The data controller is Indian Ocean Travel (referred to in this Notice as “we” or “us”), part of the Travel Centre Clapham Limited.
We are committed to doing the right thing when it comes to how we collect, use and protect your personal data.
Your privacy matters to us, so please do take the time to read our Privacy Notice which explains:
What types of personal data we collect and why we collect it.
When and how we may share personal data within the Travel Centre Clapham Limited and other organisations.
The choices you have, including how to access and update your personal data.
We have tried to keep this Notice as simple as possible.
Personal Data that we collect
When you register for any of our services, you may provide us with:
Your personal details, including your address, email address, phone number and date of birth.
Your account login details, such as your username and the password you chose.
When you browse our websites or use our mobile apps, we may collect:
Travel preferences. Information about your browsing behaviour on our websites and mobile apps.
Information about when you click on one of our adverts, including those shown on other organisations’ websites.
Information about the way you access our digital services, including operating system, IP address, online identifiers and browser details.
Social preferences, interests and activities.
When you buy our products in our shops or online, we may collect:
Passenger information, passport details, other ID document details.
Insurance details.
Relevant medical data and any special, dietary, religious or disability requests.
Information about your purchases, including what you bought, when and where you bought it, how you paid for it and credit or other payment information.
Information about your browsing behaviour on our websites and mobile apps.
Information about when you click on one of our adverts, including those shown on other organisations’ websites.
Information about the way you access our digital services, including operating system, IP address, online identifiers and browser details. Social preferences, interests and activities.
When you contact us or we contact you or you take part in promotions, competitions, surveys or questionnaires about our services, we may collect:
Personal data you provide when you connect with us, including by email, post and phone or through social media, such as your name, username and contact details.
Details of emails and other digital communications we send to you that you open, including any links in them that you click on.
Your feedback and contributions to customer surveys and questionnaires.
Other sources of personal data:
We may use personal data from other sources, such as specialist companies that supply information, retail partners and public registers.
Your insurance company, their agents and medical staff may exchange relevant personal data and special categories of personal data with us in circumstances where we/they need to act on your behalf or in the interest of other customers or in an emergency.
If you log-in using your social network credentials to connect to our platforms and online services e.g. Facebook, Google+ and Twitter, you will agree to share your user details with us. For example, your name, email address, date of birth, location and any other information you choose to share with us.
We may use CCTV images, IP address and browser details collected in or in the immediate vicinity of our shops, premises, other buildings and cruise ships.
Personal data you provide about other individuals:
We use personal data about other individuals provided by you, such as those people on your booking.
By providing other people’s personal data, you must be sure that they agree to this and you are allowed to provide it. You should also ensure that, where appropriate, they understand how their personal data may be used by us.
Using Your Personal Data
- To provide the products & services you request
- To manage and improve our products, services and day to day operations
- To personalise your experience
- To make contact and interest with you
Marketing Communications
From time to time we may send you relevant offers and news about our products and services in a number of ways, including by email. We may also send you information about other companies’ products and services that we believe may be of interest to you. We will only do this if you previously agreed to receive these marketing communications.
When you book or register with us we will ask if you would like to receive marketing communications. You can change your marketing preferences online, over the phone, using the ‘unsubscribe’ link in our marketing emails, replying STOP to the short code in our marketing text messages or by writing to us (e.g. email) at any time. Of course, the choice is entirely yours, but if you say you do not want to receive marketing information from us this will prevent you from receiving great offers or promotions that may be of interest to you.
You may still receive service-related communications from us. For example, confirming bookings you make with us and providing important information about the use of our products or services.
Sharing Personal Data with Suppliers & Retail Partners
In order to provide products or services requested by you we may share personal data with suppliers of your travel arrangements, including airlines, hotels and transport companies.
We also work with carefully selected suppliers that carry out certain functions on our behalf. For example, companies that help us with IT services, storing and combining data, marketing, advertising campaign, market research, processing payments and delivering products and services.
We may need to share personal data to establish, exercise or defend our legal rights; this includes providing personal data to others for the purposes of preventing fraud and reducing credit risk.
