Privacy Statement The Tough Club (TTC)
We collect a considerable amount of data about you and this statement sets out how seriously we take your data privacy and security. We are compliant with The Data Protection Act 2018.
TTC understands and respects the importance of your privacy. We are committed to safeguarding your personal information and this statement outlines our commitment to you.
We will be transparent about the information we collect and what we will do with it.
We will use the information you give us only for the purposes described in our Privacy Statement.
We will use the information to help understand your needs and provide more relevant offers.
If you tell us to cease marketing messages, we will stop sending them (albeit we will continue to send important information relating to a product or service you have purchased to keep you informed about your booking and travel itinerary)
We will put in place measures to protect your information and keep it secure.
We will respect your data protection rights and aim to give you control over your own information.
Information we collect from you
We may collect information about you when you, or someone acting on your behalf, contact(s) us by phone, email, post or otherwise, and when you correspond(s) with us via our website and online forms. Please note that calls may be recorded for training and quality control purposes. Information that you provide us with can take many forms, including;
When booking holiday arrangements, we will ask you to provide information such as;
Your name, gender, date of birth, contact details (postal address, email address and telephone number) and marketing preferences;
Your preferred rooming arrangements and other special requests (which may include Special Categories of personal data, see below);
The name and telephone number of an emergency contact person (whom we will only contact in urgent circumstances while you are away)
Your travel insurance details;
Your passport details and other information directly required to provide your holiday arrangements;
When you call us or correspond with us about your booking, we may keep information on why you contacted us, and the advice we gave you;
When you make a payment to us, we will receive information from you including details of your bank account (this information is processed using a third party payment services provider and is not stored by us);
When you visit us at a public event, such as trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may ask for information, such as your name, contact details, interests and marketing preferences;
When you use our online services, we may receive content that you choose to upload such as reviews, comments, photos, forum posts or details of your interests and marketing preferences;
you may also provide us with written or photographic content for us to load on to our website, including reviews and articles.
We may also collect information from publicly available sources and third parties, including:
from a Travel Agent acting on your behalf in the sale of a travel arrangement to you, and sharing some information about your purchase with us;
Information about you from other Group companies that you interact with;
payment information from our payment services provider including debit/credit card numbers, bank account and other details in order to issue refunds;
Information relating to your use of any of our social network applications, pages or plugins.
Information we may collect when you use our website
Our websites provide us with information about your use, including:
details of the content that you view and interact with during a browsing session;
technical information such as, but not limited to, service, product or server logs, IP address, time and location, domain, device and application settings, errors and hardware activity etc;
interests and preferences that you specify during the curation of your holiday arrangements;
email/chat communications you have with us may be monitored and logged.
Aggregated information derived from your personal data
We collect, use and share aggregated data such as statistical and demographic data for analytical purposes. Whilst derived from your personal data, it is not considered personal data as this data does not directly or indirectly reveal your identity.
We may collect, use and share the following special categories of personal data about you only where it is strictly necessary in order to deliver the travel arrangements you have purchased (for example, to assist with visa applications or ensure appropriate food for those with serious/life threatening allergies)dietary requirements which may disclose health matters or your religious or philosophical beliefs; health, including information about any disability or medical condition which may affect the chosen holiday arrangements.
If you fail to provide personal information
Should you fail to provide data required either by law, or necessary to provide your chosen travel arrangements, we will not be able to provide the services you have booked or are attempting to book. This may result in TTC being unable to process your booking and be forced to cancel the booking. In this case, we will treat this as a ‘cancellation by you’ in accordance with the relevant Booking Terms & Conditions and notify you accordingly.
How TTC uses the information that it collects
This section explains how we may use the information we collect for a wide range of purposes.
We may use the information we collect to ensure we give you the best possible customer experience and ensure the appropriate performance of the contract, including;
To share your data with third party service providers used in the delivery of your purchased holiday arrangements. These providers will be named on your holiday confirmation and/or in your holiday documentation, and include; accommodation and transport providers;
local ground partners and agents, where we use them; guides, tutors and local attractions where booked on your behalf; equipment hire operations.
to provide you with information on our products and services, and also to deal with your requests and enquiries regarding holiday arrangements;
to contact you if we need more information or if there are changes to your travel arrangements;
provide customer care and other after sales services; for staff training and quality assurance purposes;
ask for your opinions on our products and services (via ourselves or through a third party agent);
consider employing you if you send us your details in response to our recruitment advertising or if you approach us with a speculative employment enquiry.
We may use your information to provide you with brochures, newsletters and other communications if you have provided your prior consent or we are permitted under an identified and assessed legitimate interest.
Personalised and targeted content, recommendations and advertisements
We may use the information we collect to personalise and more effectively target our services, content, recommendations, adverts and communications. For example, you may see an advertisement for a holiday that you have recently viewed on one of our websites when browsing at a later stage.
We may use your information to create anonymous, aggregated statistics about the use of our websites, products, services and loyalty programs, which we may share with third parties and/or make available to the public.
