What is our role in relation to your personal data?
For the purposes of data protection laws, we, 153 Fish Limited, are a data controller in respect of the personal data you provide us with.
What is my personal data and what do you mean by process?
When we refer to personal data, we mean any information which relates to an identified or identifiable individual. Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties and erasing it.
What personal data will we collect from you and why?
In order to respond to an enquiry, administer and fulfil your booking, or send you a brochure or other promotional material, or communicate with you in any way, we need to process personal data we obtain from you. This personal data may be obtained from you directly or through any travel agency with whom you make your booking or booking enquiry or from an associate, partner or supplier to us.
Where you wish to make a booking, the personal data we need to collect and process is likely to include:
- names of all persons travelling
- contact details (such as telephone number, postal and e-mail addresses) of the person making the booking
- passport information of all persons travelling
- travel insurance details for all persons travelling
- dietary information where applicable
- emergency contact / next of kin details (names and telephone numbers) for all persons travelling
- credit / debit card or other payment information for the person making the booking
- information in respect of any medical condition, disability or reduced mobility which may affect you or anyone travelling with you – this comes within special categories of personal data (see below).
For an enquiry, the personal data we will need to process is likely to include the name and contact details of the person making the enquiry.
For a booking or booking enquiry, we will process your personal data (other than any data which comes within special categories of personal data – see below) on the basis that this is necessary for the performance of your contract with us, or to enable us to take steps at your request prior to your entering into a contract with us. We may also need to do so to comply with a legal obligation to which we are subject or in order to protect your vital interests (for example, in an emergency situation).
If you wish to receive brochures or other promotional material from us, we will need your name and the contact details applicable to the form of communication you have consented to. For example, if you wish to receive information by e-mail, we will need your e-mail address.
What are special categories of personal data?
Personal data which concerns your health or which reveals your racial or ethnic origin or your sexual orientation are special categories of personal data. Other information also comes within special categories but this is unlikely to be relevant to the booking and provision of travel arrangements.
Generally speaking, the processing of special categories of personal data requires your explicit consent.
Accordingly, information concerning any disability, medical condition or restricted mobility which may affect your travel arrangements (and related requirements) as well as dietary restrictions which may disclose your religious beliefs are special categories of personal data. We will ask for your consent to our processing this information at the time you make your booking or your booking enquiry. If you are providing us with information about other people in respect of a booking or enquiry, it is your responsibility to obtain their consent and we cannot be held responsible if such consent has not been given.
Who may we provide your personal data to?
Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen arrangements together with any other third party who needs this information so that we can arrange for your holiday to be provided.
Suppliers and other third parties are likely to include the following, depending on the arrangements booked:
- in-country transport operators
- hotels and the providers of other forms of accommodation
- overseas ground agents
- tour managers and guides
- excursion and activity operators
- travel insurance providers
- merchant services companies, credit card companies / banks in respect of payments.
The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.
We may also make personal data available to other companies who provide services on our behalf, such as mailing brochures and marketing material.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended 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.
Where will we process your personal data?
Your personal data may be processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein.
We may also process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.
How do we protect your personal data?
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Can we use your personal data to send you information about our holidays or other services in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to this or we are permitted to do in accordance with data protection laws (including as set out below).
We may send you e-mail marketing where we comply with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR). PECR permits us to e-mail you information about the travel services we offer where you have previously provided us with your e-mail address in the