Holi-Swap Limited (we) are committed to protecting and respecting your privacy. We want you to be fully informed about your rights, how we use, store and keep your data safe.
This policy explains in detail the types of personal data we may collect about you when you interact with us, our data processing practices and your options regarding the ways in which your personal data is used. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
2. What Personal Information Do We Collect?
Information that you provide by registering, using our services or otherwise filling in any forms by hardcopy, on our website or any other form of media you use to communicate with us. This includes information provided at the time of registering, purchasing products, subscribing to our services including receiving promotional material and news and information posted on our site, posting material or requesting further services.
The details of your visits to our site including, but not limited to, traffic data, location data, purchase information, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
Details of transactions you carry out and the fulfilment of your orders, including, but not limited to your name, address, email address, telephone number and credit card number.
If you contact us, we may keep a record of that correspondence.
If you provide personal information to us about other individuals (including medical or financial information) you should inform the individual about the contents of this Privacy Notice. We will process such information in accordance with this Privacy Notice.
Your personal record is kept confidential within the Company at all times and is only shared with staff when they need it to carry out their job. All staff are required to work to strict professional and contractual codes of confidentiality.
3. How We Collect Data
Information may be collected directly from you when:
• You enter in to a contract with us by purchasing APP product
• You register as a Holi-Swap customer
• You complete enquiry forms on the Holi-Swap website
• You submit a query to us including through our website, by email or by social media
• you correspond with us by letter, email, telephone (all incoming and outgoing calls from/to patients are recorded) or social media, including where you reference Holi-Swap in a public social media post
• You submit your survey & feedback responses to us
• You take part in our marketing activities
4. How We Use the Personal Information We Collect
Holi-Swap will use your personal information for the purpose of:
• Order fulfilment where you have entered in to a contract for the provision of travel products or holiday services
• Monitoring quality and performance of the products and service provided by Holi-Swap
• Correspondence for advertising and marketing our own business, activity, goods, services or events
• Promoting public relations in connection with that business, activity, goods, services or events.
• Analysis of website efficiency, visits and history.
In order to communicate with you about products and services you have engaged with us about and patient surveys and feedback, we are likely to do this by telephone, SMS, email, and/or post. Patient surveys and feedback are for the purpose of improving our products and services and for the purpose of monitoring health outcomes and are not a form of marketing.
As detailed above, we may contact you to ask you to participate in surveys regarding your travel plans with Holi-Swap. The surveys will largely be sent post-treatment by email or post. This is not a form of marketing and the surveys do not try to sell you any further products or services; it is solely to gather information relating to your experience with Holi-Swap, for the purposes of improving the quality and safety of the services we offer to future travellers. It is necessary for us to process your personal data in order to contact you with these surveys, on the basis of our appropriate business needs and to improve the quality of the holiday and leisure services we offer.
We may also contact you to invite you to participate in on-line surveys which aim to monitor the outcomes of your holiday. Again, these surveys are not a form of marketing. If you choose to complete a survey you will also receive subsequent surveys following your holiday to help establish the benefit you have gained from Holi-Swap.
Cookies – Information placed automatically on your computer
When viewing our websites, some information may be stored on your computer. This information will be in the form of a “cookie” or similar file and can help us improve your experience. With most Internet browsers, functions are available to erase cookies from the computer’s hard drive, block all cookies or receive a warning before a cookie is stored.
You are advised to refer to your internet browser instructions or help screen to learn more about these functions.
Your access to the website indicates your consent to our use of information gathered from cookies for these purposes.
5. Sharing Personal Information
From time to time, we may share your personal information within our group or with third parties.
Disclosures to third parties:
We may disclose your information to the third parties listed below for the purposes described in this Privacy Notice.
This might include:
• Hotel Groups, Travel and Tourism partners, Transport companies.
6. What marketing activities do we carry out?
We may also use your personal information to provide you with information about products or services which may be of interest to you where you have provided your consent for us to do so.
If you no longer wish to receive marketing emails sent by us, you can click on the “unsubscribe” link that appears in all of our emails, otherwise you can always contact us at [email protected]
7. Your Rights
Under data protection law you have certain rights in relation to the personal information that we hold about you. These include rights to know what information we hold about you and how it is used. You may exercise these rights at any time by contacting [email protected]
If we cannot comply with your request to exercise your rights, we will usually tell you why.
If you make a large number of requests or it is clear that it is not reasonable for us to comply with a request, then we do not have to respond. Alternatively, we can charge for responding.
If at any point you believe the information we process on you is incorrect and you want it corrected, you request to see this information, you request the data to be transferred, you object to our processing your Personal Information, or you request to have it deleted.
If you are unhappy with the way that we have dealt with a request from you to exercise any of these rights, or if you think we have not complied with our legal obligations. You have the right to complain to the Information Commissioner’s Office. Making a complaint will not affect any other legal rights or remedies that you have.
More information can be found on the Information Commissioner’s Office website: https://ico.org.uk/
8. Security of Collected Information
We are committed to protecting the security of the personal information collected, and we take reasonable physical, electronic, and administrative safeguards to help protect the information from unauthorised or inappropriate access or use.
22 June 2018.