Privacy Policy

Your privacy and trust are important to us and this Privacy Policy (“Policy”) provides important information about how Swoop Travel Limited, CRN: 07953919 (“Swoop” “we” or “us”) handle personal information. This Policy applies to personal information which we process in the course of doing business including information processed through Swoop’s website and in the course of providing you with our travel services (collectively, our “Services”).

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices.

It is important that you check back often for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on our website and/or contacting you using other methods such as email.

This Policy was last updated on 25 May 2018.

We will collect and store personal information including contact details of our travel partners, travel destinations, travel operators and other suppliers and their employees who provide services to us or with whom we have a contract relating to the provision of Services to our customers. We process this information in accordance with and for the performance of the contract between us. We will retain that information and any information relating to the contract between us for a period of up to six years following completion of the contract(s) between us so that we can review your performance if any complaints or issues arise after completion of the contract.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We believe that it is in our legitimate interests to develop our business and that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group e-mailing campaign unless you have consented to be contacted in this way.

We will collect and store personal information about people who we reasonably consider we might do business with as a supplier or a travel partner.

We may collect this information from you, when you contact us (including through this website) or at an event or from a mutual contact. We will only collect contact information from your website or another third party website if we have identified you specifically as someone who may be interested in working with us.

We may contact you about our Services, events and new business opportunities for us to work together with you and to keep you informed of our activities.  We believe that it is in our legitimate interests to develop our business and that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair. Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.

We will collect and store personal information including contact details of third parties with whom we are in contact during the delivery of Services to our customers or discussions relating to Services to prospective customers. We process that information because it is in our legitimate interests to do so in order for us to be able to provide our Services to our customers or propose travel arrangements to prospective customers. We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair.

Where your personal information is kept as part of a file relating to the performance of a contract with one of our customers, we will also retain that information and any information relating to that contract in accordance with our file retention policy following completion of that contract(s) so that we can review the file if any complaints or issues arise after completion of the contract.

Where your information is stored in our contacts database but is not kept in a customer or supplier file, we carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

We may also contact you about new business opportunities for us to work together with you and to keep you informed of our activities. We believe that it is in our legitimate interests to develop our business and that you would reasonably expect us to process your personal information in this way and that such processing does not have an impact on you in a way that would make this processing unfair.

We will not send you general marketing information as part of a group mailing, e-mailing or telephone campaign unless you have consented to be contacted in this way.

Employees should refer to the Staff Handbook for further information about our privacy policy in respect of employees.

Where an employee has provided us with personal information about a spouse, civil partner or other family member/friend (perhaps in relation to sharing a Company car, private medical insurance or other benefits or as an emergency contact), it is the employee’s responsibility to inform that person that the employee has provided us with their details and that we will be processing it as an emergency contact or in connection with the relevant benefit and/or policy in accordance with this privacy policy.

You are a prospective employee we have received your details in response to a recruitment initiative, we will store the personal information that either you, your recruitment agent or another third party has provided us with. We process that information in order for us to be able to assess the suitability of your application for the advertised role and make an informed decision about whether to interview you and, ultimately, recruit you.  We may ask for details about your previous experience, education, referees and for answers to questions relevant to the role you have applied for. Therefore, processing your personal data is necessary to take steps at your request prior to potentially entering into an employment contract.

Unless you request us not to do so, we may also contact those individuals who are referred to in any information you provide us with, for example referees, this contact may be made by telephone, e-mail or post. We will only do this if we have your express permission to contact them in this way.

If you are unsuccessful then the information you have provided up to that point will be retained for six months following the date from which the role was filled.

If you are successful, the information you have provided throughout the recruitment process will be retained by us as part of your employee file.

We may hold your contact details and personal information as a result of an interaction between you and one of our employees. We are processing your personal information in this way because it is in our legitimate interests to retain a record of our employee’s engagement with third parties.  We believe that you would reasonably expect us to process your personal information in this way and that such processing does not an impact on you in a way that would make this processing unfair. We carry out a review of our contacts database every 2 years when we consider whether or not we still have a legitimate interest to keep your contact information. Where we consider that we no longer have a legitimate interest to keep your contact information we will delete it.

If you give us personal information about another person, for example as part of a group booking, you must ensure that:

(a) you are legally entitled to give us that information;

(b) the disclosure is in accordance with any applicable data protection or privacy laws; and

(c) such other person has also read this privacy policy.

We will not share your personal data with third parties for marketing purposes, however, it may be necessary to share your data with third parties in the course of operating our business. Any third parties that we may share your data with are obliged to keep your details secure, and to use them only to support the fulfilment of the service we provide to you.

The third-party entities we pass your information onto are as follows:

• Our travel partners, travel destinations, travel operators and other suppliers engaged in relation to the fulfilment of your travel arrangements
  
  
• Service providers acting as processors who provide platform, cloud hosting and IT and system administration services
  
  
• HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances
  
  
• Platform and other IT Software Providers acting as processors
  
  
• Professional advisers acting as processors or joint controllers including lawyers, bankers and accountants who provide consultancy, banking, legal, debt recovery, insurance and accounting services

Many of our travel partners, travel destinations, travel operators and other suppliers engaged in relation to the fulfilment of your travel arrangements are situated outside of the European Economic Area (EEA) and so it will be necessary for the provision of our Service to transfer your personal data outside the EEA. We will not transfer your personal data outside the EEA except where it is necessary to do so in order to provide our Services.

We may also share personal information when we believe it is required, such as:

• to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities;
  
  
• in the event of a merger, sale, restructure, acquisition, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings);
  
  
• to protect our rights, users, systems, and Services.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for different aspects of your personal data set out in the above Section: Purpose, legal basis and duration of the processing.

A cookie is a small file which asks permission to be placed on your computer's hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We use this information for statistical analysis purposes and then the data is removed from the system. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or safely delete your personal information.

• Access to personal information: You have the right to request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. If you request access to your personal information, we will gladly comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data.
  
  
• Object to processing: of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  
  
• Request erasure: of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see above), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  
  
• Request restriction of processing: of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  
  
• Request the transfer: of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  
  
• Correction of your data: You have the right to request that we correct your personal information if it is inaccurate or requires updating or complete your personal information if the information we hold is incomplete.
  
  
• Withdrawal of consent: If we are processing your personal information on the basis that you have given your consent to us processing that personal information, you have a right to withdraw your consent at any time by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.
  
  
• Filing a complaint: If you are not satisfied with how Swoop manages your personal data, you have the right to make a complaint to the Information Commissioner’s Office (https://ico.org.uk).

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to book some or all of your travel arrangements). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please let us know by using the “Contact Us” option on our website or let us know in writing, by email or by telephone.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

This website has links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Please contact us with any requests related to your personal information.

We understand that you may have questions or concerns about this Policy or our privacy practices or may wish to file a complaint. Please feel free to contact us in one of the following ways:

Email: [email protected]

Address: Swoop Travel, 15 Cornwallis Crescent, Bristol, BS8 4PJ
Attn: FAO Luke Errington
Telephone: +44 (0)117 3690196