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Red7 - Privacy Policy

Introduction

This is the Privacy Policy for Bargain Travel Bureau Limited, a company registered in England and Wales with company number 01713965, having its registered office at Maria House, 35 Millers Road, Brighton BN1 5NP (“Red7”, “We”).

This Policy sets out how Red7 uses and protects any personal data that you provide to Red7 (including personal data provided through the website www.redsevenleisure.co.uk (“Website”)). We are committed to protecting your personal data and this Policy tells you about your privacy rights and how the law protects you.

Red7 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.  

Red7 and its affiliated Group companies (“Red7 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 Red7 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 an appointed Data Protection Manager who is responsible 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 Protection 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 dataprotection@redseven.co.uk or writing to our “Data Protection 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

Red7's data protection and privacy measures are governed by the (i) the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998 (“Data Protection Legislation").

For the purpose of Data Protection Legislation where personal data is provided directly to Red7 through use of the Website, email, meeting with you or other means where Red7 is determining the way in which that personal data is processed, then Red7 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 Red7 is acting as a data controller, Red7 may collect, use, store and transfer different kinds of personal data about you which Red7 has grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender, and passport or national identity card information;

  • Contact Data includes postal address, email address and telephone numbers;

  • Financial Data includes credit / debit card details, direct debit details or other payment information;

  • Transaction Data includes details about payments to and from you and other details of travel services you have purchased from Red7;

  • Technical Data includes internet protocol address, your login data, browser type and versions, 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 Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses;

  • Usage Data includes information about how you use our Services or submit an enquiry or query through our Website;

  • Marketing and Communications Data includes your preferences in receiving marketing from us and Our third parties and your communication preferences;

  • Individual Data – additional information collected from you in relation to the Services We provide, including telephone calls which We record;

  • Special Categories of Data includes information relating to disabilities or medical conditions which may affect your holiday arrangements and any dietary restrictions which may disclose your religious beliefs.  Special categories of data may also include ethnicity, sexual orientation or other biometric data, although it is unlikely that We will need to collect all of this type of data from you in connection with your holiday arrangements.

If you fail to provide personal data

Where Red7 needs to collect personal data by law, or under the terms of a contract Red7 has with you (or our client whom Red7 acts for) and you fail to provide that data when requested, Red7 may not be able to perform the contract it has or is trying to enter. In this case, Red7 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?

Red7 uses different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us your contact information by filling in forms or by corresponding with us by post, phone, email, through our Website or otherwise. This includes personal data you provide when you making a reservation or booking Red7 for travel Services, when We (or those travel providers for whom we act as an agent) provide your holiday, as well as when you join as a member of Red7; or

  • Enquiries information, when made through the Website or by email, including requests for a brochure or further information relating to the Services We offer; or

  • Participation contact if you participate in a competition, survey or other offer that We might make available to you; or

  • Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources such as contact data from providers, including third party debt agencies; or

  • Automated technologies or interactions.  As you interact with Our Website, We may automatically collect Technical Data about your equipment, browsing actions and patterns.  We collect this personal data by using cookies. Please see Our cookie policy for further details.

  • Telephone interaction.  We record our telephone calls in order to ensure quality with the Services We offer, dealing with complaints or service issues and to ensure that we are capturing data correctly.  However, where we take any payment information from you, We will pause the recording of our telephone call after we have taken your credit card number details, but before you provide Us with your CCV number, so that we do not record your full credit card or other payment information about you.

  • Business travel arrangements. If We are putting arrangements in place for your business travel, then We may undertake credit checks against directors of the business, in order to create a lodge card with any money loaded onto this, as a pre-paid card for leisure spend whilst overseas, or where we are required to make upfront payments to our suppliers.  We will let you know if We are going to undertake such a credit check on the directors of the company, as this would be processing their personal data.

Member login

In addition to the way in which your personal data is collected as outlined above, you will become a member of Red7 when you are a lead party for a booking, or when you are added to a group booking.  If you wish to become a member, then you will need to provide us with your personal data for setting up your “My Red7” account page. To do this, your personal data will be used to create a record in our database and this is where We will communicate with you in order to administer your booking arrangements and will include your name, address, telephone number, email address and preferences.

