Privacy Policy

Personal information

Any personal information processed by traWell in connection with this Privacy Policy is controlled by Smith & Behl Ltd, which is considered the “data controller” of your personal information under European Union and UK data protection law. Our address is Data Protection Officer, Smith & Behl Ltd, Brunel House, 340 Firecrest Court, Centre Park, Warrington, Cheshire, WA1 1RG, United Kingdom.

If you have made a flight booking in addition to booking a holiday package with us, then that airline will also separately be considered a “data controller” under European Union and UK data protection law. You can access the privacy policies of the other airlines via their own websites.

Any provider of services such as a hotel or car rental company will also separately be a “data controller”. You can access the privacy policies of those providers from them directly.

Personal information means details which identify you or could be used to identify you, such as your name and contact details, your travel arrangements and purchase history. It may also include information about how you use our website and mobile applications.

Applicability of the privacy policy

This Privacy Policy applies to personal information about you that we collect, use and otherwise process regarding your relationship with us as a customer or potential customer, including when you travel with us or use our other services, use our websites or mobile applications, contact our service agents or call centres.

Where we reference that others are data controllers in the sections ’Controller of Personal Information’ and ’Who do we share your personal information with?’ you should consult their privacy policies for further information.

Additional Terms and Conditions or policies may apply if you elect to take additional services from us such as entering a competition linked to traWell and other third parties.

Protecting your personal information

When you make a booking, you will be given a booking reference. This will appear on the email confirmation or ticket of each person in your booking. You should always keep your booking reference confidential.

Giving your booking reference to others may allow them to access your booking details through our systems.

If you are travelling with others and would not like your individual booking details to be accessible by them, you may prefer each person to make separate bookings.

When you buy a traWell holiday package over the Internet, your web browser connects with the website through an SSL (“Secure Sockets Layer”).  SSL is an industry-standard protocol for encryption over the Internet.

All of your personal information is encrypted as it travels over the Internet, to and from www.trawell.global. When information is encrypted, it is scrambled between your computer and our server. The information is only unscrambled when it safely reaches us. It’s fast and safe, and it ensures that your personal information cannot be read by anyone else.

However, as with any standard email, emails containing your personal data sent to or from traWell or Smith & Behl Ltd will travel in a non-encrypted format.

To make sure your access to our websites, other online services, and mobile applications is secure, you should not share your log in details with anyone else. When you finish using the website, online services or mobile app you should log out if others may be able to access your computer or device. This is especially important if you are using a publicly accessible computer.

There is an Internet fraud practice known as ‘phishing’ which is the illegal gathering of personal information by deception. Unsolicited emails are sent to individuals from lists illegally gathered by a third party, and recipients are asked to enter or reconfirm bank or password details into a ‘cloned’ or illegal copy website.

Our reasons for collecting personal information

We collect personal information about you whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you travel with us, when you use our website or mobile applications, or interact with us via email or use our contact centres.
For additional details see ’What types of personal information do we collect and retain?’ below.

In addition, we may receive personal information about you from third parties, such as:

• Companies contracted by us to provide services to you.
• Companies involved in your travel plans, including airlines involved in your prior or onward journey, relevant airport operators and customs and immigration authorities.
• Companies that participate in our loyalty schemes and other customer programmes (e.g. car hire providers and hotels).
• Companies who provide details to us under privacy polices providing information to be shared with traWell.

Types of personal information we collect and retain

When you use our services, you will need to provide us with your personal details or the details of those individual(s) who will be travelling.

We collect the following categories of personal information:

• Information you provide for traWell to complete and manage a booking you have made with us or a service you have requested from us.
• Information collected during your travel with us.
• Information about your travel arrangements.
• Information about the services we have provided to you in the past.
• Information about online registration and other interactions.
• Information about your use of our websites, contact centres and mobile applications. For more details of the methods please see ‘How we use cookies and other methods for the collection of website usage data’.
• Information about your device and your location if you have been browsing our website or using our mobile application, for example your IP address or unique device ID. (An IP address (i.e. Internet Protocol address) is a numeric code that can act as a unique identifier for your computer or other device – this can be turned off from your device).

When and why do we collect ‘sensitive personal data’?

Certain categories of personal information, such as that about race, ethnicity, religion, health, sexuality or biometric information are special categories of data requiring additional protection under European Union and UK data protection law and is referred to here as “sensitive personal data”. Generally, we try to limit the circumstances where we collect and process sensitive personal data. Examples of where we may collect and process ’sensitive personal data’ includes the following:

• You have requested specific medical assistance from us.
• You have informed us of a medical condition, or that you are more than 28 weeks pregnant.
• You have otherwise chosen to provide such information to us or it has been passed onto us by a third party.

