Privacy Policy & Personal Data

Privacy Policy Last updated: 25 May 2022

 

This policy explains when and why we collect Personal Data about the people who visit our website or other platforms such as, mobile applications, email, text messages and social media accounts (“Platforms”), how we use such data, the conditions under which we may disclose it to others and how we keep it secure.

We may change this policy from time to time so do check this page occasionally to ensure that you are happy with any changes. We will notify you of any material changes on how we use your Personal Data prior to implementing them. Notification of any such material change will be made by email or prominent notice on our website. By using our Platforms, you’re agreeing to be bound by this Policy.

This Policy is produced in accordance with applicable data protection laws including European General Data Protection Regulation (EU 2016/679) (“GDPR”).

This Policy is provided in a layered format so you can click through to the specific areas set out below.

 

Who we are

We are Unum Magnum Feriatum Ltd. (Top10Travelagents.com , or We or us), a company registered in England and Wales (company number 12029425), whose registered office is at 53 14 Apple Grove, 53 Jupoiter House, Harrow, HA2 0FE. We are committed to protecting and respecting your privacy.

The Company is a data controller of your Personal Data collected via the Platforms.

Contact Us

If you would like any more information or you have any enquiries about our Policy or our processing of your Personal Data, please either write to us at Data Protection Officer, Unum Magnum Feriatum Ltd., 14 Apple Grove, 53 Jupiter House, Harrow, HA2 0FE, or email us at data.protection@top10travelagents.com

 

Rights to withdraw consent

When you first give us Personal Data through our website, we will ask for your consent to contact you about our services, and those of our partners who provide services featured or included on our Website (“Partners”).

Where we rely on your consent to process your Personal Data for a particular purpose, your Personal Data will not be proccessed for that purpose without your consent.

You can withdraw consent at any time for us to process your Personal Data to direct market to you by; (i) clicking UNSUBSCRIBE or other opt-out urls on any marketing email you receive from us (ii) clicking the unsubscribe link. https://top10travelagents.com/emailnewsletter/unsubscribe

 

What personal data we collect

When you use or visit the Top10TravelAgents.com website, we collect information from you, some of which may be regarded as Personal Data. This information includes:

  • Profile Data includes your username and password, your interests, preferences, feedback and survey responses, support requests and responses, and (if you choose to register or login to our Platforms using your email address) your email address and password. 
  • Time Spent (Usage Data) includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your holiday preferences.
  • Identity Data includes unique username and partial post code.
  • Contact Data includes email address and telephone numbers.
  • Technical Data includes IP address, your login data, access times, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, settings and platform and other technology on the devices you use to access this website screen resolution, referring URL.
  • Mobile Technical Data If you are using a mobile device, data that identifies your device, your settings and your location.

 

When allowing us to collect your Personal Data, we take the given information as true, accurate, complete and current. You are also telling us that you have the authorisation to provide this information to us.

If you choose to register or login to our Platforms using your email address, we may collect your email address and password. If you choose a third-party service, like Facebook login, to register or login to our Platforms, you are permitting us to use and store the profile information related to your social media account.

 

How is your Personal Data collected

Ways your Personal Data is collected:

  • Direct – Example: when you provide us with your Personal Data when you register with or use our Platforms or use our online chat products or other services or when you otherwise interact with us.
  • Inactively – For example, collected Technical Data and information about you over time when you visit our website. Automated technologies and tracking tools like cookies, analytical tools and beacons are in use throughout the website. Please see our cookie policy below for details.
  • Third Party Collection – This can include when you log in using a third-party platform, such as Facebook, analytics providers such as Google, advertising networks such as DoubleClick. 

 

Website features may make use of your device attributes and settings that will allow us to determine your approximate location. Such technologies may include IP address mapping, WiFi, GPS signals, cell tower positioning or other technologies.

 

Who we share your data with

How long we retain your data

Your Personal Data will only be kept for the purposes outlined in this Policy and when these purposes have expired, or are no longer relevant, or you have withdrawn your consent for the use your Personal Data (and we have no other lawful basis to use such data), we will delete such Personal Data. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether achievement of those purposes through other means, and the applicable legal requirements is possible. In the meantime, we will continue to use your Personal Data to contact you in the manner set out in this Privacy Policy or otherwise for the purposes set out in this Privacy Policy. If you have any questions regarding data retention periods please contact us at data.protection@top10travelagents.com

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

IF PERSONAL DATA IS NOT PROVIDED

Where the need to collect personal data required by law or required to provide a service that has been requested, failure to provide that personal data when requested, will lead to us Not being able to provide with the services requested.

 

How we protect and store your Personal Data

Our website servers and data centres are located in the UK and European Union (EU). However, we may need to transfer your Personal Data to staff operating outside the European Economic Area (EEA) who work for us or for one of our Partners. Such staff may be engaged in, among other things, the fulfilment of orders, the processing of payment details and the provision of support services. These countries may have different and/or less stringent privacy/data protection and data security rules than those of the UK and EU. We will take all steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

If we need to transfer your Personal Data outside the EEA to a third party (for example, one of our Top Travel Agents) or to one of our group companies, we will satisfy at least one of the following conditions:

  • use specific contracts (between us and the recipient organisation) approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; or
  • obtain your explicit consent to the transfer prior to the transfer after making you aware of the risks involved in such transfers;
  • only transfer if necessary pursuant to a contract between the data controller and you (or pre-contractual measures at your request);

 

If your Personal Data needs to be transfered outside the EEA to another of our group companies or partners, we may, as an alternative to the above three conditions, use Binding Corporate rules. For further details, see European Commission: Binding corporate rules.

