Privacy Policy

Privacy Policy – Riverside Travel Limited

Last updated: 30/09/2019

Questor Travel are committed to protecting and respecting your privacy.

Questor Travel, a trading name of Riverside Travel Limited (“We” or “Riverside Travel”), are committed to protecting the privacy of the individuals we encounter in conducting our business.

“Personal Information” is information that identifies and relates to you or other individuals (the Data Subject).

Riverside Travel Limited is the Data Controller for all Personal Information collected. This Privacy Notice covers Riverside Travel Limited and its websites, mobile applications and mobile websites except where you are notified of another privacy notice.

We will only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this. We have set out below, in a table format, 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 us to discuss further.

 

Purpose/Activity Lawful basis for processing including basis of legitimate interest
To register you as a new customer Performance of a contract with you
To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

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) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(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) 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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (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 a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you If you have given your consent for us to do so
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences If you have given your consent for us to do so
To make suggestions and recommendations to you about goods or services that may be of interest to you If you have given your consent for us to do so

 

Where we are processing your data for marketing purposes, our lawful basis for doing so is the consent that the data subject has provided. You can change or remove your marketing preferences at any time. Please see “Marketing Preferences” below. A data subject can withdraw their consent at any time.

This Privacy Policy describes how we handle Personal Information that we collect through;

  • This website (the “Site”);
  • Our social media pages
  • Other social media content, tools and applications (our “Social Media Content”)

Collectively, these are referred to below as the “Questor Travel Electronic Services”. We may collect your information through other means (for example, telephone calls, emails, other communications, medical professionals, or other third parties involved in our business dealings with you).

The General Data Protection Regulation provides the following rights for individuals:

  1. The right to be informed;
  2. The right of access;
  3. The right to rectification;
  4. The right to erasure;
  5. The right to restrict processing;
  6. The right to data portability;
  7. The right to object;
  8. Rights in relation to automated decision making and profiling.

If you wish to access any of the rights set out above, we may ask you for additional information to confirm your identity and for security purposes, before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

  1. Who To Contact About Your Personal Information
  2. Personal Information That We Collect
  3. How We Use Personal Information
  4. International Transfer of Personal Information
  5. Sharing of Personal Information
  6. Security
  7. Retention of Personal Information
  8. Personal Information of Other Individuals
  9. Marketing Preferences
  10. Access and Correction Requests, Questions and Concerns
  11. Other Information We Collect Through Questor Travel Electronic Services
  12. Third Party Services
  13. Use of Questor Travel Electronic Services by Minors
  14. Complaints
  15. Changes to This Privacy Policy
  16. Who to Contact About Your Personal Information

If you have any questions about our use of your Personal Information, you can contact our Compliance Team via email: compliance@questor-travel.co.uk. You can also write to the Compliance Team, Riverside Travel Ltd, Third Floor Riverside House, 40-46 High Street, Maidstone, ME14 1JH.

  1. Personal Information That We Collect

We will only collect data than is necessary for the purpose of the processing.

You do not have to provide your personal information to us, but if you do not provide certain information, we will only be able to provide limited products and services to you. For example, where you refuse to provide mandatory travel information, we will not be able to arrange travel for you.

Depending on your relationship with us (for example, as prospective customer, existing customer, member of the booked party), Personal Information collected about you and other passengers may include:

  • General identification and contact information (for all passengers)

Your name; address; e-mail and telephone details; gender; date and place of birth; passwords (including on our systems); activity records, such as driving records; photos; visa information; relationship to the lead passenger; and date and cause of death, injury or disability.

  • Identification numbers issued by government bodies or agencies

Passport number; tax identification number; visa details; or driver’s or other license number.

  • Financial information and account details

Payment card number; bank account number and account details; and other financial information.

  • Medical condition and health status

Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.

  • Other sensitive information

In certain cases, we may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud. We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).

  • Telephone recordings

Recordings of telephone calls to our representatives and call centres; information to investigate crime, including fraud and money laundering (for example, we may have to provide this as part of a wider investigation).

