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1. OUR IDENTITY AND CONTACT DETAILS
1.1 We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
1.2 Please note that we are not the controller of any personal information provided directly by individuals to hotels or relating to hotel guests or travellers where a booking is made through another travel company. The data controllers in these cases will be the relevant hotel or travel company via which a booking was made. In these circumstances, it is the responsibility of the hotel or travel company to ensure they have authorisation for Miki Travel to use your personal data to fulfil our obligations in respect of providing the service requested. In such cases, if you are a hotel guest or traveller and have any queries regarding the use of your personal data or wish to access your personal data, you should contact the relevant data controller directly (or contact us, and we will try to assist with directing you to the relevant person).
1.5 It would be helpful to explain some key terms used in this policy and providing our contact details:
We, us, our:
Miki Travel Limited, a company registered in England and Wales number 01509274 with registered office at Vintners’ Place, 68 Upper Thames Street, London EC4V 3BJ, United Kingdom.
Any information relating to an identified or identifiable individual
Special category personal information:
Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data
Data concerning health, sex life or sexual orientation
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
How your personal information is collected
filling in forms or making a general enquiry via our website;
registering your interest in partnering with us;
providing information in the course of negotiating and/or entering into contractual agreements with us; and
corresponding with us by phone, email or otherwise.
However, we may also collect information:
from publicly accessible sources, e.g. Companies House;
directly from a third party, e.g.:
– sanctions screening providers;
– credit reference agencies;
from a third party with your consent, e.g. your bank;
from cookies on our website;
via our IT systems, e.g.: automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems;
Information we collect about you
2.2 The information we collect when you engage with us for any of the purposes described above may include, for example:
your name and contact information, including email address and phone number and company details;
the Internet Protocol (IP) address attached to your device;
your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and certain device information;
information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page;
your billing information, transaction and payment card information; and
your professional online presence, e.g. LinkedIn profile.
3. USES MADE OF THE INFORMATION
3.1 We use information held about you in the following ways:
for internal record keeping and account creation;
in order to enter into contractual agreements with you in relation to travel services;
to carry out our obligations arising from any contracts entered into between you and us, including, but not limited to, the processing and administration of bookings;
to provide you with the products and or services that you request from us;
to contact you in the course of providing services to you in your capacity as a B to B travel provider, hotel operator or technology platform provider, as applicable;
operational reasons, such as improving efficiency, training and quality control;
statistical analysis to help us manage our business; and
to send promotional emails about other services we offer which are similar to those that we already provide to you or that you have enquired about.
4. OUR LEGAL GROUNDS FOR PROCESSING YOUR INFORMATION
for the performance of our contract with you or to take steps at your request before entering into a contract; or
for our legitimate interests or those of a third party. A legitimate interest is when we have a business or commercial reason to use your information (for example for internal record keeping, analysis to help us manage our business or marketing purposes), so long as this is not overridden by your own rights and interests; or
to comply with our legal and regulatory obligations; or
where you have given consent.
We will only process special category information with your explicit consent.
5. PROMOTIONAL COMMUNICATIONS
5.1 We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services.
5.2 We have a legitimate interest in processing your personal information for promotional purposes (see 3 above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
5.3 We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the Miki group for marketing purposes.
5.4 You have the right to opt out of receiving promotional communications at any time by:
contacting us at email@example.com
using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
6.2 The personal information you provide to us may also be routinely shared with and processed by:
third parties we use to help deliver our products and services to you, e.g. payment service providers, travel service providers;
other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
third parties approved by you, e.g. social media sites you choose to link your account to or third party payment providers;
credit reference agencies;
our insurers and brokers;
6.3 We may also share personal information with our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.
6.4 We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
6.4 We may also need to share some personal information with other parties, such as another organisation to whom we transfer our agreement with you or potential buyers of some or all of our business or during a re-structuring.
7. WHERE YOUR PERSONAL INFORMATION IS HELD
7.1 Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see section 6 above).Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see section 9 below.
8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
8.1 We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as we consider necessary:
to respond to any questions, complaints or claims made by you or on your behalf;
to show that we treated you fairly;
to keep records required by law.
8.2 We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it
9. TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA
9.1 To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
with our offices outside the EEA;
with your and our service providers located outside the EEA;
if you are based outside the EEA;
where there is an international dimension to the services we are providing to you.
These transfers are subject to special rules under European and UK data protection law.
Some of these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, only do so where the transfer complies with data protection law (for example, using standard data protection contract clauses that have been approved by the European Commission).
10. YOUR RIGHTS
10.1 You have the following rights, which you can exercise free of charge:
Access The right to be provided with a copy of your personal information (the right of access).Please note that you are entitled to request one copy of the personal information that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs).
Rectification The right to require us to correct any mistakes in your personal information
To be forgotten The right to require us to delete your personal information or withdraw your consent to our processing of your personal information – in certain situations
Restriction of processing The right to require us to restrict processing of your personal information – in certain circumstances, e.g. if you contest the accuracy of the data
Data portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object The right to object:
– at any time to your personal information being processed for direct marketing (including profiling);
– in certain other situations to our continued processing of your personal information, e.g. processing carried out for the purpose of our legitimate interests.
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
10.2 If you would like to exercise any of those rights, please:
email or write to us – see section 14 below; and
let us have enough information to identify you (e.g. your full name and address);
let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
let us know what right you want to exercise and the information to which your request relates.
11. KEEPING YOUR PERSONAL INFORMATION SECURE
11.1 We keep your information secure by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:
We limit access to your personal information to those who have a genuine business need to access it.
Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We carry out risk assessments and audits to monitor and review threats and vulnerabilities to our systems.
11.2 However, while we will take reasonable care to protect your personal information, we cannot guarantee the security of your information which is transmitted to any website or any other online platform operated by us via an internet or similar connection. Where you have a password or username which enables you to access certain parts of our website, you are responsible for keeping these confidential.
11.3 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
12. HOW TO COMPLAIN
12.1 We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
14. HOW TO CONTACT US
By post: Data Protection Compliance Manager,
68 Upper Thames Street,
London EC4V 3BJ
By email: firstname.lastname@example.org