Privacy Policy

GENERAL STATEMENT
This Privacy Policy governs the manner in which Pound Travels collects, uses, maintains and discloses information collected from users (each, a “User”) of the Pound Travels website (“Site”). This privacy policy applies to the Site and all services offered by Pound Travels.
This document states our privacy policy in respect of customer personal data, which will govern the way we process personal data you provide us. It serves as an expression of our commitment to protecting your private personal information, but is not a contract.

INTRODUCTION
We gather and use certain information about individuals in order to provide products and services and to enable certain functions on this website.
We also collect information to better understand how visitors use this website and to present timely, relevant information to them.

OUR CONSENT
By using our websites, providing any personal data to us, or booking any travel services with us, you confirm that you agree to and consent to the terms of this document, to the extent your consent is required by any applicable law

OUR COMMITMENT
We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites and booking with or through us. We understand many of our customers care about how personal data is used by us, and we want to share with you our policies and practices.

WHO OUR PRIVACY POLICY COVERS
Our customers
Our privacy policy sets out how we process personal data (including information) relating to individuals who book or enquire about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

Examples of who this policy covers
We include in this privacy policy personal data we process relating to:
(1) individuals who make an enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family and tour group members, and officers and employees of businesses and organizations booking with or through us);
(2) individuals in respect of whom an enquiry or booking is made with us by an agent;
(3) where our customer is a business or organization, employees or individuals who act as representatives of that business or other organization, and individuals connected to that business or other organization, such as owners, partners, shareholders, and directors;
(4) individuals whose personal data comes from other companies in our group (such as where you consented to your personal data being disclosed to other group companies for marketing purposes).

TERMS USED IN THIS POLICY
When we refer to “you” and “your” in this privacy policy, we mean any such individual whose personal data we process from time to time.
When we refer to “processing” your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.
When we refer to “travel services” this covers all products and services which may be booked with or through us, such as bespoke vacations, package vacations, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provided by a third party which we book for you (acting as agent for you or the third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

WHAT LAWS WE COMPLY WITH
We comply generally with the laws of the United Kingdom in relation to the processing of your personal data.

WHAT TYPES OF PERSONAL DATA WE PROCESS
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licenses, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out about you (such as to verify your identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and other information provided to us by or in relation to you which concern you as an individual.

BUSINESS RELATED INFORMATION
If you are an individual associated with a business or other organization that is our customer, your personal data may include the following information that we link to you: business or organization details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organization (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

ENQUIRY AND BOOKING INFORMATION
Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for vacation and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the vacation, accommodation, travel, car hire, and other travel services booked or enquired about; details of passengers / vacationers travelling; details of the provider of travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

WEBSITE USAGE INFORMATION
We may collect information about your visits to, browsing of, and use of our website. The range of data we collect will depend on how you interact with our website.
This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch, etc.); web browser make and version (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you use; operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux, etc); time-zone; browser plug-ins; web-page you came from, identified as referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is linked to you personally.
This information may also include: data inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

PERSONALLY-IDENTIFIABLE INFORMATION
In order to make booking or reservation at Pound Travels, we require that you provide us with certain personally identifiable information (please see our Terms of Service for additional details). The types of personally identifiable information that may be collected by Pound Travels through the Website include, without limitation: name, address, e-mail address, cell phone number and MSISDN (mobile station integrated services digital network number), credit card and billing information, download history, texts, messages, customer generated content and/or information about your interests in and use of various products, programs, and services. Pound Travels will not collect any personally identifiable information about you unless you provide it to us voluntarily.
Please know that you will retain ownership of any information that you may include in your account and contact lists in order to identify recipients of your messages through Pound Travels’ services, and Pound Travels will not use contact lists for its own promotional campaigns or sell contact lists to third-parties, subject at all times to Pound Travels’ need to access and use such information in order to provide the services pursuant to its Terms of Service and this Privacy Policy.

We may use such personally identifiable information to provide the services that you have requested, to contact you about programs, products, features or services in which we believe you may be interested (such as future promotional materials), or for other purposes disclosed from time to time. We also may use your personally identifiable information to contact you regarding your use of our Website or changes to our Privacy Policy, Terms of Service, or other policies or terms that affect you and your use of our Website and services. In addition, we may use information collected about our users to improve the content and navigation of our Website, or for other internal purposes.

To fulfil your requests for products and services, we may share the personally identifiable information you provide with your cell phone service provider or their partner and subcontractor companies. Please know that this Privacy Policy does not cover such entities use of information. To learn more about your provider’s privacy practices, you should consult its privacy policy.
We also use third party service providers such as an email service provider to send out emails on our behalf. When you sign up for our services, we will share your personal information as necessary for the third party to provide that service.

