Pomegranate Travel is incorporated in England (company registration number 8446869) (“Pomegranate Travel/we/us”). We are registered with the Information Commissioner with number ZA393681.
As a data controller we comply with data protection laws including the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and the General Data Protection Regulation (GDPR) which comes into effect May 2018.
What personal data will we collect from you?
When we refer to personal data, we mean any information which relates to an identified or identifiable individual and may include sensitive personal data as further explained below. We need to collect personal data from you in order to respond to a travel inquiry, tailor build an itinerary for you, execute your booking, keep you up to date with travel news and offers, or send you promotional material.
We need to collect your personal data in order to effectively provide you with travel services, including but not limited to building an experience tailored to your likes and preferences; making hotel, touring, transportation, restaurant and other bookings for you; and ensuring you receive tourist rates for services (which in Israel are frequently tax free).
Examples of when and how we may collect your personal information include the following:
- Name and address
- Contact information including email address, postal address and telephone numbers
- Date of birth
- Passport details
- Credit card, bank details or other payment information
- How you would like to hear from us
- If you have previously visited one of our destinations, details of enquiries you have made with us including detailed notes from phone or email conversations, and details of quotes you have asked us to provide to you.
- Details of job applications
- Feedback you have provided to us, including post travel questionnaires you have submitted to us and details of any complaints you have made.
- Interaction with our social media pages
In order to tailor your travel experience we may also need to collect sensitive personal information such as listed below. You do not have to disclose such sensitive personal information, but if you choose not to do so we will not be able to take such factors into consideration when tailoring your itinerary.
- Dietary preferences
- Additional needs due to reduced mobility
- Religious background (our destinations include many religious heritage sites)
When we take your travel inquiry we may also ask for details of your family, children or other party members who will be travelling with you. This is in order to fully tailor your travel experience so that we can build an itinerary which matches your preferences and allows us to provide you with the best possible service. We will not directly contact your children or the other members of your party, unless in the case of other members of your party this is necessary to perform our contract with you or them, or they have specifically opted in to receive information from us.
When visiting our website we also collect information about your IP address and the pages you visit. This helps us to understand which areas of our website are most useful to our clients and make improvements. This does not tell us who you are and where you live until you choose to provide us with that information. Please see our Cookies policy for more information.
How do we collect personal data from you?
There are various ways in which you may provide personal data to us. For example, over the telephone, through an email exchange, or by leaving your details on our website.
Sharing your personal data
Where you make a booking or booking enquiry, appropriate personal data will be passed on to the relevant suppliers (such as hotels, tour guides etc) and any other third party (such as banks and/or credit card companies) who need this information so that your chosen arrangements can be booked and provided or your booking enquiry answered. Once your booking has been made, your personal data may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law. Certain information may also be passed on to security or credit checking companies.
We may also make personal data available to companies who provide services on our behalf, such as mailing brochures.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purpose of providing their services and does not collect any personal data from you in the course of performing their services. If we cannot pass personal data to the relevant suppliers or any other third party as applicable, whether in the EEA or not, we will be unable to fulfil your booking. In making your booking, you consent to your personal data being passed on to the relevant suppliers and other third parties.
Where will your data be processed?
Your personal data may be stored, used and otherwise processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein. We may also store, use or otherwise process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection (which includes Israel) or (2) the personal data is transferred to a United States company which has signed up to the Safe Harbour scheme or (3) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (4) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.
Protecting your personal data
We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.
Please be aware that data that is transmitted via the internet or in email, cannot be absolutely secure. If you wish to send us data in a more secure environment we will be happy to provide you with a secure fax number. We will take every reasonable precaution to keep your information safe but it cannot be guaranteed and so please be aware that any information you do transmit to us is at your own risk.
Can we use your personal data to promote about our tours or other services in the future?
We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so. You may provide your consent by opting to receive marketing material either on-line or by telephone or when completing a booking form. You may also choose in what ways you are happy to receive communications from us. You may, for example, be happy to receive information and offers by e-mail but not by telephone.
Can you withdraw your consent to our processing your personal data?
You can withdraw your consent to receiving marketing material or other communications from us, either generally or in any particular way, at any time by e-mailing us at StartYourJourney@Pomegranate-Travel.com, or by phoning us, and you can also unsubscribe from our newsletters by selecting the ‘unsubscribe’ button at the bottom of our newsletter emails.
You can find out what information we are holding about you
You are entitled to ask us (please email StartYourJourney@Pomegranate-Travel.com) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within one month unless the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further two months.
What to do if you would like to update the information we are holding about you
If you believe this is the case, please tell us by letter or e-mail as soon as possible. We will rectify the problem within one month or within three months if the rectification request is complex.
How long can we retain and process your personal data?
We will only hold your personal information for as long as reasonably necessary to carry out services and administer your relationship with us.
If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent or otherwise for as long as we reasonably consider your consent remains valid and effective.
Where you have provided your personal data to enable us to provide the holiday arrangements or other services you have contracted, we are entitled to retain this information for a period of ten years after the end of those arrangements. In certain limited circumstances, we may be able to retain it for a longer period.
What to do if you want us to delete your personal data
Yes, you can ask us to remove your personal data in certain circumstances for example where you have withdrawn your consent to our further using this for marketing purposes. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.
What should I do if I have a complaint about the processing of my personal data? If you have any complaint about the way in which your personal data has been dealt with, please let us know by e-mail to StartYourJourney@Pomegranate-Travel.com. We will investigate and respond to you as soon as we reasonably can. If you remain dissatisfied, you may complain to the Information Commissioner’s Office. For further details, see www.ico.org.
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