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Website Terms of Use
This page (together with any documents referred to on it) explains to you the terms of use on which you may make use of the website (www.stct.co.uk and www.stct.co.uk) (“the Website”). Please read these terms of use carefully before you start to use the Website. By using this Website, you indicate that you accept these terms of use and that you agree to abide by them. If you do not agree to these terms of use, please refrain from using the Website.
Terms of use
Specialised Travel Concert Touring Ltd – Privacy Policy
Introduction
This is the Privacy Policy for Specialised Travel Concert and Touring Limited, a company registered in England and Wales with company number 00713414, having its registered office at 3rd Floor Craven House, 40-44 Uxbridge Road, Ealing, London, W5 2BS (“STCT”, “We”, “Us” or “Our”).
This Policy sets out how STCT uses and protects any personal data that you provide to STCT (including personal data provided through any booking process and/or through STCT’s website (“Website”)). We are committed to protecting your personal data and this Policy and tells you about your privacy rights and how the law protects you.
STCT provides services to individuals in connection with booking travel arrangements and services, and through providing services to individuals it may collect and process personal data about individuals (“Services”). In addition to this, the Website also collects certain personal data from users, in accordance with this Policy.
STCT and its affiliated Group companies or brands (“STCT Group”) are firmly committed to respecting and protecting the privacy of all personal data received or collected, in strict adherence to Data Protection Legislation (defined below) and best business practice. The STCT Group has established this Policy so that you can understand the care with which We intend to treat your personal data.
How to contact us
We have a data privacy manager who is responsible (together with our Data Protection Committee) for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below. If you have any questions regarding your personal data and how We may use it, including any queries relating to this Policy, please contact us at data@stlon.com or writing to our “Data Privacy Manager” at the head office address noted above.
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.
Terminology used
STCT’s data protection and privacy measures are governed by all applicable data protection and privacy legislation in force from time to time in the UK, including without limitation (i) the UK GDPR (which has the meaning given to it in section 3(10) (as supplemented by section 205(4)) of the Data Protection Act 2018); the Data Protection Act 2018 (and regulations made thereunder); and (ii) to the extent EU GDPR applies, the General Data Protection Regulation ((EU) 2016/679)) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended (“Data Protection Legislation”).
For the purpose of Data Protection Legislation where personal data is provided directly to STCT through use of the Website, email, meeting with you or other means where STCT is determining the way in which that personal data is processed, then STCT will be a data controller of such information.
Personal data and Basis for Collection
Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Where STCT is acting as a data controller, STCT may collect, use, store and transfer different kinds of personal data about you which STCT has grouped together as follows:
If you fail to provide personal data
Where STCT needs to collect personal data by law, or under the terms of a contract STCT has with you (or our client whom STCT acts for) and you fail to provide that data when requested, STCT may not be able to perform the contract it has or is trying to enter. In this case, STCT may have to cancel the Services but it will notify you (or where appropriate, its client) if this is the case at the time.
How is your personal data collected?
STCT uses different methods to collect personal data from and about you including through:
How STCT uses your personal data
STCT will only use your personal data when the law allows Us to, ie, if We have a legal basis for doing so, as outlined in this Policy or as notified to you at the time We collect your personal data, and for the purposes for which it was collected for, unless We reasonably consider that We need to use it for another reason and that reason is compatible with the original purpose. 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 this. Please note that We may process your personal data without your knowledge or consent, where this is required or permitted by law.
Where We act as the data controller for client contact information, We have set out below in the table a description of all the ways We plan to use your personal data, and which of the legal bases We rely on to do so. We have also identified what Our legitimate interests are, where appropriate.
Note that We may process your personal data for more than one lawful ground depending on the specific purpose for which We are using your data. Please contact STCT if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest
|
To register you as a new client and verify your identity (where required) and to provide you with travel arrangements and our Services
| (a) Identity (b) Contact (c) Financial (d) Special category data | Performance of a contract with you Consent (for use of special categories of data)
|
To manage Our relationship with you which will include: (a) notifying you about changes to Our terms or privacy policy (b) asking you to leave a review or take a survey | (a) Identity (b) Contact (c) Profile (d) Marketing and Communications | Performance of a contract with you Necessary to comply with a legal obligation Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our services)
|
To process and deliver the Services including: (a) Manage accounts, payments, fees and charges (b) contacting you and corresponding about your travel arrangements and our Services
| (a) Identity (b) Contact (c) Financial
| Performance of a contract Necessary for our legitimate interests (to recover debts due to us) |
To respond to queries and enquiries
| (a) Identity (b) Contact | Legitimate interests |
To undertake marketing to you
| (a) Identity (b) Contact (c) Marketing and Communications | Consent, unless Our legitimate interests apply and this does not adversely affect your rights as a data subject
|
To administer and protect Our business and this Website (including troubleshooting data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Technical | Necessary for Our legitimate interests (for running Our business, provision of administration and IT services, network security and to prevent fraud) Necessary to comply with a legal obligation |
How your personal data may be shared
Where We act as the data controller, personal data processed by STCT may be shared as follows:
Third party travel service providers
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.