In addition, you may have requested services (such as specific meal requirements) which are not ’sensitive data’ but may imply or suggest your religion, health or other information.

How we use your personal information

The main purposes for which we use your personal information are:

• To fulfil your travel arrangements and deliver the services you haveasked for.
• To facilitate your flight connections at the airport at the start and end of your holiday with us.
• To send status updates and service communications to you.
• To keep track of you in advance of your flight and at the airport.
• To help keep you safe when you travel with us and to meet certain legal and regulatory requirements which apply to traWell as as a travel services provider.
• To provide services tailored to your requirements and to treat you in a more personal way.
• To carry out analysis and market research.
• To carry out marketing including online advertising and keep you informed of traWell’s products and services.
• To undertake targeted online advertising.
• To send you status updates and service communications.
• To improve our websites, products and services.
• For management and administrative purposes.

Marketing communications

When we have your permission, we will send you marketing communications from traWell. As traWell we do sometimes send marketing communications that include a business partners’ products and services related to the travel you are undertaking, as well as our own.

We will only allow third parties or other members of our group to send marketing communications to you when we have agreed marketing from third parties.

We will respect your choice as to what communications you wish to receive and how these are sent.

Legal basis

traWell will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons traWell collected and needs to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be:

• Because we need to use your information so that we can process your booking, fulfil your travel arrangements and otherwise perform the contract we have with you.
• Because it is in traWell’s legitimate interests as a travel services provider to use your personal information to operate and improve our business.
• Because traWell needs to use your personal information to comply with a legal obligation.
• To protect the vital interests of you or another person.
• Because you have consented to traWell using your information for a particular purpose.

More information on each legal basis is provided below.

If processing of your data is subject to any other laws, then the basis of processing your data may be different to that set out above and may in those circumstances be based on your consent in all cases.

Retention of personal information

We will keep your information for as long as we need it for the purpose it is being processed for. For example, where you book a package with us we will keep the information related to your booking, so we can fulfil the specific travel arrangements you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that we can continue to improve your experience with us and to ensure that you receive any loyalty rewards which are due to you.

We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained. If you stop interacting with us as a customer, we will remove or anonymise your information after 7 years.

Performance of a contract with you

It will be necessary for traWell to use your personal information to complete a booking you have made with us. For example, we will need to use information such as your contact details and payment information to provide you with the holiday you have requested and paid for.

Legitimate Interests
As a travel provider traWell has a legitimate business interest to use the personal information we collect to offer an effective service and carry out our business.

Compliance with legal obligations
There are situations where traWell is subject to a legal obligation and needs to use your personal information to comply with those obligations.

To protect the vital interest of you or another person
There are situations where we may need to use your personal information to protect the vital interests of you or another person.

Consent
Alternatively, we may collect and use your personal information where you have given your specific consent to us doing so.

If the basis of our processing your data is consent to marketing, you can withdraw your consent to such processing at any time (see ‘Your legal rights in relation to the personal information we hold about you’).

However, if you withdraw your full consent, in some circumstances, it may mean we will not be able to provide all or parts of the services you have requested from us and you will not be able to cancel your booking or obtain a refund of any charges you have paid.

Sharing your personal information

We may disclose your personal information to the following third parties for the purpose described here:

• Customs and immigration authorities of any country in your itinerary, where required by law.
• Hotels and other service providers needed to deliver the services you have asked for.

• Credit and charge card companies, credit reference agencies and anti-fraud screening service providers to process payments and (where necessary) to carry out fraud-screening.
• In response to a valid, legal request from Government and law enforcement agencies such as customs and immigration authorities.
• Third parties, such as law firms and law courts, to enforce or apply any contract with you.
• Third parties, such as the police and regulatory authorities, to protect our rights, property, or the safety of our customers, staff and assets.
• We may provide usage information (but not your personal details) to other websites so that they know that you have visited our websites (see ’How we use cookies and other methods for the collection of website usage data’ above).
• We may provide usage information including your personal details to marketing agencies to deliver online advertising on websites or social networks.
• If necessary to comply with a legal or regulatory obligation in any jurisdiction, including where that obligation arises because of a voluntary act or decision by us (e.g. our decision to operate to a country or a related decision).

We do not sell personal information to third parties, and we only allow third parties to send you marketing information where we have your consent to do so.

To which countries will your personal information be sent?

Your personal information may be sent to and stored by us and third parties in countries outside the country in which you are located and outside the European Economic Area and the UK.

The nature of our business means it is often necessary for us to send your personal information outside the European Economic Area or the UK to fulfil your travel arrangements. This occurs because our business and the third parties identified in ’Who do we share your personal information with?’ have operations in countries across the world.

In addition, we may transfer your data to parties in countries outside the country in which you are located to provide services to us.

This may involve sending your data to countries where under their local laws you may have fewer legal rights.

