Who we are
This privacy notice sets out how we collect, process and protect your personal data.
What types of personal data do we collect?
We collect personal data about you whenever you make a booking or otherwise interact with us, in person, by telephone or email, via our website, or by any other contact methods. This may include:
Identity Data: including your first, middle and/or last name, title, date of birth, gender and passport details.
Contact Data: including your email address, school or club address and telephone numbers, emergency contact details.
Other Travel Details: including vehicle registration and information required for excursion bookings.
Financial Data: Includes payment information, such as bank details or credit/debit card details required for us to process your booking.
Transaction Data: includes details about payments to and from you and details of services you have purchased from us.
Special category data: including information relating to disabilities, mobility or medical conditions and any dietary restrictions, which may also disclose your religious beliefs.
Marketing and Communications Data: including your preferences about receiving marketing communications from us and your communication preferences.
Usage Data: including personal data which relates to your usage of our website, products and services.
Technical Data: includes information 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.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
When do we collect your personal data?
Direct Interactions: You may provide personal data as a result of your direct interactions with us. This includes personal data that you provide when you engage with us, enquire about our products/services or place a booking with us.
Third Parties: We may collect information about you from a third party when required to do so to fulfil our contractual obligations relating to a booking. For example, if you are travelling with others or a tour has been organised on your behalf, we may have been provided with your personal data by a third party, under the terms of our Information Sharing Agreement.
Automated technologies and interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies (see further below and our cookies policy).
How do we use your personal data?
When you book a tour with NGT Travel we will provide you with an Information Sharing Agreement (ISA) . The ISA asks that you confirm you have gained consent from those whose personal data will be shared with NGT Travel. We ask that you read, sign and return the ISA to us. If you do not complete and return the ISA but do subsequently supply personal data to us, it will be deemed that you have provided explicit consent for the personal data to be used for the purpose(s) stated.
We have set out below a description of the ways in which we plan to your personal data and the legal bases we rely on to do so. We may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
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.
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.
Who do we share your personal data with?
NGT Travel uses selected third-party providers for key services such as transportation, accommodation, meals and excursions. Where we share your personal data with a third-party provider we will only disclose your information to the extent that it is necessary to allow them to perform the services they provide to us.
NGT Travel has concluded Information Sharing Agreements with all key third-party providers however, you should note that certain providers have their own privacy policies. For these providers, we recommend you read their privacy policies so you can understand the manner in which they will handle your personal information. Please let us know if you require specific details of any third-party provides involved in your booking.
We collect and process personal data within the EEA. We may also need to transfer your personal data outside the EEA for the performance of our contract with you, depending upon the destinations to which you travel. For example, we may have to provide personal data to immigration authorities, agents or excursion operators in destination countries.
This may involve sending your personal information between different countries, including countries outside the EEA where controls on data protection may not be as strong as the legal requirements in the EEA. In such circumstances, your information may become subject to the laws of the jurisdiction(s) in which that service provider, or its facilities, are located.
Where personal data is transferred outside the EEA, we will ensure that one of the following applies:
- The transfer is to a country determined by the European Commission as providing an adequate level of protection for personal data (including Privacy Shield for transfers to the US);
- Where we use certain service providers, we may use specific contractual clauses approved by the European Commission which give personal data the same protection it has in Europe; or
- One of the specific derogations provided in Article 49 GDPR applies.
How long will we keep your personal data?
We will only retain your personal data for as long as reasonably necessary for the purpose for which it was collected, 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 to our relationship with you.
To determine the appropriate retention period for personal data, we will 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 though other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Our telephone calls are recorded for quality and training purposes. They are kept for 3 months after which time they are deleted from our system.
How do we protect your personal data?
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 employees, 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request 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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request 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 of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request 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 data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the 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 data but we need to verify whether we have overriding legitimate grounds to use it.
Request 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.
Withdraw 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, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
The following is strictly necessary in the operation of our website.
This website will:
- Remember where you are in the browsing process
The following are not strictly necessary, but are required to provide you with the best user experience and also to tell us which pages you find most interesting (anonymously).
- Offer Live Chat Support
- Track the pages you visit via Google Analytics
- Allow you to share pages with social networks such as Facebook (If available)
This website will not share any personal information with third parties.