How Red7 uses your personal data

Red7 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 Red7 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 or member 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 perform anti-money laundering or ID checks

(a) Identity

(b) Contact

(c) Financial

Legitimate interests


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 (on submitting an enquiry or first logging into your MyRed7 dashboard, or through updating your preferences in your MyRed7 dashboard, once registered)

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 Red7 may be shared as follows:

  • with any member of the Red7 Group, which means Red7’s subsidiaries, Red7’s ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006;

  • where Red7 is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply Red7’s or terms and conditions and other agreements;

  • to protect the rights, property, or safety of Red7, Red7’s client, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws;

  • with the authorities, Foreign and Commonwealth Office or other regulatory or official bodies or authorities, as may be appropriate for regulatory purposes; and

  • with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

Third party travel service providers:

  • To fulfil your booking arrangements, appropriate personal data will be passed on to the relevant suppliers of your arrangements / any third party supplier / any other third party (including banks and/or credit card issuers) who need to process your personal data so that your holiday can be provided. The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.

  • If We cannot pass your personal data to the relevant suppliers, We will be unable to fulfil your booking.

  • We will generally use other companies to help provide your travel services, including hotels, airlines, ground handlers and guides, as well as when we mail brochures and send marketing material.

  • We only provide third parties with the personal data they require in order to deliver their services and their use is limited to the services they provide.

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.

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 requested information 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 dataprotection@redseven.co.uk providing your full name, address and postcode and the email address which you would have originally used.

2 .Write to Red7 at our main office address: Red7, Kensington Studios, Kensington Street, Brighton BN1 4AJ

3. Call Our office on 01273 872200.

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.

5. You can update your preferences by logging into you’re MyRed7 section on our Website.

Data security

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:  

  • The right to be informed – this is information on for what purpose we are processing it and what personal data we are processing.

  • The right of access – you have the right to be provided with copies of the personal data of you that we are processing as well as confirmation of the processing we are doing. You can do this by sending a “subject access request” to the contact details noted below for our consideration.

  • The right to rectification – if you think the personal data that we hold on you is wrong you can tell us and we will fix it.

  • The right to erasure (also known as the right to be forgotten) – if you want us to permanently delete the personal data we hold for you then you can ask us to do so.

  • The right to restrict processing – if you do not like how we are using your personal data then you can let us know and we will stop processing it in that way.

  • The right to data portability – if you want us to pass on your personal data to someone else then please let us know. This transfer should not affect the integrity or otherwise damage your personal data.

  • The right to withdraw your consent – you can withdraw your consent for us to process your personal data (if we have relied on your consent to process your personal data) at any time by contacting us. If we have relied only on your consent as the basis to process your personal data then we will stop processing your personal data at the point you withdraw your consent. Please note that if we can also rely on other bases to process your personal data aside from consent then we may do so even if you have withdrawn your consent.

  • Rights in relation to automated decision making and profiling – if we use either automated decision making or profiling then you have a right to know. Also, we need your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.

To exercise any of the above rights please email your request to: dataprotection@redseven.co.uk.

Where you exercise your right to erasure or where information is deleted in accordance with Red7’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 Red7 retains the data.

Where you exercise your right to request access to the information Red7 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.

Alternatively, we may refuse to comply with your request in these circumstances.

Red7 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 01273 872200, by emailing dataprotection@redseven.co.uk or by writing to Red7, Kensington Studios, Kensington Street, Brighton BN1 4AJ.

Children

The Website is not intended for children and Red7 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 Red7 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). Red7 would, contact us in the first instance.

External Websites

The Website may, from time to time, contain links to and from the websites of Red7 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. Red7 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

Red7 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 Red7 does its best to protect your personal data, Red7 cannot guarantee the security of any information that you transmit to Red7 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 on 11 May 2018.however, appreciate the chance to deal with your concerns before you approach the ICO so please

Red7 may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive. They help us to improve our website and to deliver a better and more personalised service. They enable us:

i. To estimate our audience size and usage pattern.
ii. To store information about your preferences, and so allow us to customise our site according to your individual interests.
iii. To speed up your searches.
iv. To recognise you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our website.

Terms Of Use

1. The Website is operated by Bargain Travel Bureau Limited, t/a ‘Redseven’ (company registration number 01713965), whose registered office is at Maria House, 35 Millers Road, Brighton BN1 5NP ("RedSeven").

2. Access to the Website is permitted on a temporary basis and RedSeven reserves the right to withdraw or amend the service provided on the Website without notice. RedSeven shall not be liable if for any reason the Website is not available at any time or for any period. From time to time, RedSeven may restrict access to some parts of the Website, or the entire Website, if required.