  • Information enabling us to provide products and services

Travel arrangements including reservation numbers; ages of passengers or policy numbers.

  • Marketing preferences and customer feedback

You may let us know your marketing preferences, enter a contest or prize draw or other sales promotion, or respond to a voluntary customer satisfaction survey.

  • Social media account

We may receive certain Personal Information about you when you use our Social Media Content, including your social media accounts ID and profile picture, and other Personal Information that you provide to us. If you elect to connect your social media account provided by another social media service provider to your account(s) on any of the Questor Travel Electronic Services, Personal Information from your social media account will be shared with us, which may include Personal Information that is part of your social media account profile or your friends’ profiles.

We may collect special categories of personal information, including details about your health or any medical conditions.

We use special categories of personal information to:

  • determine your fitness to travel (for example, if you have a pre-existing medical condition which may make it unsafe to travel)
  • provide you with special assistance (for example, where you tell us that you need an oxygen tank or a wheelchair) on our flights, at destinations or activities or at airports
  • fulfil special dietary requirements you tell us about
  • address a security or medical incident
  • comply with legal or regulatory requirements
  • as you may authorise or consent to additionally from time to time

We do not generally collect special categories of personal information from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it and handle it with extra care. We also share this information with third parties (who help manage our business and deliver services [such as those parties who provide wheelchairs at airports]), and we transfer it globally.

Where you (or any passenger travelling) provides us with special categories of personal information you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which it was collected.

Making a booking on behalf of another person

If you are making a booking on behalf of another person(s), it is your responsibility to obtain their consent to make the booking and share their details with us (as anticipated by this Privacy Notice), which we will assume that you have done prior to making the booking. It is also your responsibility to represent that person during the booking process, which means that you will need to provide us with the information required to make a booking, such as the full name and passport details of the person concerned and explain to that person how we will use their personal information as set out in this Privacy Notice.

  1. How We Use Personal Information

We use this Personal Information to:

  • Communicate with you and others as part of our business.
  • Send you important information regarding changes to your trip, other terms and conditions, the Questor Travel Electronic Services and other administrative information.
  • Process your payments
  • Provide improved quality, training and security (for example, with respect to recorded or monitored phone calls to our contact numbers).
  • Prevent, detect and investigate crime, including fraud and money laundering, and analyse and manage other commercial risks.
  • Carry out market research and analysis, including satisfaction surveys. Provide marketing information to you (including information about other products and services offered by selected third-party partners) in accordance with preferences you have expressed.
  • Identify you to anyone to whom you send messages through the Questor Travel Electronic Services.
  • Allow you to participate in contests, prize draws and similar promotions, and to administer these activities. These activities may have additional terms and conditions, which could contain additional information about how we use and disclose your Personal Information, so we suggest that you read these carefully.
  • Facilitate social media sharing functionality.
  • Manage our infrastructure and business operations, and comply with internal policies and procedures, including those relating to auditing; finance and accounting; billing and collections; IT systems; data and website hosting; business continuity; and records, document and print management.
  • Resolve complaints, and handle requests for data access or correction. Comply with applicable laws and regulatory obligations (including laws outside your country of residence), such as those relating to anti-money laundering and anti-terrorism; comply with legal process; and respond to requests from public and governmental authorities (including those outside your country of residence).
  • Establish and defend legal rights; protect our operations or those of any of our group companies or insurance business partners, our rights, privacy, safety or property, and/or that of our group companies, you or others; and pursue available remedies or limit our damages.
  • Riverside Travel Ltd does not take part in any automated decision making, including profiling.

