Privacy & Cookies Policy

Privacy Policy

This notice describes our Privacy & Cookie Policy and forms part of our website Terms of Use and any Booking Terms & Conditions. By accepting our Term of Use or by visiting www.experfly.co.uk (‘the Website’) you are accepting and consenting to the practices described in this Privacy & Cookie Policy. If you do not accept please refrain from using our site.

The Website is brought to you by Flight PA Ltd, Experfly is a trading name of Flight PA Ltd, Company No. 07938494. Flight PA Ltd (“We”, “Us”, “Our”) believes it is important to protect your Personal Data and we are committed to giving you a personalised service that meets your needs in a way that also protects your privacy. This policy explains how we may collect, store and process Personal Data about you. You should read this policy in conjunction with the Terms of Use and if applicable the Booking Terms & Conditions.

We understand we have a legal duty to protect Personal Data that we collect under the Data Protection Act 1998 (and any law which replaces it, including the new UK Data Protection Bill) (the “DPA”) and the General Data Protection Regulation (EU) 2016/679, (the “GDPR”). For the purpose of the DPA and GDPR, we are the data controller.

Personal Data about our customers is an important part of our business. We shall only use your Personal Data for legitimate purposes and shall not keep such Personal Data longer than is required.

It is important to note that in certain circumstances the provision of Personal Data by you is a requirement to comply with the law or a contract that has been entered into.

 

Personal Data We Collect

The categories of personal data about you that we may collect, use, store, share and transfer are:

Individual – This includes personal data which relates to your identity, such as your first name, middle name, last name, username or similar identifier, marital status, title, date of birth, place of birth, passport number and gender;

Communication – This includes personal data which relates to a method of communication such as your billing address, delivery address, email address and telephone numbers.

Financial – This includes personal data required for us to process your booking in line with our obligations under the Payment Card Industry Data Security Standard (PCI) and for the prevention of fraud;

Enquiry & Bookings – This includes personal data which relates to the enquiries and bookings you have conducted with us;

Marketing – This includes personal data which relates to your advertising preferences, such as your communication preferences;

I.T. – This includes personal data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication 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 our website;

Profile – This includes personal data which relates to your account or profile on our website, such as your username and password, proposals and bookings made by you, your interests, preferences, feedback and survey responses;

Operational – This includes personal data which relates to your usage and operation of our website, such as information about how you use our website, products and services;

Recordings – This includes personal data which is gathered using recording systems.

Health – This includes personal data which is gathered for health and safety purposes including any accident report or claim log or any information you provide about allergies or other medical conditions during the booking process;

Complaints – We may make a written record of key details so that we can take steps to address the complaint.

In addition, we may obtain certain special categories of your data (“Special Categories of Data”), and this Privacy Notice specifically sets out how we may process these types of personal data. The Special Categories of Data are data relating to sexuality, religious beliefs or health.

 

How We Collect the Personal Data

We obtain your personal data from the following sources:

  • Directly from you: in person, via our website, via email, via Live Chat, forms, messages or by telephone;
  • Automated technologies, such as call recording, cookies, server logs and other similar technologies;
  • Third parties, such as: analytics providers; advertising networks; search information providers.

 

Our Basis For Using Your Personal Data

We may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data and the relevant legal basis upon which we will rely (this is what the law allows us to do):

1. For managing your booking we will use information provided by you to fulfil the holiday contract you have entered into. We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

2. To make suggestions and recommendations to you about our products and services that may be of interest to you, for determining and measuring the effectiveness of promotional campaigns and advertising and making sure our marketing is relevant to you. We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;

3. To deal with your enquiries, to send you information you have requested or to provide you with information about your bookings with us. We will rely on the following legal bases to process this personal data:

(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;

(b) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

4. For the development, delivery and improvement of our products and services, marketing, customer relationships and experiences in the provision of products and services to our customers. We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;

5. To help us develop our website to be more useful to you and our customers, for identifying usage trends and for internal purposes of research, analysis, testing, monitoring, customer communication, risk management and administrative purposes, to help us define types of customer for our services, to keep our website updated and relevant and to develop our marketing strategy. We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;

6. To protect our rights or property (including our website), administer and improve our IT services and network security, prevent fraud and facilitate any business reorganisation or group restructuring exercise. We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;

7. In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the Police). We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for compliance with a legal obligation to which we are subject;

8. In order to use your personal data in life or death situations where there is no time to gain your consent (e.g. in the event of an accident and we have to give personal details to medical personnel). We will rely on the following legal basis to process this personal data:

(a) the processing is necessary in order to protect the vital interests of the data subject or of another natural person;

9. In an official role which we have been designated to carry out by an official authority (e.g. the government), or where we are otherwise carrying out tasks which are in the public interest (e.g. which have been designated as such by the government, or which would otherwise be deemed in the public interest). We will rely on the following legal basis to process this personal data:

(a) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

 

Special Categories of Data

In addition, we may lawfully process Special Categories of Data in certain ways. We set out below the purposes for which we may process Special Categories of Data along with the legal bases on which we process these Special Categories of Data (this is what the law allows us to do):

1. We may need to process your health information (for example to enable us to make arrangements for special assistance and any dietary preferences or requirements or for determining your fitness to fly). In relation to the processing of such Special Categories of Data:

(a) We rely on the following legal basis to process such Special Categories of Data:

(i) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

(ii) the processing is necessary in order to protect the vital interests of the data subject or of another natural person;

(b) Additionally, we can only process such Special Categories of Data where:

(i) The processing is necessary in order to protect the vital interests of you or another individual where you or the individual is physically or legally incapable of giving consent;

(ii) The processing is necessary for reasons of public interest in the area of public health for example:

(a) protecting against serious cross-border threats to health;

(b) ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices;

2. We may need to disclose any Special Categories of Data we hold on you, where to do so is in the substantial public interest (for example your health information in order to prevent an epidemic, in the event of illness or injury or some other related emergency, to record any accident or injury or other incident you may suffer when visiting any of our locations or to arrange for you to receive medical assistance), provided that when we do so we provide suitable measures to protect your rights. In relation to the processing of such Special Categories of Data:

(a) We rely on the following legal basis to process such Special Categories of Data:

(i) The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

(b) Additionally, we can only process such Special Categories of Data where:

(i) The processing is necessary for reasons of public interest in the area of public health for example:

(a) protecting against serious cross-border threats to health;

(b) ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices;

3. We may need to process information about your religion (for example to enable an airline to provide you with a meal indicating a particular religion e.g. halal or kosher) or your sexuality (for example to enable us to provide you with a specific holiday which you have requested from our range). In relation to the processing of such Special Categories of Data:

(a) We rely on the following legal basis to process such Special Categories of Data:

(i) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;

(b) Additionally, we can only process such Special Categories of Data where:

(i) You have given us explicit consent to the processing of such Special Categories of Data for the purpose. You may at any time withdraw this specific consent but we will be unable to fulfil your booking in such event and we may have to cancel your booking.

We will always attempt to minimise the amount of sensitive personal data collected unless there is a specific lawful reason (e.g. an emergency situation).

 

How We Share Your Personal Data

We may disclose your personal data to:

1. Our third party suppliers who may process data on our behalf to enable us to provide you with our services, such as Feefo Reviews. Any such disclosure will only be so that we can process your personal data for the purposes set out in this Privacy Notice;

2. Legal bodies, regulators or authorities, including those who request your personal data or to report any potential or actual breach of applicable law or regulation;

3. External professional advisers such as accountants, bankers, insurances, auditors and lawyers;

4 Third parties which are considering or have decided to buy some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a reorganisation, dissolution or liquidation);

5. Third parties operating plugins or content (such as Facebook, Twitter) on our website which you choose to interact with;

6. Your personal data will need to be passed onto the relevant organisations to ensure your travel arrangements can be facilitated. We must pass the information on to the relevant suppliers of your travel arrangements.

Information that you provide to us will be passed on only to the relevant Travel Principals responsible for your travel arrangements or other persons necessary for the provision of those products or services comprising your Booking. The information you provide may therefore be passed to public authorities such as customs or immigration whether specifically required by law or otherwise. This applies to any sensitive information that you give to us such as details of any disabilities, or dietary and religious requirements. Certain information which you provide to us may be passed on to security or credit checking companies and if you are travelling to the United States, the US Customs and Border Protection will receive this information for the purposes of preventing and combating terrorism and other transnational serious crimes.

In making your Booking, you consent to information provided by you being passed on to all the relevant parties needed to complete the Booking; this includes the storage of this data and transmission outside the EEA. Please note outside the European Economic Area (“EEA”), controls on data protection may not be as strong as the legal requirements in the United Kingdom.

If we were not authorised to pass this information to the relevant parties, whether in the EEA or not, we would be unable to arrange your Booking.

 

Other People’s Personal Data You Provide Us

1. If you provide personal data to us about someone else you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Notice.

2. You must ensure the individual concerned is aware of the various matters detailed in this Privacy Notice, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual’s right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

 

Accuracy Of Your Personal Data

It is important that the personal data we hold about you is accurate and current and we take all reasonable precautions to ensure that this is the case but we do not undertake to check or verify the accuracy of personal data provided by you. Please keep us informed if your personal data changes during your relationship with us by contacting us. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.

 

Retention of personal information

We will keep your personal information for limited and appropriate periods of time only and the applicable retention periods will always be linked to our purposes for processing your personal information. This means that the retention periods will vary according to the type of personal information. For example, some transaction information will be kept for a number of years in order to comply with various finance and tax related obligations.

 

Protecting Information

1. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personally identifiable customer information in accordance with accepted good industry practice. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

2. It is important for you to protect against unauthorised access to your password and to your computer. Be sure to sign off when you finish using a shared computer, and it is important you maintain active protection on your device against viruses, spyware other technical threats.

 

Your Rights With Your Personal Data

You have certain rights in respect of the personal information that we hold about you. Details of these rights are set out below. To exercise any of these rights, please contact us.

Your rights:

(a) Access: We will confirm to you whether or not we are processing and using personal information about you, at your request and, if so, provide you with access to and a copy of such personal information and the other details to which you are entitled.

(b) Rectification: We will correct any inaccurate personal data and complete any incomplete personal data (including by providing a supplementary statement) that we hold about you.

(c) Prevention of processing likely to cause damage or distress: We will respect your rights to require us to cease or not to begin processing your personal information for a specific purpose, or in a specific way, that is likely to cause you or any third parties unwarranted damage or distress.

(d) Erasure: We will erase your personal information at your request without undue delay where there is no good reason for us to continue to use it.

(e) Restriction: We will restrict the processing of your personal information in certain circumstances, if you ask us to do so.

(f) Data portability: We will provide you or third parties on your behalf with a copy of any personal information that we hold about you which you have provided to us in a structured, commonly used and machine readable format.

(g) Objection (including objection to direct marketing): We will respect your general rights to object to the processing of your personal information in certain circumstances, including for direct marketing purposes.

(h) Automated decisions and profiling: We do not make automated decisions or profile you based on your data.

 

Links To Other Websites

If you link to another website from our website, you should remember to read and understand that website’s privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.

 

Changes to our policy

We reserve the right to modify this privacy policy from time to time – for example, if we need to reflect changes to the way that we use your personal information. Any changes we make in the future will be posted on our website. You should check back frequently to see any updates or changes to our privacy policy.

 

Contact and complaints

1. We are very keen to hear from you, including if you have any questions, concerns, comments, requests or complaints regarding this privacy policy, our website and/or our use of your personal information. Please contact Data Protection Manager, Flight PA Ltd, Media Factory, 4th Floor, UCLan, Preston, PR1 2HE or email us at admin@experfly.co.uk.

2. If you have any complaints regarding this privacy policy or the way that we use your personal information, you may also contact the UK Information Commissioner at telephone number 0303 123 1113 or https://ico.org.uk/.

Cookies Policy

When we provide services, we want to make them easy, useful and reliable. This sometimes involves placing small amounts of information on your computer. These are called ‘cookies’.

These cookies cannot be used to identify you personally and are used to improve services for you, for example through:

  • Letting you navigate between pages efficiently
  • Enabling a service to recognise your computer so you don’t have to give the same information during one task
  • Recognising that you have already given a username and password so you don’t need to enter it for every web page requested
  • Measuring how many people are using services, so they can be made easier to use and that there is enough capacity to ensure they are fast

See allaboutcookies.org or www.youronlinechoices.eu to learn more about cookies. Visit www.google.co.uk/goodtoknow/data-on-the-web/cookies for a video about cookies.

Please note we use Google Analytics & Facebook Pixel.

Users typically have the opportunity to set their browser to accept all or some cookies, to notify them when a cookie is issued, or not to receive cookies at any time. The last of these options, of course, means that personalised services cannot be provided and the user may not be able to take full advantage of all of a website’s features. Refer to your browser’s Help section for specific guidance on how it allows you to manage cookies and how you may delete cookies you wish to remove from your computer.

Multiple cookies may be found in a single file depending on which browser you use.

The cookies used on this website have been categorised based on the categories found in the ICC UK Cookie guide, as follows:

Category 1: strictly necessary cookies -These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.

Category 2: performance cookies -These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Category 3: functionality cookies -These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as a live chat session. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Category 4: targeting cookies or advertising cookies -These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

By using this website, you agree that we can place all these types of cookies on your device.

 

Google Analytics.

Data gathered is used to help us identify demographics of our users, so that we can serve them better and market accordingly. Part of this use enables us to use Google’s Display Advertising (e.g. Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration or Google Analytics Demographics and Interest Reporting). Using the Ads Settings, visitors can opt out of Google Analytics for Display Advertising and customise Google Display Network ads.

We use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, may show your ads on sites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimise and serve ads based on your past visits to our website.

We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to report how our ad impressions, other uses of ad services and interactions with these ad impressions and ad services are related to visits to our site.

If you have any queries about these, or would like more information, please contact our Data Protection Manager at Flight PA Ltd, Media Factory, 4th Floor, UCLan, Preston, PR1 2HE, or email us at admin@experfly.co.uk.

Last updated: 24th May 2018