Under our control, is a security program designed to keep the Personal Data stored in our systems protected from unauthorised access and misuse. Personal Data may only be accessed by persons within our organisation or Partners to carry out the uses indicated in this Privacy Policy.

As you are aware, transmission of information via the internet is not completely secure at all times. Although we put tremendous effort to protect your Personal Data, we cannot guarantee the security of your data transmitted to our website and other Platforms via the internet; any transmission is at your own risk. Once we have received your Personal Data, we will use strict procedures and security features to try to prevent unauthorised access.

Internet Communication*

Please note that communications over the internet, such as emails and webmails (messages sent through a website), are not secure unless encrypted. Your communications may go through a number of countries before they are delivered – this is how the Internet is designed to work. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control. You are encouraged not to include any sensitive or Special Category data in your communications with out website.

 

What rights you have over your Personal Data

Subject Access Requests

You are entitled at any time to obtain information about all your Personal Data that we hold about you, in accordance with the Act. Our Data Officer may request proof of your identity before providing this information and may not be able to allow you to access certain Personal Data in some cases. Example: your Personal Data is connected with Personal Data of other person/s, or for legal reasons. In such cases we will provide you with an explanation why you cannot obtain this information.

If you would like access to the Personal Data that we hold about you, you can do this by emailing us at data.protection@top10travelagents.com (or writing to us at our address stated)

No fee usually required
We will not charge you to pay a fee to access your personal information (or to exercise any of your other data subject rights explained on the Privacy Policy page). In extreme cases, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, our Data Protection Officer may refuse to comply with the request in such circumstances.

Updating your Personal Data

We control the processing of Personal Data on our Platforms with the aim of keeping the Personal Data we hold about you accurate and up to date. If you inform us that we are holding any inaccurate Personal Data about you, we will subject to any statutory provisions (especially those affecting our accounting, processing of claims and mandatory data retention which may prohibit deletion or anonymization), delete it or promptly correct it.

Please email us at data.protection@top10travelagents.com or write to us at our address to correct or update your Personal Data.

Your other rights under General Data Protection Regulation (EU GDPR)

Implementation date: 25 May 2018

Your other rights under GDPR:

  • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing.
  • Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
  • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
  • Request the transfer of your Personal Data to another party.

 

If you would like to request erasure of your Personal Data, object to the processing of your personal data, or request that we transfer a copy of your Personal Data to another party, please contact the Data Protection Officer at f you want to request erasure of your Personal Data, object to the processing of your personal data, or request that we transfer a copy of your Personal Data to another party, please contact the Data Protection Officer at data.protection@top10travelagents.com

Further information on these rights and GDPR can be found at https://ico.org.uk

Right to complain: You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance and we would be happy to help.

 

Information that will be requested

In the interest of your security and the security of the data thet we store and keep. We will need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is a strict security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

 

Response Time

We aim to respond to all legitimate data subject requests within a 30 day period. Occasionally it may take us longer time than the month stated, this is due to some requests being particulary complex to deal with or there are number of requests. In those cases you will be notified and you will be kept updated with the proccess progression.

 

Cookies

This website uses cookies on to provide you with a better user experience. We track how you use the Site, to keep you logged into the Site where applicable, to display relevant content and advertising. When our cookie is saved on your electronic device it is stored there for a period of up to 12 months, at which point it deleted from the electronic device.

Cookies are used for the following purposes:

  1. Website Service – help us work more efficiently by remembering user settings
  2. Analytics – anonymously track website traffic and browsing patterns
  3. Advertising – used to tailor advertising on the website, build an audience profile and to measure how many times adverts have been viewed or interacted with.

 

We also use third party cookies from the following partners:

  • Facebook – we use Analytics and Advertising
  • Google (Analytics, Adsense, Search Console, Ad Words)

 

Some third party cookies will be saved for specific time periods, while others may last indefinitely. Your web browser should provide you with the controls to manage and delete cookies from your device. Please see your web browser options.

For further information visit www.aboutcookies.org;   www.allaboutcookies.org;   www.google.com/policies/technologies/cookies/

By using the top10travelagents.com website, you agree that we can place these types of cookies on your access device.

 

Third party tracking & affiliate marketing links

This website contains advertising and affiliate marketing links. These are typically served through our marketing partners who track impressions, clicks and transactions, usually by using cookies, on behalf of their advertiser clients and affiliate partners.

By accepting our Privacy Policy you consent to the use of third party tracking (including cookies) from our marketing partners. Here is the current list of partners we engage with:

  • affilinet GmbH
  • AWIN Ltd.
  • Amazon Affiliates
  • CJ Affiliate by Conversant Europe Ltd.
  • Effiliation
  • IBG Ltd. t/a Affiliate Future
  • Impact Radius, Inc.
  • Ingenious Technologies AG
  • Kwanko SA.
  • Omnicom Group, Inc.
  • Paid On Results Ltd.
  • Pepperjam, LLC
  • Performance Horizon Group Ltd.
  • Rakuten Marketing LLC
  • Silvertap
  • The Affiliate Gateway (TAG)
  • Tradedoubler AB
  • Tradetracker UK
  • Webgains Ltd.

 

What are Affiliate Links?

Clicking on affiliate marketing links or ads will track your actions by using a cookie saved to the device used to visit this website. Your actions are usually recorded as a referral from our website by this cookie. In most but not all cases we earn a commission from the advertiser or advertising partner, at no cost to you, when you make a purchase on the affiliated website.

The use marketing partners in this way is to help us generate an income from the website, which in turn will allows us to continue our work and provide you with the best overall experience and valued information for free.

Articles or Content on this website may also include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.