Data Protection & Privacy

Privacy Notice

1 Your Personal Data and Privacy

We (RWH Travel Ltd) use your personal data to operate, provide and market holiday services to you. We are committed to protecting and respecting your privacy.

Please take a few minutes to read this Privacy Notice carefully to understand our views and practices regarding your personal data, and how we’ll treat it. There are steps you can take to control what we do with your data and we have explained those steps in this Privacy Notice.

The Data Controller is RWH Travel Ltd of Lemsford Mill, Lemsford Village, Welwyn Garden City, Hertfordshire, AL8 7TR.

1 Your Personal Data and Privacy
2 The information we might hold about you
3 How we will use your personal data?
4 Using your data for marketing purposes
5 Who might we share your information with
6 The basis on which we might use your personal data
7 How long will we hold your personal data for?
8 Protecting your personal data
9 Your rights in respect of the personal data we hold about you
10 Where we store your personal data
11 Links from our website
12 Implementation of the Privacy Notice
13 Advice and assistance
14 Changes to this Privacy Notice

2 The information we might hold about you

We need to collect certain personal details from you in order to process your booking, brochure and holiday information requests, provide your holiday arrangements and to provide you with a more personal service.

Depending on the reason that you have contacted us or we have contacted you, we will hold the following information about you:

• Information you give to us

  This is information that you give to us when you fill in forms on our website (rambleworldwide.co.uk) or by corresponding with us by phone, email or otherwise.

  It includes information you provide when you: register to use our website; subscribe to receive information from us; request a brochure or information about us, our holidays, or the services we provide; make a holiday booking; buy holiday insurance from us; contact our Customer Relations Team; complete a post holiday questionnaire; enter a competition, promotion or survey; and when you report a problem with our website.

  Details we collect will include, where applicable: the names and contact details of you and those in your party; passport details; credit card, debit card or other payment details; and where you agree to provide us with such information: relevant medical conditions or disability information which may affect your participation in your chosen holiday arrangement, and; any dietary restrictions which may disclose your religious beliefs.

  In addition, if you are contacting us in a business capacity, it may include information you provide concerning the services you provide or your business relationship with us.

  Please note that telephone calls may be recorded for training and monitoring purposes.

• Personal data you provide about other individuals

  We use personal data provided by you about other individuals, such as those in your party when you make a booking. By providing other people’s personal data, you must be sure that they agree to this and you are allowed to provide it. You should also ensure that, where appropriate, they understand how their personal data may be used by us.

• Information we receive from other sources
  Where relevant we may receive personal data from third parties including, for example: third party suppliers of holiday services such as hotels, transport providers and local guides; emergency assistance providers and the emergency services; sub-contractors in technical, payment and delivery services; holiday review platform providers; analytics providers; search information providers; and holiday brands in the same group as RWH Travel Ltd (including Ramble Worldwide).
  We record any basic observations made by our tour leaders relating to your ability to cope with the nature and demands of previous holidays to enable us to advise you on the suitability of holidays you may wish to take in the future.

• Information relating to businesses only

  If you are acting in a business capacity, we may receive information from: persons making an enquiry or complaint; trade and professional bodies; regulatory authorities; police forces. In such cases, the information we receive may also include: racial or ethnic origin; religious or other beliefs of a similar nature; information about alleged offences; visual images, personal appearance and behaviour; employment; and education, experience and training details.

3 How we will use your personal data

We will only use the information that we collect about you lawfully and comply with the General Data Protection Regulation 2016, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other relevant consumer protection legislation.

Depending on the reason for holding your data we will use the information we hold for the following purposes:

• process your booking, brochure and holiday information requests, provide your holiday arrangements and to provide you with a more personal service;

• to provide you and, if appropriate, our tour leaders with information and advice to ensure that you are able to participate as fully as possible in the holiday arrangements;

• to provide you, or permit selected third parties mentioned in paragraph 5 to provide you, with information about goods or services we feel may interest you;

• to make suggestions and recommendations to you about services or goods that may interest you;

• to allow you to participate in features of our website(s), when you choose to do so;

• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;

• to notify you about changes to our holiday services;

• where relevant, to provide you with assistance and claims handling services;

• to respond to and to manage security operations, accidents or other similar incidents, including medical and insurance purposes;

• to carry out market research and internal research and development, and to develop and improve our product range, services, security, know-how and the way we communicate with you;

• to administer our site(s) and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

• as part of our efforts to keep our website and other IT systems safe and secure

Should you decline or fail to provide us with the personal details necessary for the processing of your booking, to confirm your ability to fully participate in the holiday arrangements or to comply with statutory requirements we will be unable to provide your holiday services and may be forced to cancel you booking, in which circumstances, we will consider this a cancellation by you.

We will only contact you to help you make the most of what we offer. This means for purposes such as:

• Asking you for information necessary to process your holiday arrangements

• Sending you brochures with our holidays for the coming season

• Providing you with newsletters to keep you up to date with our programme of holidays

• Tips, information and guidance to help you make informed choices about our holidays, destinations and services

• Sending you periodic holiday offers we think might be of interest to you

• To get your feedback on our holidays or services

We will make all efforts to ensure that our contact with you is relevant to the personal information we have collected.

