Last updated 17 of December, 2020.
The Travel Weekly Group (a company registered in the United Kingdom with registered number 069277031) Travel Weekly Group are committed to protecting and respecting your privacy.
The Websites in the Travel Weekly Group are:
This Policy covers our collection, processing and use of personal data when you use any of our Website.
When you supply any personal data to us we have legal obligations towards you in the way we use that data. For ease of reading, we have divided this Policy into several sections:
- What is personal data and what do we collect
- How and why do we use/share your information
- For how long do we keep your information
- International Data Transfers
- Your Rights
- Contact Details
It is important that you read this Policy together with any other privacy notice or fair processing notices that we may provide on the Website at or around the time that we collect or process personal data about you (for example, fair processing notices that we may display to you at the time that you sign up to receive e-mail updates from us) so that you are fully aware of how and why we are using that data.
This Policy supplements other notices including our Websites’ respective Terms and Conditions and Cookies Policies and is not intended to override or replace them (for this Website’s Cookies Policy please click here). By visiting or otherwise using our Websites, you are agreeing to the practices set out in this Policy. If, for any reason, you do not agree to the terms of this Policy, please stop using the Websites.
We reserve the right to revise or amend this Policy at any time to reflect changes to our business or changes in the law. Where these changes are significant we will endeavour to let registered users of the Websites know. However, it is your responsibility to check this Policy before each use of our Websites – for ease of reference the top of this Policy indicates the date on which it was last updated.
Please note that our Website is not directed at children under the age of 13 (each a "Child" together "Children") and we do not knowingly collect personal information about Children. If you believe we have collected personal information about your Child, you may contact us at firstname.lastname@example.org and request that we cease processing information about your Child.
- What is Personal Data and what do we collect?
What is personal data?
By law all organisations who process your data in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully. For more information about these rights, please see the ‘Your Rights’ section of this Policy.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, delivery address, email address and telephone numbers.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login 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 interact with or access this website.
- Profile Data includes your membership identification number, username and password (if issued), purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our website, products and services.
With your explicit consent we may also collect Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data).
We do not collect any information about criminal convictions and offences.
Data we collect from you when you use the Websites
Voluntary Provision of Data
When you voluntarily supply your personal data to us, for example where you; use the Websites to upload or send personal data (by filling out a form, subscribing to a publication or newsletter, taking part in an online survey, posting a comment, entering a competition, or engaging in similar activities in which you volunteer data about yourself); contact us by post, telephone, email or SMS; report a problem with a Website; we may collect, store and use the personal data that you disclose to us.
The information we collect from you may include your title, name, address, e-mail address, company, job title, birthday, phone number, financial and credit card information – but will depend on precisely what details you volunteer to us and the precise nature of the reason for your submission of that data.
Automated Collection of Data
We may also collect information about you when you visit the Websites through the use of technologies such as cookies. The following are examples of information we may collect:
- information about your device, browser or operating system;
- your IP address;
- information about links that you click and pages you view on our Website;
- length of visits to certain pages;
- subjects you viewed or searched for;
- page response times;
- records of download errors and/or broken links;
- page interaction information (such as details of your scrolling, clicks, and mouse-overs);
- methods used to browse away from a page; and
- the full Uniform Resource Locators (URL) clickstream to, through and from this Website (including date and time).
We use the data described above for several different reasons. Firstly we use it to ensure that the Websites work properly (e.g. to manage technical functionality, such as enabling you to log in to sections that you access with a username and password), it is secure and that you are able to receive the full benefit of them. Second, we use the data to monitor online traffic and audience participation across the Website.
Cookies that relate to these functions will be deployed on your computer automatically, either as you access the Website or as you engage the relevant functionality. If you block these cookies then certain aspects of the site may not operate properly (as they rely on the cookies to work). We undertake these activities because we have a legitimate interest in doing so and, for most of the cookies in question, because we need to do so in order to deliver the parts of the Websites that you are trying to access to you.
Third Party Cookies and Resources
We also use the services of third parties to help us to collect various data about you and the way that you use the Website in order to enable us to better understand your interests – both so that we can produce and serve content to you that we think will be of interest to you, and so that we can ensure that you are shown adverts delivered by third parties which are more likely to be of interest to you.
