PRIVACY POLICY

Welcome to The Cycladist’s privacy notice. 

The Cycladist respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you. 

Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how The Cycladist collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone and by email) when you purchase travel services, etc.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller

The Cycladist Limited is the controller and responsible for your personal data (collectively referred to as “The Cycladist”, “we”, “us” or “our” in this privacy notice).

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please send us an email at hello@thecycladist.com.

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 (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 27th February 2024.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.

The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. Identity Data
   This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, title, date of birth, nationality and gender.
2. Contact Data
   This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
3. Financial Data
   This includes data relating to your means and methods of payment, such as your bank account and payment card details, please note that while we may be required to collect those details, we do not keep on file any information relating to your credit / debit card numbers or your bank account details.
4. Transaction Data
   This includes data relating to the holiday, event or other services that we have quoted for and/or arranged on your behalf, and will include details relating to this such as details about payments to and from you.
5. Technical Data
   This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, 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 this website.
6. Usage Data
   This includes information about how you use our website and services.
7. Marketing and Communications Data
   This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

If you fail to provide personal data

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.

Where we are acting as an agent and we need to collect personal data to enter you into a contract with the supplier of your chosen travel arrangements, we may not be able to take steps to enter you into that contract if you fail to provide the data when requested.

In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide (or arrange for the provision of) the services you have booked or are attempting to book.

In this case, depending upon when you fail to provide the necessary data, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.

How your personal data is collected

We use different methods to collect data from and about you including through:

1. Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by phone, e-mail or otherwise. This includes personal data you provide when you:

• make an enquiry with us;
• make a booking of travel services; or
• give us some feedback.

1. 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 and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. 

How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you; i.e. to deliver the holiday, event or other travel services that you have booked with us.
• Where we need to take steps to enter you into a contract with the supplier of your chosen travel services, where we are acting in an agency capacity.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation, i.e. accounting for auditing and tax.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Purposes for which we will use your personal data

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 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.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We have established the following personal data control mechanisms:

Recommendations by 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 services and destinations may be relevant for you (we call this marketing).

We may contact you occasionally to let you know about services or destinations that may be of interest. We may also send a Christmas Card or occasional personal message by email. We will not send irrelevant or unwanted promotional emails and you may opt out of receiving any communications from us at any point by email.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

Opting out

You can ask us to stop sending you marketing emails by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing  emails, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.

Monitoring communications

We may monitor, record, store and use any email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Change of purpose

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 contact us.

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.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

1. External third parties.
2. 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 privacy notice.

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.

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.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax,  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 unauthorized 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 regulatory, tax, accounting or other requirements.

If you book with us we will keep your information for 7 years from your return date of travel (in the case of adults) or 7 years from the date of your 18th birthday (in the event of any children that travel on the booking) in order to enable us to defend any legal claims that you may pursue against us.

In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data by contacting us. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.