4 Using your data for marketing purposes

We would also like to store and use your personal details for future marketing purposes. We do this in various ways, for example by sending you a brochure, with details of new features, tours or special offers which we think may be of interest to you. We would like to contact you by mail, email or e-flyer, but only if you want us to. Similarly, we may also send you information about selected third parties’ products and services that may be of interest to you (such as airport accommodation or parking or offers from outdoor equipment suppliers).

We like to hear your views to help us to improve our products and services, so we may contact you for market research purposes. You always have the choice about whether to take part or continue in our market research.

We promise never to sell, rent, trade or otherwise release your personal details to any outside the RWH Travel Ltd group for their mailing or marketing purposes.

We will only use your data for legitimate marketing purposes where we believe our services will be of interest to you when you have contacted us or made a holiday booking with us and you have not told us that you no longer wish to receive marketing messages.

You can ask us not to use your personal data for marketing purposes. You can do this by checking certain boxes or unsubscribe links on the forms we use to collect your data and on any marketing emails we send you. You can also ask us at any time by visiting our Preference Centre or by contacting us.

Photographs and video footage

From time-to-time, our staff, your travelling companions, journalists, appointed photographers and suppliers may take photographs and video footage of holidays in progress, including images of our clients. These pictures may be used in future marketing materials and stored physically and digitally. You have the right to decline to be photographed whilst participating in our holiday arrangements. Should you not wish to be filmed or photographed and images of you used in this manner, please make your wishes known to your tour leader and the photographer at the start of your holiday. Should an identifiable image of you be displayed in our website or brochures, we will on request remove these from our website without delay and delete the image from our records to prevent any future use.

5 Who we might share your information with

We need to pass on your personal details to companies and organisations who need to know them in order to be able to provide your holiday arrangements (for example, airlines, hotels, credit card companies and banks). Such companies and organisations may be outside the European Union if your holiday is to take place or involves suppliers outside this area. It may also be processed by organisations operating outside the EEA who work for us or for one of our suppliers.

Occasionally we hire other companies to provide services on our behalf, for example mailing information to our customers. We only provide those companies with the personal details relating to our clients which they require in order to deliver the service. They are prohibited from using that information for any other purpose including their own marketing purposes. We will ensure that anyone to whom we pass your details for this reason agrees to treat it with the same level of protection we are obliged to provide.

Where necessary or where we have the right to do so, we will share your personal information with any member of the RWH Travel Ltd of companies and/or selected third parties including:

• business partners, holiday service suppliers and sub-contractors for the performance of any contract we enter into with them or you or for the provision of services that we agree to provide to you;

• your travel agent;

• If we exchange email with you our email system is provided by Microsoft Corporation in the European Union and Minecast Services Limited in the United Kingdom on behalf of RWH Travel Ltd.

• Our “Travelink” booking and reservation system and CRM platform is provided by Inspiretec in the United Kingdom. You can view their GDPR Statement on their website.

• We use the Amadeus Global Distribution System and your Personal Data will be processed by the Amadeus IT Group, SA in the European Union to make air, rail and other travel bookings. You can view the Amadeus Data Privacy Policy on their website.

• If we send you information about RWH Travel products and services, your details are transferred to Dotmailer Ltd in the European Union. We use Dotmailer Ltd as an email service provider and marketing automation platform. Data is proccessed in accordance with their Privacy Policy. As outlined in the privacy policy, Dotmailer Ltd also use third party service providers and data processors, a list of which can be found on their Trust Centre

• Our websites use Google Analytics, a web analysis service operated by Google Inc. (Google) in the USA, which makes use of cookies to analyse how our websites are being used.

• Our “Feefo” online review platform is provided by Feefo Holdings Ltd in the United Kingdom. You can view the Feefo Privacy Policy on their website.

• If you choose to pay for a holiday service online or by telephone, your details are processed by Secure Trading Ltd at locations in the United Kingdom or outside the European Economic Area. You can view the Secure Trading Privacy Policy on their website.

• If you choose to pay for holiday services via “PayPal” your details are processed by PayPal (Europe) S.à r.l. et Cie, S.C.A. at locations inside and outside the European Economic Area. You can view the PayPal Privacy Policy on their website.

• If you travel on a Cruise & Walk holiday your details are processed by Fred.Olsen Cruise Lines (FOCL). You can view FOCL’s Privacy Notices on their website.

• Analytics and search engine providers that assist us in the improvement and optimisation of our site;

• If RWH Travel Ltd or substantially all of its assets is acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.

• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our terms of use or terms and conditions of supply and other agreements; or to protect the rights, property, or safety of RWH Travel Ltd, our customers, or others.

Sharing your personal data with regulatory authorities

So that you can travel, it may be mandatory (as required by government authorities at the point(s) of departure and/or destination) to disclose and process your personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate.

Some countries will only permit travel if you provide your advance passenger information (API). These requirements may differ depending on your destination and you are advised to check. Even if not mandatory, we may assist where appropriate.

We may share the minimum personal data necessary with other public authorities if the law says we must, or we are legally allowed to do so.

