Privacy Policy

 

Introduction

Galina International Study Tours Ltd treats your privacy rights seriously & is committed to protecting them within the context of the General Data Protection Regulations (GDPR). This Privacy Policy explains:

  •  who we are & how you can contact us;
  •  what personal data we collect about you, why we require it & how we will use it;
  •  why we will share your data with third party suppliers (e.g. accommodation providers);
  •  security & accountability;
  •  a summary of your legal rights

Our Cookie Policy is covered separately; for details click on the following link: Galina Cookie Policy.

 

Our Details

Galina International Study Tours Ltd is an independent, family-owned company specialising in arranging study tours for schools & other educational establishments. This company is registered in the UK & has the Company number 07106143 & VAT registration number 983216408. If you believe that any aspects of your privacy rights have been infringed by us, please draw this to our attention by contacting our office by post, email or telephone:   

Postal Address:        16 Bridge Street Row, Chester, CH1 1NQ

Email:                          This email address is being protected from spambots. You need JavaScript enabled to view it. 

Telephone:                  01244 314 000 or (Freephone) 0800 801 560

You can also contact the UK Information Commissioner’s Office (ICO) which regulates and enforces data protection law in the UK. Details of how to do this can be found on their website at www.ico.org.uk

 

Definitions

The definitions used in this Privacy Policy are as follows:

  • “we”, “us” & “our” refers to Galina International Study Tours Ltd.
  • “you”, your” refers to you & the group members you represent.
  • “personal data” refers to information that relates to you & which allows us to identify you either directly or in combination with other information we may hold about you.
  • “sensitive personal data” refers to information that relates to you (or you group) that could reveal racial or ethnic origin, physical or mental health or religious beliefs.

 

Collecting & Using Your Personal Data

The following paragraphs detail the circumstance & ways in which we collect personal data from you & how it is used. At all times we try to ensure that we do not collect any data that is irrelevant or unnecessary for the purposes outlined below. For example, we are no longer required by the ferry companies to provide them with passport details so we do not ask for that information.

Responding to an Enquiry:  When you contact us to enquire about our tours, we will ask you directly – either during the course of a telephone conversation or via the enquiry form on our website – for your name, job title, school address & contact details, your destination preferences, duration of visit, curriculum relevance & the year group of the students you wish to take on tour in order that we can respond to your request adequately.

Administrating Your Booking:  Should you decide to make a booking with us, we will require further information from you in order to administrate your booking effectively & fulfil our contractual obligations to you. We will need to contact you either by email or telephone for both administrative & operational reasons such as sending you a confirmation of your booking & payments, to inform you about your tour itinerary or to ask you for passenger lists & passenger information. We will only use your personal data for the purpose for which it is obtained

The passenger information we will require includes the name & gender of all members of your group, an indication of the number of adults or children in the party, dietary requirements, medical conditions & special care & assistance requirements. You must obtain the necessary consent from group members’ parents or guardians to use this personal data & share this information with us.

We will have to share this personal data with third party suppliers in order to arrange your coach travel, ferry or Eurotunnel bookings, accommodation, venues such as museums & (where applicable) guides or representatives who assist your group whilst on tour & insurance providers. In addition we may disclose your personal data when this is required by law within the jurisdiction of any country in which your tour may be based.

The suppliers we use & who process your personal data on our behalf are required by us to comply with our own high security standards for the protection of your personal data. You should also note that they are subject to the same EU Regulations as ourselves.  

Sensitive Personal Data:  Please note that some of the information we require falls into the category of sensitive personal data (see Definitions above). Dietary requirements, for instance, could indicate specific religious beliefs whilst an indication of medical conditions could reveal information about health issues.

By providing any sensitive personal data you explicitly agree that we may collect & use it in order to provide our services in accordance with the contract we have with you. If you do not allow us to process any sensitive personal data, this may mean we are unable to provide all or parts of the services you have requested from us. Please be aware that in such circumstances you will not be entitled to cancel or obtain a refund of any price you have paid. 

Informing You about Tours Relevant to Your Curriculum:  When you provide us with your personal data, we will use your name & school address to send you occasional marketing communications, by post or email, about our tours & the services we provide. We will however carefully consider & balance any potential impact on you or your rights. To that end we will ensure that the marketing materials we send to you are relevant to you & tailored to your interests, determined by your transactional history, your job role or known curriculum &/or destination preferences.

The legal basis for using your personal data in this way is that we have a legitimate business interest in promoting & providing educational tours.  Our legitimate business interests do not, however, automatically override your interests or rights; we will not use your personal data for activities where our interests are overridden by their impact on you.