Many of Our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever We transfer your personal data to countries outside of the EEA to other people or companies it will be for one of the legal bases for processing your personal data as indicated above. Where We do so, We will take all steps to ensure that any country to which the personal data has been transferred has suitable protection mechanisms in place to protect personal data, including (if applicable) use of EU Model Clauses in any contract with that third party for steps to be taken to keep personal data secure. We will always ensure suitable safeguards are implemented.
Please contact Us if you want further information on the specific mechanism used by Us when transferring your personal data out of the UK.
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from Us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what We think you may want or need, or what may be of interest to you. This is how We decide which products, services and offers may be relevant for you (We call this marketing). You will only receive marketing communications from Us if you have either requested information from Us, or you have previously purchased travel arrangements from Us, and you have not opted out of receiving that marketing.
Opting out
You can opt-out of receiving marketing communications from Us at any time by contacting Us via the following methods.
1. Email Us at data@stlon.com providing your full name, address and postcode and the email address which you would have originally used.
2 .Write to STCT at 3rd Floor Craven House, 40-44 Uxbridge Road, Ealing, London, W5 2BS
3. Call Our office on 020 8799 8300.
4. You can also be removed from Our email database by clicking the Unsubscribe link located in the footer of all marketing email communications from Us.
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.
Other than in relation to government / public authorities (over whom We have no control), We take appropriate steps to ensure that anyone to whom We pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.
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.
Personal Data Retention
We will keep your information for as long as We need it for the purpose it is being processed for. For example, where you book a holiday with Us We will keep the information related to your booking, so We can fulfil the specific travel arrangements you have made and after that, We will keep the information for a period which enables Us to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that We can continue to improve your experience with Us, this will usually be no longer than 7 years after you have travelled with Us.
We will actively review the information We hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.
Your Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
To exercise any of the above rights please email your request to: data@stlon.com.
Where you exercise your right to erasure or where information is deleted in accordance with STCT’s retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period STCT retains the data.
Where you exercise your right to request access to the information STCT processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We will inform you of this, and our reasons, if this is the case.
Alternatively, We may refuse to comply with your request in these circumstances.
STCT will try to respond to all legitimate access requests within one month. Occasionally it may 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.
If you believe that any of your personal data which We are processing is inaccurate or incorrect please contact Us by calling Our office on 020 8799 8300, by emailing data@stlon.com, or by writing to STCT, 3rd Floor Craven House, 40-44 Uxbridge Road, Ealing, London, W5 2BS.
Children
The Website is not intended for children and STCT will not knowingly collect any personal data from persons under the age of 18. Where, as part of the Services being provided and travel arrangements being put in place, We may collect information about children from you to perform such Services and We will treat such information securely.
Complaints
If you would like to make a complaint in relation to how STCT may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). STCT would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Us in the first instance.
External Websites
The Website may, from time to time, contain links to and from the websites of STCT partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that We do not accept any responsibility or liability for these policies. STCT is not responsible for the content of external internet sites and you are advised to read the privacy policy of external sites before disclosing any personal data.
Remember the Risks Whenever You Use the Internet
STCT is committed to ensuring that your information is secure and has in place reasonable and proportionate safeguards and procedures to protect your personal data. Whilst STCT does its best to protect your personal data, STCT cannot guarantee the security of any information that you transmit to STCT and you are solely responsible for maintaining the secrecy of any passwords or other account information.
Changes to this Privacy Policy and your duty to inform us of changes
As and when necessary, changes to this Privacy Policy will be posted here. Where changes are significant, We may also email all our registered users with the new details, and where required by law, We will obtain your consent to these changes.
This Privacy Policy was last updated in August 2022.