6 The basis on which we might use your personal data

We can only use your personal data if we have a proper reason for doing so. We will only use your personal data where one or more of the following apply:

• You have given your consent to the use (which you can withdraw at any time by notifying us), or

• It is necessary:
  (a) for the performance of a contract between us, or
  (b) for the taking of steps at your request with a view to entering into a contract, or

• It is necessary for compliance with a legal obligation that we must comply with, or

• It is necessary in order to protect your interests.

• It is necessary for us to pursue our legitimate interests such a marketing our services in the appropriate circumstances, for example, where you have used our services and have not objected to receiving information about further services of a similar nature. Even so, we will not unfairly put our legitimate interests above what is best for you.

7 How long will we hold your personal data for?

We will keep your data only for as long as it is necessary for the particular purpose or purposes for which we hold it unless there are any legal or operational reasons to hold it for a longer period. At the end of that period the data that we hold will be securely destroyed.

8 Protecting your personal data

We understand how important it is to protect and manage your personal data. We take appropriate security measures to help protect your personal data from accidental loss and from unauthorised access, use, alteration and disclosure.

The security of your personal data also depends on you. For example, where we have given you or where you have chosen a password for access to certain services, you are responsible for keeping this password confidential.

9 Your rights in respect of the personal data we hold about you

You can ask to see a copy of the information that we hold about you and for corrections to be made to any incorrect information. We want to be as helpful as possible and, in most cases will provide the information within one month of your request.

We do not have to provide information in all cases including where it would involve disclosing information about another person or where a request is excessive or manifestly unfounded. We may make a charge for providing the information in some cases.

You have the right to receive the data concerning you in a structured, commonly used and machine readable format and you have the right to transmit those data to another controller.

You can also ask us for following information:

• the purposes of the processing;

• the categories of personal data concerned;

• the recipients or categories of recipient to whom the personal data have been or will be disclosed;

• where it is possible for us to provide the information, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

• where we have not collected the data from you, any available information as to their source.

You can ask us to erase any data that we hold about you where one of the following grounds applies:

• the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

• you withdraw your consent to the processing and there is no other legal ground for the processing;

• you object to processing on grounds relating to your particular situation and our legitimate grounds for processing do not override your interests;

• you object to processing for direct marketing purposes;

• the personal data have been unlawfully processed;

• the personal data have to be erased for compliance with a legal obligation in European Union or Member State law to which we are subject.

We are not required to erase your data where we need to process your data:

• for exercising the right of freedom of expression and information;

• for compliance with a legal obligation which requires processing by European Union or Member State law to which we are subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

• for reasons of public interest in the area of public health;

• for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes so far as the erasure of data is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

• for the establishment, exercise or defence of legal claims.

You can ask us to restrict our processing of your data where one of the following applies:

• you contest the accuracy of the personal data we hold about you for a period enabling us to verify the accuracy of the personal data;

• the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;

• we no longer need the personal data for the purposes of the processing, but the data are required by you for the establishment, exercise or defence of legal claims;

• you object to processing on grounds relating to your particular situation pending the verification of whether our legitimate grounds for processing override your interests.

10 Where we store your personal data

We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this privacy notice.

The data that we collect from you may be transferred to and stored at a destination outside the European Economic Area ("EEA"). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your holiday contract and the provision of support services.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data and have contractual processes in place with our business partners to do this, we cannot guarantee the security of your data transmitted to our site.

Once we have received your information, we will use relevant procedures and security features to try to prevent unauthorised access, unlawful use, accidental loss, corruption or destruction. All such information is held on secure servers.

In order to process your holiday payment and comply with Payment Card Industry Data Security Standards (PCI DSS), reputable third-party banking institutions handle our debit and credit card transactions. They receive the information needed to verify and authorise your payment card transactions and holiday payments. All such organisations are under strict obligation to keep your personal information private.

11 Links from our website

Our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

12 Implementation of the Privacy Notice

RWH Travel Ltd staff , including our tour leaders, are aware of and have been instructed to comply with this privacy notice and other company policies relating to data privacy regulations.

13 Advice and assistance

Please do let us know if your details change so that we can continue to stay in touch. If you have any concerns about the content of this Privacy Notice or any personal information RWH Travel Ltd holds about you please get in touch.

Any questions, comments and requests regarding this privacy notice are welcomed and should be addressed to Data Protection, RWH Travel Ltd, Lemsford Mill, Lemsford Village, Welwyn Garden City, Hertfordshire, AL8 7TR or you can send an email to us at dataprotection@rambleworldwide.co.uk.

If you think that there is a problem with the way that we are handling your data or you are not happy with our response to your concerns, you have the right to complain to the Information Commissioner’s Office. You can contact their helpline on 0303 123 1113, use the live chat service available through the Information Commissioner’s website www.ico.org.uk, or visit https://ico.org.uk/concerns/.

14 Changes to this privacy notice

We keep our privacy notice under regular review. As the content of this privacy notice may change from time to time due to developments in the law and changes to our company policy, we would encourage you to periodically reread it from time to time so that you are aware of any changes in how we gather and use your personal information.

This privacy notice was last updated on 17 November 2023 and supersedes all previous versions.