In addition, we may disclose personally identifiable information collected about you in the following instances:
A. Legal Action: We may disclose information about our users, including personally identifiable information; (i) when requested by governmental or quasi-governmental authorities conducting an investigation; (ii) if required to do so by subpoena, court order or legal process; (iii) to verify or enforce compliance with the policies governing our Website and applicable laws; or (iv) to protect against misuse or unauthorized use of our Website. We also may disclose user information whenever we believe disclosure is necessary to limit our legal liability; to protect or defend our rights or property; or protect the safety, rights, or property of our users.
B. Change in Control: We may sell, transfer, or otherwise disclose user information, including personally identifiable information, to a successor entity in connection with a corporate merger, consolidation, the sale of substantially all assets, or other corporate change respecting Pound Travels, the Website and/or the services offered hereby.
Except as stated in this Privacy Policy, or as otherwise stated at the time personally-identifiable information is gathered, Pound Travels will not provide personally-identifiable information to third parties who are not under the direction and control of Pound Travels.

TYPES OF DATA COLLECTED
Among the types of Personal Data that (Name of Company)collects, by itself or through third parties, there are: Cookies, Usage Data, Data communicated while using the service, first name, last name, email address, various types of Data, phone number, address, username, password, company name, country, state, province, ZIP/Postal code, city, billing address, shipping address, house number and unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provide d by the User, or, in case of Usage Data, collected automatically when using Pound Travels.
Unless specified otherwise, all Data requested by Pound Travels is mandatory and failure to provide this Data may make it impossible for Pound Travels to provide its services. In cases where Pound Travels specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Pound Travels or by the owners of third-party services used by Pound Travels serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Pound Travels and confirm that they have the third party’s consent to provide the Data to the Owner.

HOW WE USE THE INFORMATION COLLECTED
We usually use your information to:
1. Facilitate the creation of and securing your user account;
2. Define you as a user in our system;
3. Providing, customizing and improving the services;
4. Provide feedback and user base demographics of third parties listed on websites or services;
5. To communicate with you about your use of the services for your benefit;
6. Development of new products and services,
7. Tracking the use of websites and services;
8. Personalize the ad you view and recommend content;
9. Backup our systems and enable emergency recovery;
10. Fulfilment of your inquiries and providing customer support;
11. Send newsletters, surveys, offers and promotional materials related to the services and your user preferences and behaviours, as well as for other marketing purposes.
12. Defend, investigate, prevent and potentially take action against possible fraudulent, unauthorised or unlawful activities;
13. To respond to claims that the content of the website is inauthentic, false or otherwise violates the rights of third parties;
14. Respond to your enquiries for customer service;
15. Protect our rights and the rights of other users;
16. Enforce terms of use, privacy policy, and any other policies governing your access to or use of websites or services.
17. Enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you.

ACCESS TO PERSONAL INFORMATION
If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, delete or deactivate it by making the change on our member information page or by contacting us using the Contact Us on the website. We will respond to your request to access within 30 days.
We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

HOW WE PROTECT YOUR INFORMATION
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information and data stored on our Site.

TRANSFERS OF DATA OUT OF THE EEA
We will make reasonable efforts to ensure that your data is not transferred outside the European Economic Area (EEA). Where we use data servers that may transfer data out of the EEA we will take steps to ensure adequate protections are in place to ensure the security of your information and give you remedies in the unlikely event of a security breach.
All information you provide to us is stored with secure data processors for the purposes of storing your data, accounting purposes and social media purposes
Please note that we review all processors we utilise and ensure that there are adequate safeguards in place to protect your personal data, such as adherence to binding corporate rules or compliance with the EU-US Privacy Shield Framework, which is a mechanism that ensures compliance with EU data protection requirements when transferring personal data from the European Union to the United States.
While we will use all reasonable efforts to safeguard your personal data, you acknowledge that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data that are transferred from you or to you via the internet. If you have any particular concerns about your information, please contact us using our contact details at the bottom of this policy.

THE RIGHTS OF USERS
Users may exercise certain rights regarding their Data processed by the Owner.
Users entitled to broader protection standards may exercise any of the rights described below. In all other cases, Users may inquire with the Owner to find out which rights apply to them.
In particular, Users have the right to do the following:
• Right to obtain a copy of your personal information. You have the right to obtain a copy of the personal information we hold about you.
• Right to rectification. You may request that we rectify any inaccurate and/or complete any incomplete personal information. We will then correct out records, and notify any third parties to whom such personal information may have been transmitted as described above.
• Right to data portability. You may request a copy of all personal information you have provided to us after which we will transmit those data to another data controller of your choice.
• Right to opt-out of marketing communications. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.
• Right to withdraw consent. You may withdraw your consent to the processing of your personal information at any time. Such withdrawal will not affect the lawfulness of processing based on your previous consent. Please note that if you withdraw your consent, you may not be able to benefit from certain service features for which the processing of your personal information is essential.
• Right to object to processing. You may request that we stop processing your personal information. Please note you may not be able to benefit from certain service features for which the processing of your personal information is essential.
• Right to erasure. You may request that we erase your personal information and we will comply, unless there is a lawful reason for not doing so.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION
Our lawful basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect vital interests.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
If you have questions about or need further information concerning the lawful basis on which we collect and use your personal information, please contact us.

