protected]
• Performance of Contract
Means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Comply with a legal or regulatory obligation
Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
• Internal third parties
Other companies in the Abercrombie & Kent Group acting as joint controllers or processors and who are based globally and provide travel related services, IT and system administration, human resources-related services, finance and legal.
• External third parties
i. Service providers acting as processors based globally and providing travel related services.
ii. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, information technology service providers and insurers based globally who provide consultancy, banking, legal, insurance and accounting services.
iii. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based globally who require reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
• Request access
to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.
• Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy
(b) where our use of the data is unlawful, but you do not want us to erase it
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims
(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it
• Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.