In an emergency, we may use your personal information to:

  • provide in-flight or on the ground medical support
  • provide accurate and updated information to persons directly affected by an emergency such as your next of kin and other relatives
  • provide information to emergency services, hospitals and clinics if you are admitted to them on your medical condition
  • communicate to embassies and consulates regarding their citizens
  • arrange a hotel booking in the event re-accommodation is necessary
  • as you may authorise or consent to additionally from time to time
  1. International Transfer of Personal Information

Your personal information may be transferred outside your country of residence.  Some other countries are subject to different standards of data protection than your country of residence.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, and we only transfer personal information to another country where:

  • we are satisfied that adequate levels of protection are in place to protect your information; and
  • the transfers are fully managed to protect your privacy rights and interests and are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.

You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.

  1. Sharing of Personal Information

Riverside Travel Ltd may make Personal Information available to:

We share your personal information in the manner and for the purposes described below:

  • with third parties who deliver products and services to us;
  • bank and payment providers to authorise and complete payments;
  • with governments, government organisations and agencies, border control agencies, regulators, law enforcement and others as permitted or required by law, in relation to legal requirements as apply from time to time when travelling to or from a particular country, and to generally comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
  • with third parties whose products or services you are purchasing via us or otherwise such as airlines, tourism agencies, hotel, transfer and car hire companies, tour and excursion providers or to tour operators, including if there is a problem with your booking so that we or the tour operator can resolve it with you;
  • in connection with your social sharing activity, such as if you connect your social media account provided by another social media service provider to your Questor Travel Electronic Services account or log into your Questor Travel Electronic Services account from another social media account. By connecting your Questor Travel Electronic Services account and your other social media account you authorise us to share information with the provider of your other social media account and you understand that the use of the information we share will be governed by the other service provider’s social media website’s privacy policy. If you do not want your Personal Information shared with other users or with your other social media account provider, please do not connect your other social media account with your Questor Travel Electronic Services account and do not participate in social sharing on the Questor Travel Electronic Services.
  • After purchase review

We have contracted with Trustpilot to contact you so that you can provide a review of your experience with us. You will receive an email around 14 days after the start date of your policy. We would be grateful if you could take the time to complete a review as this is invaluable to us in developing our website, products and services. We provide Trustpilot with your email address in order to review and improve our service – this data is processed under the lawful basis of legitimate interests.

If you have been contacted by Trustpilot and do not wish to be contacted by them again, you can unsubscribe by clicking on the relevant link on the Trustpilot email that you have received.

  1. Security

Riverside Travel will take appropriate technical, physical, legal and organisational measures, which are consistent with applicable privacy and data security laws. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any Personal Information you might have with us has been compromised), please immediately notify us. (See the “Who to Contact About Your Personal Information” section above.)

When Riverside Travel provides Personal Information to a contracted service provider, the service provider will be selected carefully and required to use appropriate measures to protect the confidentiality and security of the Personal Information.

  1. Retention of Personal Information

Riverside Travel always takes reasonable steps to ensure that the Personal Information we process is reliable for its intended use, and as accurate and complete as is necessary to carry out the purposes described in this Privacy Policy. Riverside Travel will retain Personal Information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

  1. Personal Information of Other Individuals

If you provide Personal Information to Riverside Travel regarding other individuals, you agree: (a) to inform the individual about the content of this Privacy Policy; and (b) to obtain any legally-required consent for the collection, use, disclosure, and transfer (including cross-border transfer) of Personal Information about the individual in accordance with this Privacy Policy.

  1. Marketing Preferences

We use personal information to let you know about products and services that we think may be of interest to you based on interests you have expressed previously, either by quoting or purchasing.

We will provide you with regular opportunities to tell us your marketing preferences, including in our communications to you. To tell us your marketing preferences or to opt-out, you can also contact us by e-mail at: sales@questor-travel.co.uk or by writing to: Customer Service, Riverside Travel Ltd, Third Floor, Riverside House, 40-46 High Street, Maidstone, ME14 1JH.

  • Receiving e-mail messages and text messages from us:

If you no longer want to receive marketing-related e-mails or text messages from Riverside Travel on an ongoing basis, you may opt-out of receiving these marketing-related messages by clicking on the link to “unsubscribe” provided in each message or by contacting us at the above addresses.

