1. POLICY OVERVIEW
Scope of this policy
P&P Associates Limited understands and respects the importance of your privacy and we are committed to safeguarding your personal information. In providing our service to you, we must collect personal information from you and this policy outlines how we treat your personal data after it has been collected by any of our channels which include our website, call centre and any future digital services or channels as they evolve.
2. ABOUT US
Who are we?
We are P&P Associates Limited (The Official Travel Partner of London Luton Airport), a company incorporated in England and Wales under company number 2124920 and part of the P&P Group. You’ll find our registered address below.
Who is the Data Controller?
For the purposes of data protection laws, we act as either the “data controller” or “data processor” in relation to personal information collected on our websites.
How to contact us
The Data Protection Officer
P&P Group, Falcon House, Primett Road, Stevenage, SG1 3EE
3. WHAT INFORMATION MIGHT WE COLLECT ABOUT YOU?
The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we may collect some or all of the following:
You are responsible for ensuring that other members of your party are aware of the content of this Policy and consent to your acting on their behalf in all your dealings with us.
4. HOW WE COLLECT INFORMATION ABOUT YOU
How we collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we collect information in any of the following ways:
5. WHY DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?
In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:
We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it.
6. HOW WE USE YOUR INFORMATION
For what purposes do we use your information?
We’ll use your information for a variety of different purposes, some of which will depend on the services that you engage us for. This includes:
On what grounds will we process your information?
We will use your information for the purposes listed above, either:
What do we mean by “legitimate interests”?
As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers. This involves:
Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours, and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as when we have your consent, or we have a legal obligation to use your information in that way). From 25 May 2018 you will have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.
7. REASONS FORSHARING YOUR INFORMATION
In connection with the purposes described above, we share your personal information with the following third parties:
Where we do share your information with third parties, we will require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).
When you’ll hear from us
We will keep you up to date with our latest destinations, offers, partnerships, sales, promotions, competitions (or those of other members of the P&P Group) that we think might be of interest / relevant to you if you have indicated that you are happy to receive marketing communications from us – that is, if you have:
Opting out of or withdrawing your consent in relation to marketing
If you no longer want to hear from us, you can opt out or unsubscribe by:
Third parties and marketing
We might rely on third parties to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.
In order for us to provide you with optimum service, we use ‘Cookies’ on our website.
What are cookies?
A cookie is a text-only string of information that a website transfers to the cookie file of the browser on your computer's hard disk so that the website can remember who you are. Cookies will typically contain the name of the domain from which the cookie has come, the "lifetime" of the cookie, and a value, usually a randomly generated unique number.
Two types of cookies are used on this web site - session cookies, which are temporary cookies that remain in the cookie file of your browser until you leave the site, and persistent cookies, which remain in the cookie file of your browser for much longer (though how long will depend on the lifetime of the specific cookie).
Cookies allow us to obtain information regarding users of our site which essentially helps us to provide you with a better user experience and tailor our services to your individual needs. We may collect information such as your IP address, online activity, web browser details and online activity. We will not however collect or store any of your passwords or other highly sensitive data.
We use the following types of cookies on our website:
Category 1: strictly necessary cookies
These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website. Without these cookies services you have asked for, like shopping baskets or e-billing, cannot be provided.
Category 2: performance cookies
These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
Category 3: Functionality Cookies
These cookies are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Category 4: Targeting or Advertising Cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with our permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.
By using our website, you agree that we can place these types of cookies on your device.
To find out more information about cookies, please visit www.allaboutcookies.org.
10. YOUR RIGHTS
Overview of your rights
You have certain rights in respect of the personal information that we hold about you, including:
The right to ask us not to process your information for marketing purposes;
The right to request access to the information that we hold about you;
The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
In certain circumstances, the right to ask us to stop using information about you; and
The right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.
Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.
Your rights under the GDPR
From 25 May 2018, you will have certain additional rights in respect of the information that we hold about you, including:
How to exercise your rights
- You can update the details we hold about you by logging into your booking via the “Manage your booking” tab on our site and following the instructions to edit your details, or contact us to change details of your booking; and
- If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.
We will comply with your requests unless we have a lawful reason not to do so. Please be aware that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request.
11. OPERATING WORLDWIDE
Our service providers and suppliers
A list of the countries outside of the EEA to which we may transfer your personal information is available.
As we outline above, in certain circumstances, we are required to share information about you with immigration or other government authorities before we can deliver you to your destination.
12. SAFEGUARDING YOUR INFORMATION
Our security measures
We take security very seriously and we are committed to safeguarding your personal information. We take a number of administrative and technical steps to ensure the security of the information you provide to us.
For example we:
How you can help ensure the security of your information
You can also play a part in helping to keep your information safe. Here are a few useful starting points:
Links to other sites and resources
13. DATA RETENTION
We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims.
As part of our ongoing data retention policy we look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example: