+44 (0) 203 764 0900 sales@axisglobe.co.uk

Company Privacy policy

  1. Introduction

1.1    We are committed to safeguarding the privacy of our website visitors and service users; in this policy we explain how we will handle your personal data.

1.2    We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website

  1. How we use your personal data

2.1    In this Section we have set out:

(a)    The general categories of personal data that we may process;

(b)    In the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c)    The purposes for which we may process personal data; and

(d)    The legal bases of the processing.

2.3    We may process [your account data] (“account data“). [The account data may include [Your Name, Job Title, Company address, telephone number, email address]. The source of the account data is [you or your employer].] The account data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.] The legal basis for this processing is [consent] OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

2.5    We may process [your personal data that are provided in the course of the use of our services] (“service data“). [The service data may include [Your name, Job Title, Company address, telephone number, email address\]. The source of the service data is [you or your employer].] The service data may be processed [for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

2.6    We may process [information that you post for publication on our website or through our services] (“publication data“). The publication data may be processed [for the purposes of enabling such publication and administering our website and services]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business]] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

2.7    We may process [information contained in any enquiry you submit to us regarding products and/or services] (“enquiry data“). The enquiry data may be processed [for the purposes of offering, marketing and selling relevant products and/or services to you]. The legal basis for this processing is consent.

2.8    We may process [information relating to transactions, including purchases of goods and services that you enter into with us and/or through our website] (“transaction data“). [The transaction data may include [your contact details, your card details and the transaction details].] The transaction data may be processed [for the purpose of supplying the purchased goods and services and keeping proper records of those transactions]. The legal basis for this processing is [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely [our interest in the proper administration of our website and business].

2.9    We may process [information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters] (“notification data“). The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters]. The legal basis for this processing is [consent] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

2.10 We may process [information contained in or relating to any communication that you send to us] (“correspondence data“). The correspondence data may include [the communication content and metadata associated with the communication]. [Our website will generate the metadata associated with communications made using the website contact forms.] The correspondence data may be processed [for the purposes of communicating with you and record-keeping]. The legal basis for this processing is [our legitimate interests, namely [the proper administration of our website and business and communications with users].

2.11  We may process [any of your personal data identified in the other provisions of this policy] where necessary for [the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]. The legal basis for this processing is our legitimate interests, namely [the protection and assertion of our legal rights, your legal rights and the legal rights of others].

2.12  We may process [data specifically provided to us by you, regarding your clients. [This data may include [names, addresses, telephone numbers, date of birth, email address, dietary requirements, and passport information.][The source of this data is [as provided by you or your company.] This data may be processed for [the provision of services requested by you or your company]. The legal basis for this processing is [consent] OR [our legitimate interests, namely [the proper administration of our website and business] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

2.13  In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process [any of your personal data] where such processing is necessary [for compliance with a legal obligation to which we are subject, or] in order to protect your vital interests or the vital interests of another natural person.

2.14  Please do not supply any other person’s personal data to us, unless we prompt you to do so.

  1. Providing your personal data to others

3.1    We may disclose [your personal data] to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

3.2    We may disclose [your personal data] to [our insurers and/or professional advisers] insofar as reasonably necessary for the purposes of [obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes].

3.3    We may disclose [your or your client’s personal data supplied by you or your company] to [our suppliers or subcontractors] insofar as reasonably necessary for [the provision of services requested by you or your company]. The legal basis for this disclosure is [consent] OR [our legitimate interests, namely [the proper administration of our website and business] OR [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract].

3.4    Financial transactions relating to [our website and services] [are] OR [may be] handled by our payment services providers, [HSBC]. We will share transaction data with our payment services providers only to the extent necessary for the purposes of [processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds]. You can find information about the payment services providers’ privacy policies and practices at [https://www.hsbc.co.uk/1/PA_esf-ca-app-content/content/pws/content/personal/pdfs/your-information.pdf].