You can choose, as is your right, to opt out from receiving marketing communications at any time, by clicking on the unsubscribe link at the bottom of any marketing-related email you may receive from us or by telephoning or emailing our office to request that we stop sending you personalised marketing material. 

(Note: Generic or anonymised marketing communications addressed to “The Head of Department” or similar do not identify you as an individual by name, are not regarded as personal data; nor are they governed by the same conditions of use).

 

Security & Accountability

We take appropriate technical & organisational measures to protect your personal data against unauthorised or unlawful processing & accidental loss, destruction or damage to your personal data. When you provide your personal data through our website(s), this information is transmitted across the internet securely.

As described in this Privacy Statement, we may in some instances disclose your personal data to third parties (such as a coach or ferry company or accommodation provider). We require such third parties to have appropriate measures in place to protect your personal data.

The information that you provide to us will be held in our secure systems at our premises or those of an appointed third party. We may also allow access to your information by other third parties who act for us for the purposes described in this Policy or for other purposes approved by you.

We are responsible for ensuring the security & confidentiality of your personal data & we also recognise that this is a dynamic & continuous process. For this reason we have established data protection compliance procedures including:

  • staff training on an on-going basis to ensure a company-wide awareness & understanding of the importance of data protection;
  • internal data audits of our processing activities to minimise the collection & storage of personal data as far as practicable;
  • the anonymization of personal data held where this is possible;
  • the development & refinement of clear, transparent procedures & internal lines of communication understood by everyone;
  • the maintenance & improvement of the security features of our systems.

For the effective management of these internal procedures all of the above will be recorded & documented.

 

Your Rights under GDPR

We respect your right to control your own personal data. Your rights include:

Right of Access: The right to obtain details of the personal data that we hold about you. We will not charge you for making such a Subject Access Request (SAR) except where we feel your request is unjustified or excessive. 

Right to Rectification: The right to ask us to correct inaccuracies in the personal data we hold.  

Right to Erasure (sometimes referred to as the right to be forgotten): The right to ask us to erase your personal data where the following circumstances apply:

  • your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed by us; 
  • where you withdraw consent and no other legal ground permits the processing; 
  • where you object to the processing and there are no overriding legitimate grounds for the processing; 
  • your personal data have been unlawfully processed; or
  • your personal data must be erased for compliance with a legal obligation. 

Where we store your personal data for statistical purposes, we may not be able to comply with such a request where it would likely impair such statistical purposes or where we require your personal data for compliance with a legal obligation or in connection with legal proceedings.

Right to Restrict Processing: The right to restrict the processing of your personal data where: 

  • the personal information which we hold about you is inaccurate. This restriction will be in place for a period to enable us to verify the accuracy of your personal data;
  • the processing is unlawful but you do not want your personal data be erased & request the restriction of its use instead; 
  • we no longer need to process your personal data (e.g. any of the purposes outlined above have been completed or have expired) but we require it in connection with legal proceedings; 
  • you have objected to our processing of your personal data pending the verification of whether or not our legitimate business interests override your interests, rights & freedoms.

Where you exercise your right to restrict our processing of your personal data, we will only continue to process it with your consent or in connection with legal proceedings or for the protection of the rights of other people or for reasons of important public interest.

Right to Data Portability:  The right to receive and transfer the personal data that you provide to us in a structured, commonly used and machine readable format where we process your personal data on the legal bases of: a) your consent; or b) where it is necessary to perform our contract with you. Where you make such a request, we will directly transfer your personal data on your behalf to another controller of your choice (where it is feasible for us to do so). 

Right to Withdraw Consent: The right to withdraw your consent, at any time, to our processing of your personal data which is based on your consent. Where you exercise this right, our processing of your personal data prior to your withdrawal of consent will remain valid.

Right to Object to Processing: The right to object to our processing of your personal data where we process it on the legal bases of our legitimate business interest or your consent to marketing. Under exceptional circumstances, we may be unable to comply with your request where:

  • we can demonstrate compelling legitimate grounds for us to process your personal data which override your interests, rights & freedoms or
  • the processing of your personal data is required for compliance with a legal obligation or in connection with legal proceedings. 

 

Updates

This Privacy Policy is effective from 25th May 2018. We may be obliged to make changes to this Policy from time to time to comply with any alterations to the Regulations that may occur in the future. We will update this Privacy Policy & publish any amended version as soon as practicable. This version of our Policy was published on 11th May 2018.

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