About this policy

This document (our “privacy policy”) sets out information into how we use personal information relating to website users of The Real Word. It serves as an expression of our commitment to protecting their private personal information but is not a contract.  Please see Section ‘Your Rights’ below for the rights which the law provides you with in relation to your personal data.

Please note this privacy policy relates to content supplied by and readers of The Real Word only. If you are a customer or potential customer of Trafalgar Tours Pty Ltd, please review the privacy policy for your specific region at the following address:

Trafalgar UK:  Privacy

Trafalgar USA:  Privacy

Trafalgar Canada:  Privacy

Trafalgar Australia:  Privacy

Trafalgar New Zealand: Privacy

Trafalgar Europe:  Privacy

Trafalgar South Africa:  Privacy

Trafalgar Asia / Rest of the World: Privacy

Your consent

We will only use and retain your personal data with your consent or other lawful basis.  We ask for your consent on those occasions and in those places where we specify what we will use your personal data for.

Copyright Notice

This document and all content of our websites is Copyright© 2018 Trafalgar Tours Pty Ltd. ALL RIGHTS RESERVED.

About Us

This is the privacy policy of The Real Word, a website owned by Trafalgar Tours Pty Ltd (referred to as “we“, “us” or “our“).  We are a member of ABTA (Y181X) and licensed by the Civil Aviation Authority (10148).

Contacting us

If you have any questions about our website or these terms of use, including any complaints, please contact us by e-mail at trafalgarhelp@gmail.com

Our Commitment

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, when using our website and reading our content. 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. 

Who our privacy policy covers

Our Readers and Contributors

Our privacy policy sets out how we process personal data (including information) relating to individuals who are readers of our editorial platform, The Real Word, and who contribute articles, images and videos for publishing on The Real Word

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.

What types of personal data we process

Data concerning you as an individual

We may collect the following:

– 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,
– results of searches carried out against you (such as to verify your identity, address, and credit status),
– your preferences,
– any other information provided to us by or in relation to you which concern you as an individual.

Survey Information

Information collected or generated out of any surveys we conduct.

Competition Information

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

Account, Registration and Loyalty Information

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

Correspondence

Correspondence, communications, and messages, including between you and us, and between us and third parties.

Website Usage Information

We may collect information about your visits to, browsing of, and use of our website unless your web browser blocks this. The range of data we collect will depend on how you interact with our website. This information may include:  

– your IP address (a unique identifier allocated to your computer for your connection to the internet);
– your computer device details (PC, tablet, smartphone, watch, etc.);
– the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;
– your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux, etc);
– your time-zone;
– your browser plug-ins;
– any web-page you came from, identified as the referrer web page address by your web browser;
– cookies;
– page response times;
– download error;
– pages and parts of pages you visit;
– the usage you make of our website, including inquiries and searches undertaken, and registrations for accounts, forums, etc.;
– services and products you viewed;
– length of visit to website and pages;
– page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). 

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

This information may also include:
– data inputted into forms and fields;
– registrations for any accounts,
– forum,
– feedback mechanism,
– social functionality,
– newsletters or other features of our site;
– usernames and passwords,
– log-in / out history, and settings;
– actions are taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

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.

Visiting our website

By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. 

Data you provide

Your personal data will include data you provide (or later amend), whether: 

– from correspondence with you;
– verbally to us over the phone or in-person;
– by filing in any field or form on a website;
– by filling in any printed form we provide you with;
– by e-mail;
– from documents you provide us with; and
– from updates to any information you provide to us from time to time.  

This includes when you: 

– register or subscribe for any service, account, members, or loyalty program,
– make an inquiry or booking for a holiday with Trafalgar Tours Pty Ltd or other travel services whether in person, by phone, through our website or otherwise;
– send us your comments or suggestions;
– subscribe to any newsletter or other publication;
– request sales and advertising information, including brochures, from Trafalgar Tours Pty Ltd

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 inquiry, booking or complaint through Trafalgar Tour Pty Ltd; or
– in performing any booking or other contract with you through Trafalgar Tour Pty Ltd; or
– through the analysis of your personal data; or
– data gained from your use of our website.
We may record telephone calls with you.

What do we use your personal data for

This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.

Operate our website

To operate and provide the search function of our website, and to inform us of the type of content best suited for our audience 

Provide information and respond to inquiries

To provide information to you about our website, and to keep you updated generally.  This is done on the basis of our legitimate interests in ensuring our business is run efficiently.

