Privacy Policy
We take your privacy very seriously. Please read this privacy policy carefully as it contains important
information on who we are, how and why we collect, store, use and share your personal data. It also
explains your rights in relation to your personal data and how to contact us or supervisory authorities
in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are
subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU
General Data Protection Regulation (EU GDPR) in relation to goods and services we offer to
individuals in the European Economic Area (EEA).
Key terms
It would be helpful to start by explaining some key terms used in this policy:
We, us, our Hummingbird-Tours Ltd (Company number
15645849)
6 Hurstbourne Priors, Whitchurch, Hampshire,
United Kingdom RH28 7SE
Our data protection manager Nicholas Tucker
Personal data Any information relating to an identified or
identifiable individual
Special category personal data Personal data revealing racial or ethnic origin,
political opinions, religious beliefs, philosophical
beliefs or trade union membership
Genetic data
Biometric data (where used for identification
purposes)
Data concerning health, sex life or sexual
orientation
Data subject The individual who the personal data relates to
Personal data we collect about you
The personal data we collect about you depends on the particular products and services we provide
to you. We may collect and use the following personal data about you:
• your name and contact information, including email address and telephone number and
company details.
• information to check and verify your identity, e.g. your date of birth.
• your gender, if you choose to give this to us.
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• location data, if you choose to give this to us.
• your billing information, transaction and payment card information.
• your next of kin and contact information.
• dietary requirements.
• height and weight.
• travel insurance details.
• passport details (including nationality and place of birth).
• scan of your passport.
• visa application.
• medical / health information (including pre-existing medical conditions).
• vaccination status.
• disability.
• details of mediation.
• food allergies or religious food restrictions.
We collect and use this personal data for the purposes described in the section ‘How and why we
use your personal data’ below. If you do not provide personal data we ask for, it may delay or
prevent us from providing products and services to you.
How your personal data is collected
We collect most of this personal data directly from you—in person, by telephone, text or email and/or
via our website.
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, eg:
• where you have given consent;
• to comply with our legal and regulatory obligations;
• for the performance of a 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 personal data, so
long as this is not overridden by your own rights and interests. We will carry out an assessment when
relying on legitimate interests, to balance our interests against your own.
The table below explains what we use your personal data for and why.
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What we use your personal data for Our reasons
Providing products and services to you To perform our contract with you or to take
steps at your request before entering into a
contract
Preventing and detecting fraud against you or
us
For our legitimate interest, i.e. to minimise
fraud that could be damaging for you and/or us
Conducting checks to identify our customers
and verify their identity
Screening for financial and other sanctions or
embargoes
Other activities necessary to comply with legal
and regulatory obligations that apply to our
business, e.g. under health and safety law or
rules issued by our professional regulator.
Depending on the circumstances:
—to comply with our legal and regulatory
obligations
—for our legitimate interests
To enforce legal rights or defend or undertake
legal proceedings
Depending on the circumstances:
—to comply with our legal and regulatory
obligations;
—in other cases, for our legitimate interests,
i.e. to protect our business, interests and rights
Ensuring business policies are adhered to, e.g.
policies covering security and internet use
For our legitimate interests, i.e. to make sure
we are following our own internal procedures
Operational reasons, such as improving
efficiency, training and quality control
For our legitimate interests, i.e. to be as
efficient as we can so we can deliver the best
service to you at the best price
Ensuring the confidentiality of commercially
sensitive information
Depending on the circumstances:
—for our legitimate interests, i.e. to protect
trade secrets and other commercially valuable
information;
—to comply with our legal and regulatory
obligations
Statistical analysis to help us manage our
business
For our legitimate interests, i.e. to be as
efficient as we can so we can deliver the best
service to you at the best price
Preventing unauthorised access and
modifications to systems
Depending on the circumstances:
—for our legitimate interests, i.e. to prevent and
detect criminal activity that could be damaging
for you and/or us;
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—to comply with our legal and regulatory
obligations
Protecting the security of systems and data
used to provide the goods and services
To comply with our legal and regulatory
obligations
We may also use your personal data to ensure
the security of systems and data to a standard
that goes beyond our legal obligations, and in
those cases our reasons are for our legitimate
interests, ie to protect systems and data and to
prevent and detect criminal activity that could
be damaging for you and/or us
Updating and enhancing customer records Depending on the circumstances:
—to perform our contract with you or to take
steps at your request before entering into a
contract;
—to comply with our legal and regulatory
obligations;
—for our legitimate interests, e.g. making sure
that we can keep in touch with our customers
about existing orders and new products
Statutory returns To comply with our legal and regulatory
obligations
Ensuring safe working practices, staff
administration and assessments
Depending on the circumstances:
—to comply with our legal and regulatory
obligations;
—for our legitimate interests, eg to make sure
we are following our own internal procedures
and working efficiently so we can deliver the
best service to you
Marketing our services and those of selected
third parties to:
—existing and former customers;
—third parties who have previously expressed
an interest in our services;
—third parties with whom we have had no
previous dealings.
For our legitimate interests, ie to promote our
business to existing and former customers
Credit reference checks via external credit
reference agencies
For our legitimate interests, i.e. to ensure our
customers are likely to be able to pay for our
products and services
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To share your personal data with members of
our group and third parties that will or may take
control or ownership of some or all of our
business (and professional advisors acting on
our or their behalf) in connection with a
significant corporate transaction or
restructuring, including a merger, acquisition,
asset sale, initial public offering or in the event
of our insolvency
In such cases information will be anonymised
where possible and only shared where
necessary
Depending on the circumstances:
—to comply with our legal and regulatory
obligations;
—in other cases, for our legitimate interests, ie
to protect, realise or grow the value in our
business and assets
How and why we use your personal data—in more detail
More details about how we use your personal data and why are set out in the table below.
Purpose Processing
operation
Lawful basis relied
on under the UK
GDPR and EU GDPR
Relevant categories
of personal data
Communications with
you not related to
marketing, including
about changes to our
terms or policies or
changes to the
products or other
important notices
(other than those
addressed above)
Addressing and
sending
communications to
you as required by
data protection laws,
i.e.:
—the UK GDPR or
Data Protection Act
2018;
—the EU GDPR
Processing is
necessary for
compliance with a
legal obligation to
which we are subject
(Article 6(1)(b))
—your name, address
and contact
information, including
email address and
telephone number;
—your account details
(username)
Addressing and
sending
communications to
you
Processing is
necessary for
compliance with a
legal obligation to
which we are subject
(Article 6(1)(b))
—your name, address
and contact
information, including
email address and
telephone number.
Addressing and
sending
communications to
you about changes to
our terms or policies
or changes to the
products or other
important notices
Our legitimate
interests (Article
6(1)(f)), which is to be
as efficient as we can
so we can deliver the
best service to you
—your name, address
and contact
information, including
email address and
telephone number.
—your account details
(username)
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How and why we use your personal data—Special category personal data
Certain personal data we may collect is treated as a special category to which additional protections
apply under data protection law:
• health information, including any mental health problems; and
• dietary information.
Where we process special category personal data, we will also ensure we are permitted to do so
under data protection laws, e.g.:
• we have your explicit consent;
• the processing is necessary to protect your (or someone else’s) vital interests where you are
physically or legally incapable of giving consent; or
• the processing is necessary to establish, exercise or defend legal claims.
How and why we use your personal data—sharing
See ‘Who we share your personal data with’ for further information on the steps we will take to
protect your personal data where we need to share it with others.
Marketing
We will use your personal data to send you updates (by email, text message, telephone or post)
about our products and services, including exclusive offers, promotions or new products and services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How
and why we use your personal data’). This means we do not usually need your consent to send you
marketing information. If we change our marketing approach in the future so that consent is needed,
we will ask for this separately and clearly.
You do, however, have the right to opt out of receiving marketing communications at any time by
contacting us.
We may ask you to confirm or update your marketing preferences if you ask us to provide further
products and services in the future, or if there are changes in the law, regulation, or the structure of
our business.
We will always treat your personal data with the utmost respect and never sell or share it with other
organisations for marketing purposes.
Who we share your personal data with
We routinely share personal data with:
• third parties we use to help deliver our products and services to you, e.g. payment service
providers, warehouses and delivery companies;
• other third parties we use to help us run our business, e.g. marketing agencies or website
hosts;
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• 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;
• our banks.
We only allow those organisations to handle your personal data if we are satisfied they take
appropriate measures to protect your personal data. We also impose contractual obligations on them
to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above occasionally also share personal data with:
• our and their external auditors, e.g. in relation to the audit of our or their accounts, in which
case the recipient of the information will be bound by confidentiality obligations;
• our and their professional advisors (such as lawyers and other advisors), in which case the
recipient of the information will be bound by confidentiality obligations;
• law enforcement agencies, courts, tribunals and regulatory bodies to comply with our legal
and regulatory obligations;
• other parties that have or may acquire control or ownership of our business (and our or their
professional advisers) in connection with a significant corporate transaction or restructuring,
including a merger, acquisition, asset sale, initial public offering or in the event of our
insolvency—usually, information will be anonymised but this may not always be possible. The
recipient of any of your personal data will be bound by confidentiality obligations.
