Trafalgar Tours Limited

Privacy Policy

Last updated: 23 June, 2015

Contents

Please click on a link below to jump to a specific paragraph:-

1. About This Document
2. Your Consent
3. Copyright Notice
4. About Us
5. Contacting Us
6. Our Commitment
7. Who Our Privacy Policy Covers
8. What Laws We Comply With
9. What Types Of Personal Data We Process
10. How We Collect Or Generate Your Personal Data
11. What Do We Use Your Personal Data For?
12. Use Of Your Personal Data For Direct Marketing
13. Disclosure Of Your Personal Data
14. How Third Parties Will Handle Your Personal Data
15. Location Of Your Personal Data
16. Keeping Your Data Secure
17. How Long Do We Keep Your Personal Data For?
18. Your Rights
19. Changes To This Privacy Policy 

1.           About this document

This document sets out our privacy policy in respect of customer personal data, which will govern the way in which we process any personal data that you provide us with.  It serves as an expression of our commitment to protecting your private personal information, but is not a contract.  Please see Section 18 below for the rights which the law provides you with in relation to your personal data.

2.           Your consent

By using our websites or apps, providing any personal data to us, or booking any travel services with us, that you confirm that you agree to and consent to the terms of this document, to the extent that your consent is required by any applicable law.

3.           Copyright notice

This document is Copyright © 2015, Trafalgar Tours Limited. All Rights Reserved.

4.           About us

This is the privacy policy of Trafalgar Tours Limited (referred to as "we", "us" or "our").  We are incorporated under the laws of the Bailiwick of Guernsey. Our incorporation number is 50679 and our incorporation address or registered office is Travel House, Rue du Manoir, St Peter Port, Guernsey, Channel Islands, GY1 2JH.

5.           Contacting us

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail to enquiries@trafalgartours.com, or by post to Trafalgar Tours Limited, Travel House, Rue du Manoir, St Peter Port, Guernsey, Channel Islands, GY1 2JH.

6.           Our commitment

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data that you entrust to us.

7.           Who our privacy policy covers

7.1         Our customers

Our privacy policy sets out how we process personal data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5)  who upload, post or send anything to or through our  websites or apps, or who receive messages through our websites or apps, using any community functionality.

7.2         Examples of who this policy covers

We include in this privacy policy personal data we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes). 

7.3         When we are data processor only

Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account.  In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data.

7.4         Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal data we process from time to time.

When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of use appear: https://www.trafalgar.com/uk . References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites. 

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and in particular includes the following app: myTrafalgar, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages,  including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

8.           What laws we comply with

We process your personal data in accordance with the following data protection laws:

The Data Protection (Bailiwick of Guernsey) Law, 2001, and the European Communities (Implementation of Privacy and Electronic Communications) (Guernsey) Ordinance, 2004;

The United Kingdom Data Protection Act 1998 (which covers protection of personal data generally) and The Privacy and Electronic Communications (EC Directive) Regulations 2003 of England and Wales (which covers, among other things, the use of telephone numbers, fax numbers and e-mail addresses for unsolicited direct marketing).

Our regulators are:

Guernsey: The Office of the Data Protection Commissioner, https://dataci.gg/;

United Kingdom: The UK Information Commissioner, https://www.ico.org.uk/.

We also comply generally with the law of the Bailiwick of Guernsey, and the law of England and Wales in relation to the processing of your personal data, and not any other laws.

9.           What types of personal data we process

This section summarizes the types of personal data about you that we process:-

9.1         Data concerning you as an individual

This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

9.2         Business Related Information

If you are an individual associated with a business or other organisation that is our customer,  then your personal data may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

9.3         Enquiry and Booking information

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

9.4         Performance information

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

9.5         Survey Information

Information collected or generated out of any surveys we conduct.

9.6         Competition Information

Information collected or generated out of any competitions or promotions we run.

9.7         Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program, including your profile and settings information.

9.8         Correspondence

Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

9.9         Technical Information about your computer

We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux, etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

9.10      Website and App usage information

We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

9.11      Community Data

Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

10.       How we collect or generate your personal data

This section sets out the ways in which we may collect or generate personal data concerning you.

10.1      Automatic capture

By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and and retrieve information previously stored. This includes:  information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps. 

10.2      Data you provide

Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time.  This includes any data you provide when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

10.3      Data obtained from third parties

We may obtain personal data concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us; and posts and  messages sent to you or addressed to you by other customers of ours using any community functionality.

10.4      Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal data or data gained from your use of our websites and apps. We may record telephone calls with you.

11.       [j1] What do we use your personal data for?

This section sets out the uses which we make of your personal data:

11.1      Operate our websites, apps and services

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality.  This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, and making changes to your settings and profile at your request.

11.2      Provide information and respond to enquiries

To provide information to you about our websites, apps, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

11.3      Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings,  orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

11.4      Payments

To collect and make payments due and administer our accounts.