For details of the cookies that we use on the Website, what those cookies do, and the privacy policies of the third parties which provide them (where relevant) please see our Cookies Policy.
Please note that, while you have to option to consent to specific individual cookies that, unless specifically set out in our Cookies Policy, we rely on our legitimate interests as our condition for processing your personal data on the basis set out in this section (specifically that, where you consent to receiving those cookies, that we have a legitimate interest in using the data that they provide to us to optimise the Websites’ content and to ensure that you are served with relevant commercial communications as you use them). You can stop providing us with that data at any time by removing the relevant cookies from your computer.
- How and why do we use/share your information
We will use your personal data to provide various services that you request from us. Depending on which services you tell us that you want to receive this may include sending you printed publications, sending you e-mail updates and newsletters, enabling you to receive news of and apply for job vacancies, and enabling you to attend and participate in events.
Where an individual nominates you for an award which is to be presented at one of our events, or where you are suggested as a potential judge at such events, then we will process your data on the basis that we have a legitimate interest in doing so in order to ensure that awards are fairly awarded to the most worthy winners.
Where we wish to process your personal data for more than a brief period of time (if, for example we decide to add your details to a short list of potential winners or judges) then we will notify you that this processing is taking place and give you the opportunity to ask us to stop if you are not happy for it to continue.
Where you provide us with your personal data in this way we will use it to the extent necessary to fulfil the terms of the contracts that we enter into with you.
Where you subscribe to receive e-mail updates from us which represent marketing communications we will use your personal data on the basis that you have consented to use using your data for this purpose. You can withdraw this kind of consent at any time – for more information see ‘Your Rights’ below.
HOW WE USE 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 you have asked us to do so, or have otherwise consented to us doing so.
- Where we need to do so to perform a contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we envisage we may use your personal data, the types of personal data we may collect 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 us 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 we may collect||Lawful basis/bases for processing including basis of legitimate interest|
|To register you as a new client or customer||(a) Identity|
(e) Marketing and Communications
|Performance of a contract with you|
|To process and deliver your requests and orders including:||(a) Fulfilment of requests placed by you or on your behalf|
(b) Manage payments, fees and charges
(c) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to recover debts due to us)
(b) Asking you to leave a review or take a survey
(d) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary to comply with our legal / regulatory obligations
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity |
(e) Marketing and Communications
|(a) Performance of a contract with you |
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|To administer and protect our business and the Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)|
(b) Necessary to comply with our legal / regulatory obligations
|To deliver relevant website content, newsletters and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity |
(e) Marketing and Communications
|(a) Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
(b) Necessary for our legitimate interests (to promote products, surveys and services we offer that you may be interested in)
|To use data analytics to improve and optimise the effectiveness and functioning of the Websites, products/services, marketing, customer relationships and experiences||All types of data that we collect||Necessary for our legitimate interests (in optimising the content of the Websites, to define types of customers for our products and services, to keep the Websites updated and relevant, to develop our business and to inform our marketing strategy)|
|To respond to your enquiries where you have contacted us via e-mail or telephone or participated in any surveys or reviews.||(a) Identity|
(c) Marketing and Communications (d) Technical
|Necessary for our legitimate interests (in responding and contacting you regarding the enquiries you have made in relation to the services we offer and reviewing your responses to our surveys).|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity |
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
Sharing your information
Depending on how and why you provide us with your personal data we may share it in the following ways
- we may share your personal information with any member of our company group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;
- with selected official bodies to prevent and detect fraud or credit risks such as: central and local government bodies, HM Revenue & Customs, regulators and other tax authorities, law enforcement agencies, and fraud protection agencies;
- with selected third parties who we sub-contract to provide various services and/or aspects of the Websites’ functionality, such as where we use third parties to host and/or store data for us or use other IT systems supplied by third parties or we use third party plugins provide functionality such as message boards or image hosting services (see “Service Providers” below);
- with analytics and search engine providers that assist us in the improvement and optimisation of this Website as described above; and
- with selected third parties who we contract with to provide professional services such as our insurers, accountants, auditors and lawyers.