Communication with customers

To communicate with you concerning any inquiries, problems, and complaints, and to respond to any submissions, inquiries or requests from you.  This is done on the basis of our legitimate interests in ensuring our business is run efficiently.

Record Keeping

To keep internal records and maintain reasonable archives, including concerning as to inquiries and complaints. This is done on the basis of our legitimate interests in ensuring our business to run efficiently.

Manage and Improve our business

To analyze, audit, provide, operate, administer, maintain and improve our business, website, and services; 

– to carry out surveys and analyze the results;
– to run promotions and competitions;
– undertake customer research/development;
– to assist us in and help us to improve our content
– editorial, advertising, and marketing processes;
– to carry out other business development and improvement activities; and
– to provide training for our staff, sub-contractors, and suppliers. 

For example, we may use your personal data to help us profile how our audience generally are using our website and engaging with our content. We may also use this information to ascertain interests so that we can better tailor our content offerings.  This is done on the basis of our legitimate interests in ensuring our business to run efficiently.

Direct marketing

To carry out direct marketing to you, see section ‘Use of your personal data for direct marketing” for further information.

Advertising

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

Anything you have specifically consented to

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis

Consequences of Not Providing your Data

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/content, we may not be able to offer some/all our services/content without it.

Period for retaining your data

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


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 unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

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 do this, such as through an opt-in box or a form on our website and/or
– you have made a booking with Trafalgar Tour Ptd Ltd and there is a legitimate interest to do is. 

In addition to data protection law, if we use your personal information for direct marketing purposes we may also be subject to additional rules that regulate direct marketing.  The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.

Direct marketing by us

We will use your personal data to send you marketing information (including newsletters) about our content, as well as travel services offered by Trafalgar Tours Pty Ltd. These travel services include:

  1. Products and services offered by Trafalgar Tours Pty Ltd
  2. Products and services which can be booked with third parties through us
  3. Products and services which can be booked with other companies within our group (i.e. the Travel Corporation Group); and
  4. Products and services offered by third parties and selected by us. 

Where applicable we will only send you marketing information about the content or services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email).  

Withdrawing from Direct Marketing 

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.” 


When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties. 


You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

Disclosure of your personal data

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

Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, 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. 

Public forums etc.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum) than any personal data you provide in relation to that forum or other facility, which is provided in a circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

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,
– where reasonably required to protect your vital interests or 

We may disclose your personal data where otherwise required by or permitted by law. 

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. This is to ensure that your data is protected and kept secure. 

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. 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. 

Rectification

You have the right to have your personal data amended if it is inaccurate or incomplete.

A right to object

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

Deletion of Data inaccuracies

You have the right to have your personal information deleted or removed in certain circumstances and we may have the right in some cases to refuse to do so.

Portability

 You have the right to obtain and re-use your personal information for your own use in certain circumstances.

Restrict Processing

You may prevent or suppress the processing of your personal information in certain circumstances.

Complaints to applicable authority

In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from this supervisory authority 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 complaints or concerns you have.  You can contact us using the details provided in the ‘Contacting Us’ section of this our privacy notice.

Right to withdraw your consent

You are free to withdraw your consent at any time. Please contact us using the details outlined in this policy.

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 website. You should check this privacy policy for updates each time you visit our website 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. 

Cookies

This website uses cookies. We use cookies to analyze our traffic, enhance our website’s functionality and performance, and a better experience for our users. If you require more information please view our cookie policy.


TTC Covid-19 processing activities specific Privacy Notice

23 July 2020

Trafalgar Covid-19 Privacy Notice

This Privacy Notice supplements our standard Privacy Notice and should be read in conjunction with that Notice.  This Privacy Notice gives specific details about how we will deal with personal information in light of Covid-19.

Due to the current public health situation, Trafalgar may temporarily collect additional information from customers, including health or biometric information. In some countries, such information is considered as “sensitive” or “special categories of personal data”.

Trafalgar will always treat the information we collect from customers, in particular health and biometric information, with the highest standards of care and in line with all applicable legal requirements and guidelines from public authorities. Trafalgar complies with the EU General Data Protection Regulation 2016/679 (GDPR), the UK Data Protection Act 2018 and all amendments, any other legislation relating to personal data and all other local or national legislation and regulatory requirements in force from time to time which apply to us relating to the use of your personal data.

The purpose of this specific privacy notice is to inform our customers of what personal data Trafalgar collects, for which purposes and under which legal grounds we may process it during the SARS-CoV-2 pandemic.

Who are we?