  • Receiving telephone communications and postal mail from us:

If you no longer want to receive mobile messages, telephone communications or postal mail from Riverside Travel on an ongoing basis, you may opt-out of receiving these marketing-related communications by contacting us at the above addresses.

  • Our sharing of your Personal Information with selected third-party partners for their marketing purposes:

If you have provided your consent we may share your Personal Information on an ongoing basis with our third-party partners for their own marketing purposes. If you change your mind, you may opt-out of this sharing on an ongoing basis by contacting us at the above addresses.

We aim to comply with all opt-out requests within a reasonable period. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of third parties with whom we have already shared your Personal Information (i.e., to those to whom we have already provided your Personal Information as of the date on which we respond to the opt-out request). Please also note that if you do opt-out of receiving marketing communications from us, we may still send you other important administrative communications from which you cannot opt-out.

  1. Access and Correction Requests, Questions and Concerns

In certain countries, an individual may have the right to access, correct or object to the use of, or request deletion or suppression of Personal Information on certain grounds. Please contact us as set out in the “Who to Contact About Your Personal Information” section above with any such requests or if you have any questions or concerns about how we process Personal Information. Please note that some Personal Information may be exempt from access, correction, objection, deletion or suppression rights in accordance with local privacy and data protection laws.

  1. Other Information We Collect Through Questor Travel Electronic Services

“Other Information” is any information that does not reveal your specific identity, such as:

  • Browser and electronic device information;
  • Information collected through cookies, pixel tags and other technologies;
  • Demographic information and other information provided by you; and
  • Aggregated information

 

We and our third-party service providers may collect Other Information in a variety of ways, including:

  • Through your internet browser or electronic device:

Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e., your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit and page(s) visited. We use this information to ensure that the Questor Travel Electronic Services function properly.

  • Using cookies:

Cookies are pieces of information stored directly on the computer you are using. Cookies allow us to recognize your computer and to collect information such as internet browser type, time spent using the Questor Travel Electronic Services, pages visited, language preferences and relevant country website. We may use the information for security purposes, to facilitate navigation, to display information more effectively, to personalize your experience while using the Questor Travel Electronic Services, or to gather statistical information about the usage of the Questor Travel Electronic Services. Cookies further allow us to present to you the advertisements or offers that are most likely to appeal to you. We may also use cookies to track your responses to our advertisements and understanding your online behaviour and search journeys.

Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “Other Information We Collect” section above, we may use and disclose Other Information for all the purposes for which we use and disclose Personal Information.

  1. Third Party Websites

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Questor Travel Electronic Services link. The inclusion of a link on the Questor Travel Electronic Services does not imply endorsement of the linked site or service by us or by our group companies.

Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the information security practices) of other organizations, such as Facebook, Twitter, Apple, Google, Microsoft®, RIM/Blackberry or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or electronic device manufacturer, including any Personal Information you disclose to other organizations through or in connection with the Questor Travel Electronic Services.

  1. Use of Questor Travel Electronic Services by Minors

The Questor Travel Electronic Services are not directed to individuals under the age of eighteen (18), and no minor will be able to use our services without a full paying adult. We may receive Personal Information from minors where the lead passenger is travelling with one or more minors.

  1. Complaints

If you are concerned that we have breached a privacy law or code binding on us, please send an email to compliance@questor-travel.co.uk. We aim to respond in a reasonable time (usually no later than 5 working days). Our Compliance Team will handle your complaint and will give you additional information about how it will be handled.

You also have the right to complain to the Information Commissioner’s Office (ICO) if you believe we have not handled your request in an appropriate manner. For more information, please see: www.ico.org.uk/concerns.

  1. Changes to This Privacy Policy

We review this Privacy Policy regularly and reserve the right to make changes at any time to take account of changes in our business and legal requirements. We will place updates on our website.

Please look at the “LAST UPDATED” date at the top of this Privacy Policy to see when it was last revised.