USE OF YOUR PERSONAL DATA FOR DIRECT MARKETING
We do not use or disclose your personal data for direct marketing purposes unless we obtained your consent, such as through an opt-in or opt-out tick box on any form or website of ours.
We may also use personal information you provide us to review and improve the guided vacations and services we offer, and to contact you (by mail, email, telephone or other means) about other guided vacations and services offered by Pound Travel

TRANSMISSIONS BETWEEN YOUR WEB BROWSER AND OUR SERVERS
We use Secured Socket Layer (“SSL”) software to encrypt personal information you provide us while it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

STORAGE OF YOUR PERSONAL DATA
Personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

USE OF COOKIES
This website uses cookies to better the users experience while visiting the website. Where applicable this website uses a cookie control system allowing the user on their first visit to the website to allow or disallow the use of cookies on their computer / device. This complies with recent legislation requirements for website’s to obtain explicit consent from users before leaving behind or reading files such as cookies on a user’s computer / device.
Cookies are small files saved to the users computer’s hard drive that track, save and store information about the user’s interactions and usage of the website. This allows the website, through its server to provide the users with a tailored experience within this website.
Users are advised that if they wish to deny the use and saving of cookies from this website on to their computers hard drive they should take necessary steps within their web browsers security settings to block all cookies from this website and its external serving vendors.
This website uses tracking software to monitor its visitors to better understand how they use it. This software is provided by Google Analytics which uses cookies to track visitor usage. The software will save a cookie to your computer’s hard drive in order to track and monitor your engagement and usage of the website but will not store, save or collect personal information. Other cookies may be stored to your computer’s hard drive by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking and typically expire after 30 days, though some may take longer. No personal information is stored, saved or collected.

YOUR SECURITY MEASURES
For your privacy protection, you should maintain anti-virus and other malware protection software on your computers and other devices, and maintain other measures and follow other procedures to protect your personal data. You should not include sensitive personal data in any e-mails you send us, including payment card information.
We encourage you to be careful about whom you give personal data to. Regarding sensitive personal data, such as payment card information, or passport numbers or log-in details, we will only ask you for such information in person or through our website, or by telephone in connection with a booking you make or made. If you are ever in doubt about who is contacting you, asking for information, or why, please do not provide the information. Instead, contact us directly to inquire about the request for information. Please let us know if someone purports to contact you in other circumstances, using our name.

LEGAL DISCLOSURE
Under limited circumstances, Bulk Trader may disclose your personal information to third parties as permitted by, or to comply with, applicable laws. For example, we may disclose personal information to cooperate with law enforcement agencies to comply with subpoenas or other official requests, and as necessary to protect our rights or property. Except as described in this privacy policy, we will not use your personal information for any other purpose, unless we describe how such information will be used at the time you disclose it to us or we obtain your permission.

HOW LONG DO WE KEEP YOUR PERSONAL DATA
We keep your personal data as long as reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal data may be relevant to a possible obligation or liability we may have.

EXTERNAL LINKS
Although this website only looks to include quality, safe and relevant external links users should always adopt a policy of caution before clicking any external web links mentioned throughout this website.
The owners of this website cannot guarantee or verify the contents of any externally linked website despite their best efforts. Users should therefore note they click on external links at their own risk and this website and its owners cannot be held liable for any damages or implications caused by visiting any external links mentioned.

APPLICABLE LAW AND DISPUTES
This policy is subject to the law of the United Kingdom and International law and you must bring any claims against us exclusively in the courts of the state of United Kingdom.

YOUR ACCEPTANCE OF THESE TERMS
By accessing the Website, you signify your assent to the Pound Travels Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Website. You should visit this page periodically, as we may, from time to time, update this Privacy Policy and such changes shall be effectively immediately upon posting on the Website and without further notice to you. Your continued access to the Website following the posting of changes to this Privacy Policy shall be deemed an acceptance of such changes by you. Pound Travels will, however, use personally-identifiable information only in accordance with the version of the Privacy Policy under which the information was collected.

CHANGES TO THIS PRIVACY POLICY
We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be aware of changes. You should check the top of the document to see the latest version.

INQUIRIES AND FURTHER DETAILS
If you would like to: access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information please contact us at info@poundtravels.com