3.5    We may disclose [your enquiry data] to [one or more of those selected third party suppliers of goods and services identified on our website] for the purpose of [enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services].[ Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.]

3.6    In addition to the specific disclosures of personal data set out in this Section 3, we may also disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

  1. Retaining and deleting personal data

4.1    This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

4.2    Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

4.3    We will retain and delete your personal data as follows:

(a)    [Account data] will be retained for [12 months] following [last communication date from you or your company], at the end of which period it will be deleted from our systems.

(b)    [Service data] will be retained for [12 months] following [last communication date from you or your company], at the end of which period it will be deleted from our systems.

(c)    [Publication Data] will be retained for [12 months] following [communication of termination of any contract with you or your company], at the end of which period it will be deleted from our systems.

(d)    [Enquiry Data] will be retained for [12 months] following [last communication date from you or your company], at the end of which period it will be deleted from our systems.

(e)    [Transaction Data] will be retained for [12 months] following [last Transaction date from you or your company], at the end of which period it will be deleted from our systems.

(f)    [Notification Data] will be retained for [12 months] following [last communication date from you or your company OR immediately on receipt of your request to be unsubscribed], at the end of which period it will be deleted from our systems.

(g)    [Correspondence Data] will be retained for [12 months] following [last communication date from you or your company], at the end of which period it will be deleted from our systems.

4.4    In some cases it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based on the following criteria:

(a)    The period of retention of [data specifically provided to us by you, regarding your clients personal data] will be determined based on [Financial and legal criteria].

 

4.5    Notwithstanding the other provisions of this Section 5, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

  1. Amendments

5.1    We may update this policy from time to time by publishing a new version on our website.

5.2    You should check this page occasionally to ensure you are happy with any changes to this policy.

 

  1. Your rights

6.1    In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

6.2    Your principal rights under data protection law are:

(a)    The right to access;

(b)    The right to rectification;

(c)    The right to erasure;

(d)    The right to restrict processing;

(e)    The right to object to processing;

(f)    The right to data portability;

(g)    The right to complain to a supervisory authority; and

(h)    The right to withdraw consent.

6.3    You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.

6.4    You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

6.5    In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: [the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; the processing is for direct marketing purposes; and the personal data have been unlawfully processed]. However, there are certain general exclusions of the right to erasure. Those general exclusions include where processing is necessary: [for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims].

6.6    In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

6.7    You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

6.10  To the extent that the legal basis for our processing of your personal data is consent, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

6.11  If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.

6.12  To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

6.13  You may exercise any of your rights in relation to your personal data [by written notice to us], in addition to the other methods specified in this Section 6].

  1. Cookies used by our service providers

7.1    Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

7.2    We use [MAILCHIMP] to [to facilitate the membership of users to our distribution list for the purpose of receiving our newsletters and special offers]. This service uses cookies. For more information for [purpose(s) of cookies used, and list of relevant cookies used, as well as viewing the privacy policy of this service provider please go to https://mailchimp.com/legal/cookies/?_ga=2.154079288.1896751272.1527178317-1105080214.1525780393

  1. Our details

8.1    This website is owned and operated by [Axis And Globe Travel Limited].

8.2    We are registered in [England and Wales] under registration number 2924592, and our registered office is at [8 Jury Street, Warwick, Warwickshire, CV34 4EW].

8.3    Our principal place of business is at [10 Warple Mews, Warple Way, London, W3 0RF].

8.4    You can contact us:

(a)    [by post, using the postal address [10 Warple Mews, Warple Way, London, W3 0RF];

(b)    [Using our website contact form];

(c)    [By telephone, on [the contact number published on our website from time to time]

(d)    [By email, using [the email address published on our website from time to time]].

9. Data protection officer

9.1 Our data protection officer’s contact details are: dpo@axisglobe.co.uk

Data Protection Officer – Axis & Globe Travel – 10 Warple Mews, Warple Way, London W3 0RF, UK. Tel. +44 (0) 203 764 0900