3. RedSeven aims to update the Website regularly and may change the content at any time. RedSeven may therefore have to suspend access to the Website, or close it if necessary. Any of the material on the Website may be out of date or incorrect (eg, pricing) at any given time and RedSeven is under no obligation to update such material, however will use all reasonable endeavours to correct errors or omissions as quickly as practicable after being notified of them.

4. You are responsible for making all arrangements necessary for you to have access to the Website and for ensuring that all persons who access the Website through your internet connection are aware of these terms and that they comply with them.

5. RedSeven shall not be liable for and accepts no responsibility for any information presented by a third party including, but not limited to, pricing, liability in connection with any bookings and cancellations made directly with a third party, or any other transactions between you and a third party, and the performance of the contract entered into between you and the third party or any circumstances that may arise during your holiday.

6. All holidays, tours, packages and events shown on the Website are subject to availability and you must always check with RedSeven to see whether a holiday, tour, package or event is available prior to arranging any booking. You may book a holiday, tour, package and or event with RedSeven by contacting RedSeven by telephone, email or fax.

7. Any links provided on the Website to other websites are not intended to provide an endorsement by RedSeven (unless otherwise specified) and RedSeven will have no liability or responsibility for the content of this or those websites whatsoever. You must not establish a link to this Website from any other website without RedSeven’s explicit written consent.

8. RedSeven cannot guarantee that the Website is free from infection by viruses or anything else that has contaminating or destructive properties. You must not misuse the Website by introducing viruses, trojans, worms, logic bombs or other material which is malicious or technologically harmful. You must not attempt to gain unauthorised access to the Website, the server on which the Website is stored or any server, computer or database connected to the Website.

9. Any destination/attraction/tour/travel/event guide information on this Website written or provided by RedSeven is purely for information. RedSeven endeavours to ensure that such information is accurate, however RedSeven provides no guarantee that such information is accurate. This information does not form part of your agreement with the third party and is provided solely as additional background content. RedSeven shall not be held liable in any way whatsoever for any inaccuracy, misunderstanding or expectation drawn from this content.

10. All rights in the Website, including copyright, the content and design of the Website, is owned by RedSeven or used under licence from third party owners. RedSeven is a registered trade mark and no party can make any use of the trade marks (whether registered or not) of RedSeven without its explicit prior written consent. Any use of this Website or its contents, including copyright or storing it or them in whole or part, other than for your personal or non-commercial use is prohibited without the permission of RedSeven. You are prohibited from copying, modifying, transmitting, distributing, selling, displaying, licensing or reproducing any content including images and other media on this Website for any commercial purpose.

11. The transmission of unlawful, threatening, defamatory, pornographic, political or racist material is strictly prohibited.

12. If you breach the provisions of these Terms of Use, RedSeven shall be entitled to suspend or permanently terminate your access to the Website.

13. To the maximum extent permitted by law, RedSeven disclaims all liability, representations, warranties, whether express or implied by statute, custom or usage relating to the information contained in or services offered on this Website. This does not affect your statutory rights under English law. RedSeven shall not be liable for any losses or damages (whether direct, indirect or consequential) whatsoever, whether in contract, tort (including negligence), or otherwise arising from this Website, or from any interruption or delay in accessing this Website.

14. Any material you upload to the Website will be considered to be non-confidential and non-proprietary and RedSeven has the right to use, copy, distribute and disclose to third parties any such material for any purpose.

15. RedSeven processes information about you in accordance with the Privacy Policy displayed on the Website from time to time. By using the Website you consent to such processing and you warrant that all data provided by you is accurate.

16. These Terms of Use may vary from time to time. By using this Website you accept that you are bound by the terms and conditions in force at that time and displayed on this page.

17. If any part of these Terms of Use or any document referred to herein is illegal or unenforceable, such portion(s) shall be excluded from these Terms and Conditions and any relevant document to the minimum extent required and the balance of these Terms and Conditions and any relevant document shall remain in full force and effect and enforceable.

18. These Terms of Use and any documents or policies referred to herein shall govern the entire relationship between the parties to the exclusion of any other terms.

19. It is not the intention of the parties to confer any rights on any third parties by virtue of this Agreement and accordingly the Contracts (Rights of Third Parties) Act 1999 shall not apply to these Terms of Use.

20. These Terms of Use and any disputes that may arise between you and RedSeven will be governed by the laws of England and Wales and the parties shall submit to the jurisdiction of the English courts.

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