We may use your information to develop and improve new and existing products and services, recommendations, advertisements and other communications and learn more about our customers’ holiday preferences in general. Publish your reviews, comments and content
Where you upload or provide us with product reviews, comments or content to our websites that are publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.
Sharing information about you
We will not use information about you in ways that are not explained in this Privacy Statement. We may share information about you in the following circumstances:
Legal and business purposes
To disclose to organisations who act as data processors and perform business functions on our behalf. Such business functions include marketing analysis and assessment of customer preferences, payment processing, email newsletter delivery and brochure delivery services.
To share your data with third party service providers used in the delivery of your purchased holiday arrangements;
To government bodies and law enforcement agencies to prevent fraud, to comply with the law and to meet a reasonable request from such bodies.
to third parties (including professional advisors) to enforce or defend the legal rights of TTC or the terms and conditions of any TTC product or service.
Sharing of information by you
Some of our online services allow you to upload and share messages, reviews, photos, video and other content and links with others. We will obtain consent if we publish this information on our websites, marketing collateral or social media profiles.
You should not expect any information that you make publicly available to others via our online services to be kept private or confidential and you should always exercise discretion when using such services.
When you communicate with us, we may give you the opportunity to subscribe to our email newsletter. Once subscribed, you can choose to unsubscribe at any time:
to unsubscribe from an email sent to you, follow the instructions placed (typically) at the bottom of the email;
This method will only unsubscribe specifically for the e-newsletter or other communication received. Should you receive other marketing such as brochure mailings, you will need to opt-out separately by contacting us to change your marketing preferences.
You can contact us using the details on the “Contact us” Page in order to change your marketing preferences at any time.
Please note that despite opting out of marketing communications, you will still receive service communications where necessary, for example, to confirm your booking or to provide you with an update on its status.
Our legal rationale as to why we may collect and process your personal data, which could alternate between contractual obligations, legitimate interest, legal compliance or consent depending on the nature of its use.
We will only process your personal information where we have a legal basis to do so. The legal basis will depend on the reason or reasons we collected and need to use your information. Under EU and UK data protection laws in almost all cases the legal basis will be:
because we need to use your information to process your booking, fulfil your travel arrangements and otherwise perform the contract we have with you;
because there is a legitimate interest to use your personal information to operate and improve our business as a travel experience, activity provider (a legitimate interest assessment is performed prior to making this determination);
because we need to use your personal information to comply with a legal obligation;
because you have consented to us using your information.
How long do we keep personal information?
We will keep your personal information for only as long as needed to fulfil the purposes described in this statement. For example, where you book a holiday with us, we will keep the information related to your booking, so we can fulfil the specific travel arrangements you have made and after that, we will keep the information for a period which enables us to handle or respond to any complaints, queries or concerns relating to the booking and to fulfil our obligations to our third party suppliers who provided your holiday arrangements. The information may also be retained so that we can continue to improve your experience with us while you continue to engage with and purchase from us and to ensure that you receive any loyalty rewards that you may be eligible for.
We will actively review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal requirement, business need or customer interest for it to be retained.
By law we have to keep basic information about our customers for legal and tax purposes (including identity, contact, financial and transaction data) for up to 7 years after they cease being customers.
Security of your information
This section lists the steps we take to protect your personal information and keep it secure.
We take a number of steps to protect your information from unauthorised access, use or alteration and unlawful destruction, including where appropriate:
we are PCI compliant when processing your payments;
we put in place physical, electronic, and procedural safeguards in line with industry standards to limit access to the information we collect about you;
we monitor our system for possible vulnerabilities and attacks to identify ways to further strengthen our security.
Cookies and web beacons
Access to your information and your rights
This explains how you can access your personal information and outlines your rights, for example requesting corrections and asking us to exclude you from direct marketing.
For a copy of the personal information that we store about you in our customer databases, please contact us using the details given in the “Contact us” page. You will be asked to provide some proof of identification so that we can verify that it is you making the request.
Links to other sites
Explains that our websites may occasionally contain links to or from third-party websites and that this privacy statement and our responsibility does not extend to these other websites.
Our website may contain links to other websites that are not operated by TTC. While we try to link to sites that share our high standards and respect for privacy, we are not responsible for the content, security or privacy practices of those websites. You should view the privacy and cookie policies displayed on those websites to find out how your personal information may be used.
Information about you and members of your party, including your names, contact details and any special needs, disabilities or dietary requirements is collected by us when you request information or make a booking with us. We will ensure that all such data is stored securely and in accordance with UK data protection legislation. We may disclose this information to our service providers (who may be located outside the UK/EEA) for the purpose of providing you with your arrangements. Only information necessary for this purpose will be disclosed to them. Where email addresses have been provided for your group, we will send them transactional communications, such as payment reminders and receipts. We will contact you, as group leader for the booking, with any necessary information relating to your booking, via email, phone and SMS.