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.
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:
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:
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:
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:
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.
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:
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.
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.
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:
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.
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:
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:
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:
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@example.com
The address for a written request is:
Data Protection Officer
Smith & Behl Ltd
340 Firecrest Court
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 firstname.lastname@example.org. 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