When we share personal data with other organisations we require them to keep it safe, and they must not use your personal data for their own marketing purposes.
We only share the minimum personal data that enable our suppliers and retail partners to provide their services to you and us.
Protecting Your Personal Data
We know how important it is to protect and manage your personal data. We take appropriate security measures to help protect your personal data from accidental loss and from unauthorised access, use, alteration and disclosure.
The security of your data also depends on you. For example, where we have given you or where you have chosen a password for access to certain services, you are responsible for keeping this password confidential.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by organisations operating outside the EEA who work for us or for one of our suppliers. We put in place appropriate protections to make sure your personal data remains adequately protected and that it is treated in line with this Notice. These protections include, but are not limited to, appropriate contract clauses, such as standard contract clauses approved by the European Commission , and appropriate security measures.
Social Media Features
Our websites or mobile apps may contain social media features such as Facebook, Twitter, Google+ and Pinterest that have their own privacy notices. Please make sure you read their terms and conditions and privacy notice carefully before providing any personal data as we do not accept any responsibility or liability for these features.
Accessing & Updating your personal data & complaints
You have a right to ask for a copy of the personal data we hold about you, although you should be able to access online the personal data associated with your account or booking. You can write to us asking for a copy of other personal data we hold about you.
Please include any details to help us identify and locate your personal data. Where we can provide data access, we will do so free of charge except where further copies are requested in which case we may charge a reasonable fee based on administrative costs.
We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details we hold are incorrect, please let us know.
You can also ask for your personal data to be rectified or erased, to object to the processing of your personal data and, where technically feasible, to ask for personal data you provided to be transmitted to another organisation.
We will update or erase your data, unless we have to keep it for legitimate business or legal purposes.
You can also contact us if you have a complaint about how we collect, store or use your personal data. We aim to resolve complaints but if you are dissatisfied with our response, you may complain to the Information Commissioner’s Office.
Please submit your request or complaint at holidays@indianocean.travel
Please note that we may ask you to verify your identity before we can act on your request or complaint. We may also ask you for more information to help ensure that you are authorised to make such a request or complaint when you contact us on behalf of someone else.
Legal basis for processing personal data
We will only collect and use your personal data if at least one of the following conditions applies:
We have your consent;
Example: Customer account
You give us permission to process your personal data when you register for a customer account.
It is necessary for a contract with you or to take steps at your request prior to entering into a contract;
Example: To provide the products and services you request
We need to process your personal data so that we can manage your account or booking, provide you with the products and services you want to buy and help you with any orders and refunds you may ask for.
It is necessary for us to comply with a legal obligation;
Example: Sharing personal data with regulatory authorities
So that you can travel, it may be mandatory (as required by government authorities at the point(s) of departure and/or destination) to disclose and process your personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate.
It is necessary to protect your vital interests or those of another individual;
Example: In an emergency
Your insurance company, their agents and medical staff may exchange relevant personal data and special categories of personal data with us in circumstances where we/they need to act on your behalf or in the interest of other customers or in an emergency.
It is in the public interest or we have official authority; or
Example: Security operations
We may use personal data to respond to and to manage security operations, accidents or other similar incidents, including medical and insurance purposes.
It is in our or a third party’s legitimate interests and these are not overridden by your interests or rights.
Example: To personalise your experience
We may use your personal data to better understand your interests so that we can try to predict what other products, services and information you might be most interested in. This enables us to tailor our communications to make them more relevant and interesting for you.
Where we need to process special categories of personal data, for example health data for medical reasons, we will only do so if one or more additional conditions apply. For example, we have your explicit consent; it is necessary to protect the vital interests of you or another individual and you are physically or legally incapable of giving consent; it is necessary to establish, exercise or defend legal claims; it is necessary for reasons of substantial public interest.
Changes to our notices
This Notice replaces all previous versions. We may change the Notice at any time so please check it regularly on our website(s) for any updates. If the changes are significant, we will provide a prominent notice on our website(s) including, if we believe it is appropriate, electronic notification of Privacy Notice changes.