11.5      Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, community functionality, problems and complaints, and to respond to any submissions, enquiries or requests from you.

11.6      Record Keeping

To keep internal records and maintain reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints, and including for the purposes of disputes, legal proceedings and investigations.

11.7      Promotion, management and Improvement of our business

To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. We may also use this information to ascertain interests so that we can better tailor our business offerings. 

11.8      Direct marketing

To carry out direct marketing to you.  See next section below for further information.

11.9      Advertising

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

11.10   Anything you have specifically consented to

For any purpose which we have obtained your consent to.  For instance, we may have asked your consent, with respect to any community functionality, to apply hashtags to your Twitter updates sent through our community functionality, to disclose your email address to other persons on the same tours as you, and to let other customers of ours send you messages through our community functionality.

11.11   Maintenance of our website and apps

We may use your personal data to maintain and update our websites and apps.   For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

12.       Use of your personal data for direct marketing

We do not use or disclose your personal data for direct marketing purposes unless we have obtained your consent to this, such as through an opt-in or opt-out tick box on any form or websites of ours.

12.1      Direct marketing by us

Where you have consented to this, we may use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.  Where you have consented to this, we may also use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us. You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive.  In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

12.2      Direct Marketing by Third Parties

Where you have consented to this, we may disclose your personal data which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us.  They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal data for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal data from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

13.       Disclosure of your personal data

We transfer your personal data to third parties in the following circumstances:-

13.1      Credit Checks etc.

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks).  This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

13.2      Bookings and performance of contracts

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you.  This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

13.3      Synchronizing within our group

If you have an account, registration, contract or other relationship with any other company in our group of companies (such as an affiliate, subsidiary, holding company, or subsidiary of a holding company, or joint venture company) and any of your personal data held by us or that other company is updated (whether, for example, by you, us, by such other company, or by a travel director or travel agent), then we and such other company may update your personal data accordingly, and disclose such updates to each other for the purposes of keeping our respective copies of your personal data consistent and up to date.

13.4      Suppliers of travel and other services

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

13.5      Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer.  Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

13.6      Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, apps, databases, systems, business, community functionality, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal data to them as required for use for or processing as part of those purposes.

13.7      Community functionality

Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, may be disclosed accordingly.  Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

13.8      Legal requirements

We may supply personal data to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract.  We may disclose your personal data where otherwise required by or permitted by law.  

13.9      Direct Marketing by third parties

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing.  See the direct marketing section above.

13.10   Customer Representatives

If our customer is a business or organisation, and we are holding your personal data in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal data.   If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

13.11   Business acquirers

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.

14.       How third parties will handle your personal data

Where we provide your personal data to a third party one of the following two circumstances will apply:-

14.1      Processing on our behalf

In some cases, your personal data may be held and otherwise processed by them on our behalf, in which case we will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy.

14.2      Processing on their own account

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for that personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

15.       Location of your personal data

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere in the world.  Where we disclose your personal data to third parties, that disclosure may also involve a transfer of your personal data anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world. In each case, we will comply with any legal requirements concerning the transfer of your personal data by us to any third party outside the country where we are established, and where your personal data is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

16.       Keeping your data secure

16.1      Our security measures

16.1.1      Our general commitment

We are committed to doing what we reasonably can to keep your personal data secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, your personal data. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

16.1.2      Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”. 

16.1.3      Storage of your personal data

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

16.2      Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information.  We also encourage you to be careful about who you give personal data to. We never contact you to ask you for sensitive personal data, such as payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our websites, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

17.       How long do we keep your personal data for?

We keep your personal data for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal data may be relevant to any possible liability we may have to you.

18.       Your Rights

Our privacy policy is not intended to create a contract or form part of any contract. You have certain non-contractual rights under the laws noted above, which we summarize below. If you contact us about these rights, we may ask for proof of your identity before we act, and may refuse to act if you do not provide this or your identity is not established by you.

18.1      Access to your personal data

You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold. We may charge a fee for handling your request, in an amount prescribed by law. This fee is £10 as at the date of this policy.  The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

18.2      Use causing substantial distress or damage

You have the right to ask us to stop using your personal data for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions. 

18.3      Use for direct marketing

You have the right to ask us to stop using your personal data to carry out direct marketing to you.

18.4      Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal data we hold about you.

18.5      Compensation

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

18.6      Complaints to applicable authority

The laws we comply with are regulated by:

Guernsey: The Office of the Data Protection Commissioner, Data Protection Office, Guernsey Information Centre, North Esplanade, St. Peter Port, Guernsey GY1 2LQ,  https://dataci.gg/

United Kingdom: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF, https://ico.org.uk/.

In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator, who has powers to compel us to comply with applicable laws and fine us for non-compliance.  However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.  

19.       Changes to this privacy policy

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our websites. You should check this privacy policy for updates each time you visit our websites to be sure that you are aware of any changes.  You should check the top of the document to see the latest version in force.  Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

End of Document


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