Where your personal information is transferred outside the European Economic Area or the UK because we are using a service provider in a third country, we will implement safeguards so that your personal information continues to be protected to the standards set out in this privacy policy.

If you would like more information on these safeguards, please contact the Data Protection Officer, Smith & Behl Ltd, Brunel House, 340 Firecrest Court, Centre Park, Warrington, Cheshire, WA1 1RG, United Kingdom.

Your legal rights in relation to the personal information we hold about you

Under data protection laws in the European Union and the UK, you have certain rights in relation to your personal information. Responses to exercise your rights will be provided within one month and generally there is no fee for making these requests. If your request is particularly complicated we may extend the deadline for responding to three months, but we will let you know if this is the case.

We will handle all requests in accordance with applicable law. However, depending on the right you wish to exercise, and the nature of the personal information involved, there may be legal reasons why we cannot grant your request. Further explanation of those rights and the exceptions to them are set out below.

Details of how to exercise your rights are set out in the section below “How can you exercise your legal rights and change how we use your data?

Your rights include the following:

1. You may request us to stop sending you marketing, by clicking the ‘unsubscribe’ link at the bottom of any of our email. If you do so we will no longer be able to send you marketing communications. However, if you subsequently book a package with us we will need to send you communications about the services you have booked to use. These communications will help you get the most from the services we provide and may also contain options and other details about the services you will be using.
2. You may request us to stop using your personal information where we are doing so under legitimate interests unless it is needed for dealing with legal claims or we have other compelling legitimate reasons that override your rights.
3. You may request us to stop processing of your personal information for marketing purposes including analytics for the purposes of targeted marketing, including online advertising.
4. You may access the personal information we hold on you.
   There are some limited exceptions to this right, such as information relating to others who have not consented to the disclosure of their information and information which is legally privileged.
5. You may ask us to correct the personal information that you have shared with us (the ‘right of rectification’) if that information is inaccurate. Please email the details to [email protected]. We are not able to amend any data that has been created as a result of a transaction with us.
6. You may ask for personal information which identifies you to be removed (anonymised).

To do this the information that identifies you will be removed our active systems. However, a separate and restricted copy of the identifying information will be kept for 7 years to meet the obligations we have to law enforcement, national authorities and legal proceedings.

Considerations for removing/anonymising data:

• We may need to retain certain elements that relate to a contract between you and Smith & Behl Ltd because we need it for our own legal and auditing purposes (for more information on the basis on which we process your personal information see the section “What is our legal basis for using your personal information?”).
• A record of your request including the personal information you supplied will be retained in the application used to carry this out for 3 years.
• In some circumstances it may mean we will not be able to provide all or parts of the services you have requested from us in relation to previous travel or retain any preferences you have previously shared with us.
• We cannot erase your personal information if you have either travelled with us in the past 13 months or you hold a forward booking with us. You may come back to us once this time period has passed and submit a request.
• We cannot erase your personal information if we have identified that you either have an open complaint with us or we hold a previous case for you within the past 6 years. We are required to retain this information in case there is a need to re-open the complaint.

Reviewing your personal information

If you wish to review the personal identifiable information we hold on you and your flight history, or to receive a copy of any other information we hold on you, we ask that you make a request in writing and include the following information with your request:

• Your name and postal address
• Details of your request
• We need corroborating information to establish your identity this could be: a photocopy of your passport or driving licence.
• your signature and the date of the request
• if you are applying on behalf of another person then signed authority from the individual is required

Any details which may help us locate the information which is the subject of your request, for example:, your booking reference or travel itinerary and dates

You may also send your request to: [email protected]

The address for a written request is:

Data Protection Officer
Smith & Behl Ltd
Brunel House
340 Firecrest Court
Centre Park
Warrington
Cheshire
WA1 1RG
United Kingdom

Changes to this Privacy Policy

If we change this Privacy Policy, we will let you know about the changes by publishing the updated version on trawell.global.  We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Policy.

This Privacy Policy came into effect on 20 December 2019. This Privacy Policy applies to all information we process about you in connection with your relationship with us as a customer or potential customer.

Please write to the Data Protection Officer if you would like to find out more about any matters to do with this Privacy Policy.

How to contact us / Your right to complain

If you have any questions about this policy, please contact the Data Protection Officer.

The Data Protection Officer for traWell can be contacted at [email protected]. Please note that traWell’s Data Protection Officer is also the data protection officer for Smith & Behl Ltd.

We work hard to handle your information responsibly. If you are unhappy about the way we do this, please contact traWell’s Data Protection Officer who will address your concerns.

We hope that we will be able to resolve any concerns you may have.

However, you have a right to complain to the UK’s Supervisory Authority for data protection, the Information Commissioner at:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF