1. WHO WE ARE
1.1 At Audley Travel, we strive to protect your privacy, and we recognize that it is important for you to understand how we may use your personal information.
2. PERSONAL INFORMATION WE COLLECT AND HOW WE USE IT
We collect and use various types of personal information about you. Details of this information, together with an overview of the way that we may use it, are set out below:
2.1 PERSONAL INFORMATION PROVIDED BY YOU
Inquiries and bookings
a) We collect personal information from you when you make an inquiry or request a brochure from us. This personal information may include your name and contact information, details about the destinations and countries that you are most interested in, the brochures that you request, and any additional details of your travel plans which you voluntarily give to us. We may also collect details about the best time to contact you and any in-person appointments that you request as well as what prompted you to contact us and any other requests or comments that you make.
We may use this information so that we can provide you with the information that you have requested or contact you if you have indicated you want to hear from us. For example, we may call you once the brochure has been sent to enable you to choose your destination based on the information you provide. We also collect personal information from you when you make a booking through a travel agent or affiliate, if that is how you contacted us.
b) If you book trips with us, we may ask you to provide certain details about your travel arrangements. These details may include information about your passports, emergency contacts, travel insurance arrangements, preferences and special requirements, frequent flier club membership, visa requirements, flights (if you arrange your own flights), and amounts (if any) to be contributed to offset the carbon for your flights through the ClimateCare scheme. We may also collect details about any other friends or family who are accompanying you as part of your booking. Please ensure that you have obtained the consent of any such third parties prior to providing any personal information to us.
We may use this information to help us organize your trip, make bookings on your behalf, and ensure that you (and any other friends or family accompanying you) receive the products and services set out in your itinerary. Where you are a regular customer we may retain some of this personal information so that we can use it when you next book with us to improve your journey and ensure we look after our regular customers.
c) If you have made an inquiry with us, or booked a trip with us, we will send you our Traveller magazine in the mail.
If you do not want to receive Traveller magazine, please let us know using the contact details in section 7.
Honeymoon Gift Service
d) We may collect information if you register to use our Honeymoon Gift Service. Once you’ve confirmed your honeymoon, we will use your information to set up your honeymoon website. You may choose to personalize your honeymoon website as much as you’d like with details about your wedding and honeymoon. In addition, your family and friends may also visit to contribute to your honeymoon and check wedding details. You can include photos (of you and your partner or others) on your honeymoon website, add details about your wedding day (such as the schedule of events), and include other useful information for your guests (such as places they can stay and directions to particular venues). Guests can make a general contribution or buy a particular extra that’s on your itinerary, e.g. a balloon trip. We may use the information you and others provide to administer our Honeymoon Gift Service.
e) If you make a contribution to a honeymoon of friends or family members through our Honeymoon Gift Service either online or by calling us we will collect and use your payment information (including credit or debit card details) in order to process the payment.
Administrative or other business purposes
f) If you sign-up for our email newsletter, we collect your first name, last name and email address. You can unsubscribe at any time by following the “unsubscribe” instructions included in each of our communications. Please note that you may continue to receive certain transactional or informational messages from us.
g) We may collect and use certain other personal information when we correspond with you (whether by telephone, e-mail, or otherwise). For example, we may record both in-bound and out-bound telephone calls or collect information when you use our LiveChat feature to speak with our specialists to ensure quality of service and for training purposes.
h) We may collect personal information from any of our apps including: identity data, contact data, transaction data, device data, usage data, location data (if you wish to use this particular feature, you will be asked to consent to your data being used for this purpose and you can withdraw your consent at any time by disabling location data in your settings). It will also include text in your journal on the app and photographs which you add to the app. We use this information in order to provide you with the functions and features of the app that you have requested.
i) We may collect details about you, such as your user name, when you engage with us on social media (by mentioning or tagging us in a post or contacting us directly) this is so that we can respond to any comments and queries you have.
j) If you apply for job vacancies with Audley Travel, we may collect personal information such as your name, contact details, and employment history in order to process your application and assess your suitability for employment.
k) We may collect personal information when you enter into competitions, promotions, contests, or complete surveys. This personal information may include photos, comments and demographic information to determine eligibility. We use this information to administer your participation in the competition, promotion or contest. The information obtained through our surveys is used in an aggregated, non-personally identifiable form in order to help us understand our customers and enhance our product and service offerings.
l) We may collect certain other information that you give us, for example, when you contact us for a particular reason other than those set out above such as to report problems with our website. We use this information to respond to your inquiry and to ensure that our website works properly and that we operate our business efficiently.
m) We may also collect and use certain special categories of personal information about you on an optional basis, such as details of any relevant health conditions, disabilities, access requirements and special dietary requirements that you may have. We collect this information directly from you to try to ensure that your trip is appropriate for your needs and to try and keep you safe during any trip that you plan through us.
2.2 PERSONAL INFORMATION WE AUTOMATICALLY COLLECT
Websites, apps, marketing and advertising
a) We may collect certain technical information about you when you visit our website or apps. This information may include: the internet domain you use, your IP address or other device identifier, your browser type and version (e.g. Chrome or Internet Explorer), the operating system and platform that you are using (e.g. Windows or Mac), the screen resolution of your device, the dates and times when you access our website or apps, the full URLs of the pages you visit and the websites or links that you use to access our website, login information, details of products or services that are viewed, and the length of visits to certain pages of the website or app.
c) We may use this information for site management and security purposes (such as troubleshooting and testing) as well as to help us improve our website. These technologies help us to recognize you, customize or personalize your experience, and analyze the use of our services to make them more useful to you.
d) Interest-Based Advertising: We work with third-parties such as ad networks and other advertising companies that use their own tracking technologies (including cookies and pixel tags) on our website or app in order to provide you with tailored advertisements across the Internet and on other websites and apps. These companies may collect information about your activity on our website or app and third-party websites and apps (such as web pages you visit and your interaction with our advertising and other communications) and use this information to make predictions about your preferences, develop personalized content and deliver ads that are more relevant to you. This information may also be used to evaluate our online advertising campaigns. For information on how to learn more or adjust your preference, please see How to Control Cookies below.
How to control Cookies
e) You can review your Internet browser settings, typically under the sections "Help" or "Internet Options," to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your settings, you may not be able to use features of the Sites.
We support the Self-Regulatory Principles for Online Behavioral Advertising of the Digital Advertising Alliance (“DAA”). To learn more about certain third-party Cookies used for interest-based advertising, including through cross-device tracking, and to exercise certain choices regarding such cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance of Canada, European Interactive Digital Advertising Alliance or your device settings if you have the DAA or other mobile app. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third-party advertising companies that participate in the DAAC’s AppChoices tool, please visit https://youradchoices.ca/appchoices/.
The opt-outs described above are device- and browser-specific and may not work on all devices. If you choose to opt-out through any of these opt-out tools, this does not mean you will cease to see advertising. Rather, the ads you see will just not be based on your interests.
2.3 PERSONAL INFORMATION WE OBTAIN FROM THIRD PARTY SOURCES
We collect information about individuals from a number of third party sources.
Business partners and service providers
2.4 Our business partners and service providers, such as payment processors, analytics providers and our app solution provider (mTrip), collect personal information and share some or all of this information with us. For example, we receive personal information from vendors to identify potential employment candidates, to coordinate events and programs, to facilitate survey activities, to identify prospective customers and to conduct marketing and analytics.
Publicly available sources
2.5 Where permitted by applicable law, we collect personal information about you that we do not otherwise have (including contact information, employment-related information and vacation interest information) from social media platforms (for example, Facebook, Twitter, Instagram, LinkedIn and YouTube), blogs (for example, WordPress), and other publicly available databases. We use this information to enable us to provide a service that best meets your requirements and preferences.
3. HOW WE SHARE PERSONAL INFORMATION
3.1 We do not sell, rent or disclose your personal information to third parties without your consent, except as described below or as required or permitted by applicable law.
3.2 In order to make sure that we run our business efficiently, and to make sure that you get the service that you expect, we may share your personal information from time to time with the following categories of recipients:
(a) Members of our group, which means our parent company, our subsidiaries, and our parent company’s subsidiaries.
(b) Selected trusted third party business partners (such as the local businesses we partner with in the locations our customers travel to) and service providers (such as Travelport, hotels, and airlines) to perform services related to the contracts we enter into with you.
(c) Third party service providers who provide services on our behalf to assist in providing our services to you such as payment processing services, marketing, advertising or analytics.
(d) Any other third parties if necessary to comply with legal obligations or to enforce agreements (which may include disclosure pursuant to a subpoena, court order or lawful access request by Canadian, US or other foreign governmental authorities, courts or law enforcement agencies).
(e) Any other third parties if this is necessary to protect our or your rights, property, or safety and/or those of others.
3.3 We and our business partners and service providers may store and process personal information in the United States or other jurisdictions in which we have business partnerships and relationships with service providers.
3.4 If you choose to share content with third parties or access third party sharing tools such as widgets, tools, or buttons, we may use your information to share content. As with all links to third party websites, content, and services, we recommend you read the relevant third party privacy policies.
3.5 We may share your personal information in the event of a prospective or completed business transaction including a transfer as part of an asset sale to the purchaser or disclosed to a third party in the event of an insolvency or bankruptcy or other change in corporate control. We may notify you of any change in ownership of Audley Travel as well as of any choices you may have regarding your personal information.
4. SECURITY OF YOUR PERSONAL INFORMATION
4.1 We have put in place physical, electronic, and managerial procedures intended to protect personal information. Of course, we cannot guarantee that interactions with the Services will not be unlawfully intercepted or that your personal data will not be unlawfully accessed by third parties. You can also take additional measures to protect yourself and your information, such as keeping confidential log-in credentials and passwords.
5. ACCESS TO PERSONAL INFORMATION
5.1 You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. You may request access, updating and corrections of inaccuracies in personal information by emailing or writing to us at the contact information set out below. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to their personal information records.
7. CONTACT AND COMPLAINTS
February 6, 2019