We may rely on one or more of the following legal bases when processing your personal data. We have set out below the purposes for which we may process your personal data and the relevant legal basis upon which we will rely (this is what the law allows us to do):
5.1.1 For managing your booking we will use information provided by you to deliver our products and services. This includes booking holidays, tours, transportation, car hire and the issuing of tickets. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
5.1.2 To make suggestions and recommendations to you about our products and services that may be of interest to you, for determining and measuring the effectiveness of promotional campaigns and advertising and making sure our marketing is relevant to you. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
5.1.3 To deal with your enquiries, to send you information you have requested or to provide you with important-real time information about our products and service you have ordered from us (e.g. a change of time or location due to unforeseen circumstances). We will rely on the following legal bases to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
(b) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
5.1.4 For the development, delivery and improvement of our products and services, marketing, customer relationships and experiences in the provision of products and services to our customers. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
5.1.5 Where you have submitted a job application we may for a reasonable period of time keep your details on file for future reference should a suitable position subsequently become available and we may send you information about job opportunities. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
5.1.6 To help us develop our website to be more useful to you and our customers, for identifying usage trends and for internal purposes of research, analysis, testing, monitoring, customer communication, risk management and administrative purposes, to help us define types of customer for our products and services, to keep our website updated and relevant and to develop our marketing strategy. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
5.1.7 To protect our rights or property (including our website), administer and improve our IT services and network security, prevent fraud and facilitate any business reorganisation or group restructuring exercise. We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data;
5.1.8 In order to comply with our own legal obligations, e.g. health and safety legislation, or to assist in an investigation (e.g. from the Police). We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for compliance with a legal obligation to which we are subject;
5.1.9 In order to use your personal data in life or death situations where there is no time to gain your consent (e.g. in the event of an accident and we have to give personal details to medical personnel). We will rely on the following legal basis to process this personal data:
(a) the processing is necessary in order to protect the vital interests of the data subject or of another natural person;
5.1.10 In an official role which we have been designated to carry out by an official authority (e.g. the government), or where we are otherwise carrying out tasks which are in the public interest (e.g. which have been designated as such by the government, or which would otherwise be deemed in the public interest). We will rely on the following legal basis to process this personal data:
(a) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
5.2 Special Categories of Data
In addition, we may lawfully process Special Categories of Data in certain ways. We set out below the purposes for which we may process Special Categories of Data along with the legal bases on which we process these Special Categories of Data (this is what the law allows us to do):
5.2.1 we may need to process your health information (for example to enable us to make arrangements for special assistance and any dietary preferences or requirements or for determining your fitness to fly). In relation to the processing of such Special Categories of Data:
(a) We rely on the following legal basis to process such Special Categories of Data:
(i) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
(ii) the processing is necessary in order to protect the vital interests of the data subject or of another natural person;
(b) Additionally, we can only process such Special Categories of Data where:
(i) The processing is necessary in order to protect the vital interests of you or another individual where you or the individual is physically or legally incapable of giving consent;
(ii) The processing is necessary for reasons of public interest in the area of public health for example:
(aa) protecting against serious cross-border threats to health;
(ab) ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices;
5.2.2 we may need to disclose any Special Categories of Data we hold on you, where to do so is in the substantial public interest (for example your health information in order to prevent an epidemic, in the event of illness or injury or some other related emergency, to record any accident or injury or other incident you may suffer when visiting any of our locations or to arrange for you to receive medical assistance), provided that when we do so we provide suitable measures to protect your rights. In relation to the processing of such Special Categories of Data:
(a) We rely on the following legal basis to process such Special Categories of Data:
(i) The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
(b) Additionally, we can only process such Special Categories of Data where:
(i) The processing is necessary for reasons of public interest in the area of public healthfor example:
(aa) protecting against serious cross-border threats to health;
(ab) ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices;
5.2.3 we may need to process information about your religion (for example to enable an airline to provide you with a meal indicating a particular religion e.g. halal or kosher) or your sexuality (for example to enable us to provide you with a specific holiday which you have requested from our range). In relation to the processing of such Special Categories of Data:
(a) We rely on the following legal basis to process such Special Categories of Data:
(i) the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract;
(b) Additionally, we can only process such Special Categories of Data where:
(i) You have given us explicit consent to the processing of such Special Categories of Data for the purpose. You may at any time withdraw this specific consent but we will be unable to fulfil your booking in such event and we may have to cancel your booking.
We will always attempt to minimise the amount of sensitive personal data collected unless there is a specific lawful reason (e.g. an emergency situation).