Where your personal data is held
Personal data may be held at our offices and those of our third party agencies, service providers,
representatives and agents.
Some of these third parties may be based outside the UK/EEA. For more information, including on
how we safeguard your personal data when this happens, see below: ‘Transferring your personal
data out of the UK and EEA’.
How long your personal data will be kept
We will not keep your personal data for longer than we need it for the purpose for which it is used.
If you no longer have an account with us or we are no longer providing goods or services to you, we
will usually delete or anonymise your account data after seven years.
Following the end of the of the relevant retention period, we will delete or anonymise your personal
data.
Transferring your personal data out of the UK and EEA
It is sometimes necessary for us to transfer your personal data to countries outside the UK and EEA.
In those cases we will comply with applicable UK and EEA laws designed to ensure the privacy of
your personal data.
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We may transfer your personal data to our service providers located outside the UK.
We may also transfer your personal data from the EEA to the UK.
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA
where:
• the UK government has decided the particular country ensures an adequate level of
protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the
UK GDPR. A list of countries the UK currently has adequacy regulations in relation to is
available here.
• in the case of transfers subject to EEA data protection laws, the European Commission has
decided that the particular country ensures an adequate level of protection of personal data
(known as an ‘adequacy decision’) further to Article 45 of the EU GDPR. A list of countries
the European Commission has currently made adequacy decisions in relation to is available
here.
• there are appropriate safeguards in place, together with enforceable rights and effective legal
remedies for you; or
• a specific exception applies under relevant data protection law.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we
rely on to transfer personal data internationally will be notified to you in accordance with the section
on ‘Changes to this privacy policy’ below.
Your rights
You have the following rights, which you can exercise free of charge:
Access The right to be provided with a copy of your
personal data
Rectification The right to require us to correct any mistakes
in your personal data
Erasure (also known as the right to be
forgotten)
The right to require us to delete your personal
data—in certain situations
Restriction of processing The right to require us to restrict processing of
your personal data in certain circumstances, eg
if you contest the accuracy of the data
Data portability The right to receive the personal data 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 data being
processed for direct marketing (including
profiling);
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—in certain other situations to our continued
processing of your personal data, eg
processing carried out for the purpose of our
legitimate interests unless there are compelling
legitimate grounds for the processing to
continue or the processing is required for the
establishment, exercise or defence of legal
claims
Not to be subject to automated individual
decision making
The right not to be subject to a decision based
solely on automated processing (including
profiling) that produces legal effects concerning
you or similarly significantly affects you
The right to withdraw consent If you have provided us with a consent to use
your personal data you have a right to withdraw
that consent easily at any time
You may withdraw consent by [insert details as
relevant depending on consents]
Withdrawing consent will not affect the
lawfulness of our use of your personal data in
reliance on that consent before it was
withdrawn
For more information on each of those rights, including the circumstances in which they apply, please
contact us (see ‘How to contact us’ below) or see the Guidance from the UK Information
Commissioner’s Office (ICO).
If you would like to exercise any of those rights, please:
• email, call or write to us—see below: ‘How to contact us’; and
• provide enough information to identify yourself (eg your full name, address and customer or
matter reference number) and any additional identity information we may reasonably request
from you;
• let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being lost accidentally, or used
or accessed unlawfully. We limit access to your personal data to those who have a genuine business
need to access it. Those processing your personal data will do so only in an authorised manner and
are subject to a duty of confidentiality.
We also have procedures 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 on how to protect your personal data and other information and your
computers and devices against fraud, identity theft, viruses and many other online problems, please
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visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading
businesses.
How to complain
Please contact us if you have any queries or concerns about our use of your personal data (see
below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You may also have the right to lodge a complaint with the Information Commissioner (the UK data
protection regulator).
Changes to this privacy policy
This privacy notice was published on 16 September 2024 and last updated on 16 September 2024.
We may change this privacy notice from time to time—when we do we will inform you via our website.
Updating your personal data
We take reasonable steps to ensure your personal data remains accurate and up to date. To help us
with this, please let us know if any of the personal data you have provided to us has changed, eg your
surname or address—see below ‘How to contact us’.
How to contact us
Individuals in the UK
You can contact us by post, email or telephone if you have any questions about this privacy policy or
the information we hold about you, to exercise a right under data protection law or to make a
complaint.
Our contact details are shown below:
Hummingbird Tours Ltd
6 Hurstbourne Priors
Whitchurch
Hampshire
United Kingdom
RG28 7SE