We will not share your information with third parties in order for that third party to provide direct marketing communications to you, unless it relates to a specific activity which we are undertaking with a third party (e.g. a competition where a third party is providing the prize) and you have provided your consent for that use. Such activity may have its own terms and conditions relating to the way in which your information may be used, which you will be notified of at the relevant time.
We may also disclose your personal information to third parties in the following events:
- if we were to sell or buy any business or assets, in which case we might disclose your personal information to the prospective seller or buyer of such business or assets as part of that sale
- if Travel Weekly or substantially all of its assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
- if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or if we are compelled to provide your details to a lawful authority in order to aid in the investigation of crime or disorder; and/or
Our service providers provide us with a variety of administrative, statistical, and technical services. We will only provide service providers with the minimum amount of personal data they need to fulfil the services we request, and we stipulate that they protect this information and do not use it for any other purpose. We take these relationships seriously and oblige all of our data processors to sign contracts with us that clearly set out their commitment to respecting individual rights, and their commitments to assisting us to help you exercise your rights as a data subject. The following is a list of our major service providers:
- Where you subscribe to one or more streams of e-mail communications from us (such as newsletters or other e-mails) we use Salesforce’s ‘Pardot’ system to store your details and to manage the sending of those communications to you.
- Where you register to come to one of our events we are likely to use the Delegate Select platform to manage your registration and attendance details.
- Where you become a member of the Connections Community, we use online community platform facilitated by Botsmith Technologies OU to store your details, manage your membership and event participation, as well as communicate member news and information.
- Where you use any part of our Websites that involve job vacancies, your details (including details of any listings or applications that you make) will be stored on and processed via Madgex’s ‘Job Board’ system. Your details will also be passed to the company or individual to which you make any form of application
- Our Websites are hosted on third party servers which are provided to us by a variety of hosting service providers, all of those servers are located within the EEA (or where they are provided on a ‘cloud’ basis appropriate mechanisms are in place to ensure that your data is kept secure) for more information on these mechanisms see ‘Security’ below.
- Where you subscribe to receive a printed publication to you we will share your details with various fulfilment partners (which will depend on which publication you subscribe to) who handle tasks such as printing and distribution for us. We may also pass your details to organisations which handle telephone contacts for us, such organisations may be used to contact you if/when your subscription is due to lapse to remind you that you will need to renew that subscription if you wish to continue receiving the relevant publication.
Links to third party sites
Where we provide links to third party websites, plug-ins and applications that are not affiliated with the Travel Weekly Group those sites will have their own privacy policies and will not be covered by this policy. Such sites are out of our control and if you access them using the links provided, the operators of these sites may collect information from you that could be used by them, in accordance with their own privacy policies. Please check these policies before you submit any personal data to those websites.
- For how long do we keep your information?
We will hold your personal information on our systems only for as long as required to provide you with the services you have requested, to perform the purpose for which that data was collected or for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. For more specific descriptions of how long we will retain your data for specific activities please see the details provided below in respect of certain key areas of processing
Magazine SubscriptionsWhere you subscribe to receive a printed publication from a member of the Travel Weekly Group we will hold your details for the duration of your subscription. We will also keep your details for a period of up to six years after your subscription has lapsed as part of our books and records – which enable us to properly account for our business each year, and which we need to keep on file in order ensure that we are able to properly respond to any disputes which may arise relating to that subscription (or the fulfilment of it by our fulfilment agents).
Newsletter Subscriptions and other e-mail communications
Where you subscribe to receive a newsletter or similar e-mail communication we will hold your e-mail address for the full duration of that subscription in order to ensure that we are able to deliver that subscription to you. We may also hold other details about you which you provide to us (such as your name and title) to personalise those communications to you.
If you unsubscribe from a publication (by way of sending us an ‘opt-out’ message telling us that you do not wish to receive it in the future) we will keep a record of your e-mail address indefinitely in order to ensure that we know that we must not send similar correspondence to it going forwards (this practice is often referred to as ‘supressing’ an e-mail address) – for more information see ’Your Rights’ below.
Use of Online Job Boards
Where you use online job boards featured on our Websites to advertise your availability for, or to apply directly to, job vacancies we will use that data to advertise your ability and to send any applications that you may make to the relevant recipients. That data will be held and made available on the job board for so long as you maintain an active profile. You can deactivate your profile at any time, either by ‘hiding’ your data or by deleting your profile entirely.
If you give us your consent to send you future updates about vacancies that may be relevant to you (which you may do we will use your details in the same way as described in ‘Newsletter Subscriptions’ above. Where we do this we will use the details that you have supplied to us in order to ensure that we are supplying you with details of jobs that are relevant to the interests/qualifications that you have described to us. You can unsubscribe from these e-mails at any time – however, please note that this is a separate service to hosting your profile, and that you will need to unsubscribe from these e-mails separately if you wish to stop receiving them. You can do this by using the ‘unsubscribe’ link contained in each e-mail – for more information see ’Your Rights’ below.
Applications to the Travel Weekly Group
Where you approach us to enquire about employment opportunities or to apply for an advertised vacancy at the Travel Weekly Group we will keep your details and your application on file irrespective of whether you are successful or not. We do this on the basis that we have a legitimate interest in ensuring that we are able to contact you should a suitable vacancy arise in the future.
Usually we will keep your details in this fashion for a period of twelve months or less. However, if you are a candidate who we consider has particularly specialist skills that may be relevant to our business in the future (or where you have gained additional experience or qualifications) then we may keep your details on file for several years.
You are always entitled to ask us not to do this, or to have us dispose of your data if you do not wish for us to retain it – for more information, please see the section on ’Your Rights’ below.
Events and Awards
Where you attend one of our events (as a guest or as a judge) and/or are awarded an award at such an event then we will keep your details on file for up to six years to ensure that we are able to accurately record who attended. If you are awarded an award at such an event then we will keep your details in a similar fashion in order to ensure that we have an accurate record of previous winners. We will keep such details on file for so long as we continue to operate the same or similar events. We do this on the basis that we have a legitimate interest in being able to withhold a list of previous winners for reference purposes.
Please note that where you supply special category personal data to us as part of your attendance at an event (such as disclosing dietary preferences to us which indicate that you suffer from a particular health condition) we will retain that data on file for future reference to ensure that we respect those preferences in the event that you attend future events. You may ask us to stop holding that data at any time and we will always honour and respect those requests.
In some circumstances you can ask us to delete your data: see ’Your Rights’ below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Travel Weekly Group takes the protection of your information very seriously. We have put in place appropriate security measure to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including use of secure servers, encryption and passwords. If you have ever chosen a password, or we have given you one, which enables you to access certain parts of the Websites, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.
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.
- International Data Transfers
If you are based in Europe please note that some of our service providers may be based outside of the UK and/or the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your order, the processing of your payment details, the hosting of one or more of the Websites, and the provision of support services.
Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are either made:
- to a country recognised by the European Commission as providing an adequate level of protection; or
- to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
By submitting your personal data, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your personal data is transferred, please contact email@example.com.
- Your Rights
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a "subject access request").
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a subject access request. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. You may also ask us to erase personal data if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”).
Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right. Further, we are not always obliged to erase personal data when asked to do so; if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest (see the sections of this Policy above which explain how and why we use your information) you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if you dispute the accuracy of that personal data and want us verify that data's accuracy; (b) where it has been established that our use of the data is unlawful but you do not want us to erase it; (c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using the contact details set out here and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulated electronic messages) you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at firstname.lastname@example.org and telling us which communications you would like us to stop sending you.
Your Right to object to automated decision making and profilingYou have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
If you are unhappy with the way that we have processed your data then you have the right to lodge a complaint with your local data and privacy regulator. If you wish to do so then you can write to them using their published contact details. We would however appreciate the chance to address your concerns before you approach the local regulator so please contact us in the first instance.
If you are located in the UK then your local regulator is the Information Commissioner’s Office. If you are resident in the European Union then details of your local regulator are published by the European Data Protection Board.
- Contact Details If you have any queries regarding this Policy, if you wish to exercise any of your rights set out above or if you think that the Policy has not been followed, please contact us at
The Head of Marketing
Travel Weekly Group LTD
52 Grosvenor Gardens
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