1.Important information and who we are
Hidden Cultures’ registered office is at 26 Mingle Lane Stapleford, Cambridge, England, CB22 5SY with company number 11362768.
Email address: firstname.lastname@example.org
Postal address: 26 Mingle Lane, Stapleford, Cambridge, CB22 5SY
Telephone number: 01223 455 171
You have the right to make a complaint at any time to the Information Commissioner’s Office (the ICO), the UK’s supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
2.The personal data we collect about you
Personal data generally means any information about an individual from which that person can be identified (either directly or indirectly). It does not include personal data where the identity has been removed (anonymous data).
The personal data we collect will generally include, but is not restricted to, your name, age, address, phone number, e-mail address, emergency contact information, passport information, travel medical information (where required), insurance details, nationality, residency, trip evaluations, travel and accommodation preferences, comments you provide us, trip destination information, and payment-related information and any other information that we have gathered from correspondence with you, for example in regard to your booking of one of our tours.
We may also need to collect ‘special categories of personal data’ (as defined in the GDPR) such as but not restricted to personal data relating to any disability, medical condition or dietary restrictions which may affect the chosen tour arrangements.
When you book a tour through our website, we will provide a box on the booking form for you to tick which will state that you consent to us processing any special categories of personal data including but not restricted to personal data relating to any disability, medical condition or dietary restrictions. By ticking this box you are providing explicit consent for us to process any special categories of personal data provided by you. If you have any questions on why we need your consent for processing special categories of personal data please contact us.
3.How is your personal data collected?
We use different methods to collect personal data from and about you including through:
Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, telephone, email or otherwise. This includes personal data you provide when you make a booking of one of our tours.
4.How we use your personal data
Lawful bases for processing 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.
To ensure the safety and security of our passengers and products;
To comply with laws, regulations, and immigration requirements.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent if we are required to do so. We will rely on your explicit consent as a legal basis for processing any special categories of personal data received from you.
Purposes for which we will use your personal data
We will process your personal data for the purposes of corresponding with you by post, telephone, email or otherwise, including when dealing with a booking by you for one of our tours, and to provide and improve our website. Your personal data may also be used for the purposes of:
enabling us to better understand your needs as a customer and determine eligibility for our products and services which may also include sending you customer preference and product development surveys if you have provided your consent to receive them;
informing you about our products and services (provided that we have received valid consent from you, if such consent is required);
providing ongoing service and support, including resolution of any issues with the services or products you request from Hidden Cultures; and
to carry out internal accounting and administration of our business.
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 using the details provided above.
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.
5.Disclosures of your personal data
We may be required to share your personal data with third parties for the purposes given above, such as with service providers (for example, providing IT and administration services) and professional advisers. We may also be required to share your personal data with third parties involved in the provision of services under one of our tours, for example with airlines for the purposes of securing a ticket or accommodation businesses.
In addition to the third party travel suppliers outlined above, Hidden Cultures may transfer your personal data to third parties who provide services on our behalf. For example, we may use service providers to authorise and process payments, host our customer service operations, serve advertisements on our website or send email or other communications. For information about the policies or practices of our service providers, please contact us.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We do not envisage transferring your personal data outside the European Economic Area (EEA) but, if we are to do so, we will ensure that a similar degree of protection is afforded to it as if it were to be processed in the EEA using one of the appropriate mechanisms listed in the GDPR.
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 staff, 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.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.
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, regulatory, tax, accounting or other requirements.
9.Your legal rights
Under data protection law, under certain circumstances you have the right to:
9.1Request 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.
9.2Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new personal data you provide to us.
9.3Request 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 for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
9.4Object 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
9.5Request 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:
- If you want us to establish the personal data’s accuracy.
- Where our use of the personal data is unlawful but you do not want us to erase it.
- Where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
9.6Request 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.
9.7Withdraw 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 (and we are relying on consent as a legal basis for processing your personal data), we may not be able to correspond with you or consider you for one of our schemes or grants. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the details provided above.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any your other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in those 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.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could 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.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.