Trafalgar is a company registered in Trafalgar Tours Pty Ltd. All references to Trafalgar, ‘we’, ‘us’, ‘our’ are references to Trafalgar, its group, subsidiaries and sister companies. If you have any questions or concerns about this privacy notice, or Trafalgar’s personal data policies or practices, please contact us either by e-mail to trafalgarhelp@gmail.com.

We are the Data Controller for the purposes of the matters detailed in this Privacy Notice.

What personal data do we collect?

Depending on the situation, we may collect the following information:

  • Your name and contact details.
  • Where authorised by local regulations or where you agree, we may collect your temperature before giving you access to our services/premises or to a public area. On such occasions, we do not record this information, which is deleted immediately unless the readings are not within acceptable levels in which case we may refuse access and we may retain the data in order to demonstrate that our refusal of access was reasonable.
  • When you have accepted or where required by local regulations, we may collect your name, contact details, date, time and location of your presence in the premises we manage for contact tracing purposes. If you notify us that you have been tested positive, we will not record this information, but only the date, time and location of the risk in order for us be able to notify the relevant customers that may have been exposed unless otherwise required by law.
  • Your medical insurance information, as required by tourism and travel regulations.

Why do we collect personal data?

Depending on the situation, we collect and process your personal data for the

Following purposes:

  • To check body temperature prior to giving access to public areas and our premises, to protect the health and safety of our customers, staff, contractors and suppliers;
  • To record attendance in certain premises we manage, in order to notify our customers if they have been exposed to a risk and to recommend to self-isolate;
  • If you choose to share such information with us, to record if you have a particular risk to your health so we can take any additional measure appropriate to ensure your safety;
  • To record your medical insurance information as required by health regulations.

What are our legal grounds to collect and process your personal data?

We rely on the following legal bases to collect and process your personal data:

  • Your explicit consent.;
  • To perform the contract you have with us;
  • To comply with a legal obligation: when we are required to collect and process your information because we have a legal requirement to do so in some jurisdictions;
  • To protect your vital interest: when required by the circumstances, we may process your data to protect your vital interests or the vital interests of other individuals;
  • Our legitimate interests: we may process your data because it is our legitimate interests to do so, or the legitimate interests of others.

Special category data

Depending on the circumstances, we rely on the following legal bases to collect and process your health  information:

  • Your explicit consent;
  • To comply with a legal obligation: when we are required to collect and process your information because we have a legal requirement to do so in some jurisdictions, in particular, to protect and safeguard public health;
  • To protect your vital interests, when you are not legally or physically able to give consent.

Who are we sharing your personal data with?

We will not share data with third parties other than as documented in our regular privacy notice. However, in some circumstances, your data may be shared with:

  • Public authorities, in particular health authorities, if we have a legal obligation to do so;

Our providers, including qualified health professionals in line with local regulations,

We will not share your data outside of the European Economic Area (EEA) except when:

  • It is necessary to perform your contract with us (for instance, because you are travelling outside the EEA);
  • We have the legal obligation to do so.

How long do we keep your data for?

We will endeavour to record your personal data, especially your health data, only for the time strictly necessary for the purposes set out in this privacy notice. This includes the following periods:

  • For the time of your tour or travel;
  • 15 days to one month after your visit to our premises, unless a longer period is required by law;
  • For as long as necessary to comply with our legal obligations, contractual requirements or the establishment, exercise or defence of legal claims;

We will delete/destroy your personal data immediately after the relevant retention period above is reached.

How do we protect your data?

We will always collect and process your data, in particular health and biometric information, with due care and we will keep this data separate from our other regular business processing activities.

The information you share with us under the scope of this Privacy Notice will be secured by additional technical and organisational measures and only staff required to see this information will be able to access it on a “need-to-know” basis.

Paper-based records will be kept securely in locked cabinets. Digital records will be kept in encrypted and separate databases or folders with strict access controls in place.

What are my rights and how do I exercise them?

You have the right to:

  • be informed of any data processing;
  • access to your personal data;
  • rectify your personal data;
  • erase your personal data, in some circumstances;
  • restrict processing of your personal data, in some applicable circumstances;
  • data portability, in applicable circumstances;
  • object to the processing of your personal data, in some circumstances;
  • to withdraw consent to the processing of your personal data, where applicable.

If you wish to exercise any of your rights, please contact us either by e-mail to trafalgarhelp@gmail.com.

You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances and we will explain the reasons in our response to you.

You also have the right to make a complaint at any time to the relevant supervisory authority, for example, the Information Commissioner’s Office in the UK.

Further information about your rights is included in our standard Privacy Notice above which this Notice supplements.