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Client – means any individual who has by any means submitted Personal Information to Mabey Ski Ltd, whether by that individual directly or by another Client on his or her behalf.
Personal Information – means any information that may be used to identify you as an individual, such as your first and last name, date of birth, home or other physical address, email address or other contact information, user passwords and, if you make a reservation, your credit card or bank account information, passport and/or travel visa details or personal medical information.
Privacy Officer – means the individual designated responsibility for ensuring that Mabey Ski Ltd complies with this policy any relevant legislation in force from time to time.
PERSONAL INFORMATION THAT WE COLLECT FROM YOU
Unless the purposes for collecting information are obvious and the Client voluntarily provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection.
We may collect, use, disclose, transfer and store any Personal Information you enter through our website or give us through various means, including telephone calls, emails, SMS, messenger apps, social media platforms, surveys, post, and any platforms used by Mabey Ski Ltd. from time to time, including in connection with:
When you register as a user or a subscriber: when you first register on the site as a user or a subscriber for our newsletters or other mailings, you may provide details such as your name, username, email address and an account password.
Details of your visits to the site: when you visit the site, your internet browser sends information that we record, such as location data, traffic data, weblogs, IP address, the date and time of your request and the pages that you access on the site.
Bookings: when you make a booking, we collect information such as name, title, date of birth, nationality, medical information, payment details, travel schedules and trip details, seating preferences, accommodation and other reservation information, including names and passport details, for both individuals and group party leaders.
Cookies: when you visit the site, we send a small file containing one or more cookies. Cookies are small data files which contain information that is transferred to your computer’s hard drive. They help us to improve the site and to deliver a better and more personalised service. We may collect information about your computer including your IP address, operating system and browser type for system administration, although this information will not identify you individually. You can refuse to accept cookies by changing the settings on your browser, although this may prevent you from accessing some areas of the site.
Communications: when you send email or other communications to us, we may keep those communications to process your inquiries, respond to your requests and improve the site.
When you make a reservation with us on behalf of a travel companion or another person or persons, we will request the Personal Information of that individual. You should obtain the consent of such other individuals prior to providing their Personal Information to us.
HOW YOUR INFORMATION IS USED
We will only collect Personal Information that is necessary to fulfill the following purposes:
- to verify identity;
- to provide you with the adventures and services you request;
- to tailor trips to you and your travel companions;
- to provide you with travel confirmation and updates;
- to manage your account, including processing bills and providing travel notifications;
- to communicate with you in general;
- to respond to your questions and comments;
- to allow us to contact you for customer service, if necessary;
- to measure interest in and improve our adventures, services, and website;
- to notify you about special offers and travel-related products and services that may be of interest to you;
- to personalise or customise the content of our website according to your interests;
- to reward you as part of any reward and recognition programme you choose to join;
- to resolve disputes, collect fees, or troubleshoot problems;
- to meet regulatory requirements;
- to prevent potentially prohibited or illegal activities;
- to enforce our Terms and Conditions when you make a travel booking with us; and
- as otherwise notified to you at the point of collection.
SHARING YOUR DATA WITH THIRD PARTIES
We will only share your information with other companies or individuals under the following circumstances:
Bookings: we may need to transfer details of your booking to service providers, suppliers and reservation systems within your country or to other countries to which you are traveling. Please note that these service providers and suppliers may contact you as necessary to obtain additional information about you in order to facilitate the travel reservation which you have made through us.
Business Partners: if you choose to receive information about products or services that we jointly offer with our business partners, we may share information about you, including your Personal Information, with those business partners so that they can contact you directly by email or post about their products and services.
Transfer of Business: if we are involved in a sale or purchase of business or assets, bankruptcy proceedings or a re-organisation, your Personal Information may be transferred or disclosed.
Legal Requirements: we may have to disclose your Personal Information to public or government authorities or regulators (local and/or foreign) if we are required to do so, or if we believe that this is reasonably necessary. This may include co-operating with third parties to prevent fraud and mitigate credit risk. We may also share your Personal Information with public authorities in the interest of your health, safety and security in the event of an emergency.
We will obtain the Client’s consent to collect, use or disclose Personal Information (except where, as noted below, we are authorised to do so without consent).
Consent can be provided orally, in writing, electronically or, through an authorised representative on a Client’s behalf, or it can be implied where the purpose for collecting using or disclosing the Personal Information would be considered obvious and the Client voluntarily provides Personal Information for that purpose.
Consent may also be implied where a Client is given notice and a reasonable opportunity to opt-out of his or her Personal Information being used for mail-outs, the marketing of new services or products, fundraising and the Client does not opt-out.
Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Clients, can withhold or withdraw their consent for Mabey Ski Ltd. to use their Personal Information in certain ways. A Client’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the Client in making the decision.
We may collect, use or disclose Personal Information without the Client’s consent in the following limited circumstances:
- When the collection, use or disclosure of Personal Information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- The collection is clearly in the interests of the individual and consent cannot be obtained in a timely way;
- When the Personal Information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
ENSURING ACCURACY OF PERSONAL INFORMATION
We will make reasonable efforts to ensure that Client’s Personal Information is accurate and complete where it may be used to make a decision about the Client or disclosed to another organisation.
Clients can request correction to their Personal Information in order to ensure its accuracy and completeness. A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought. A request to correct Personal Information should be forwarded to the Privacy Officer.
If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organisation to which we disclosed the Personal Information in the previous year. If the correction is not made, we will note the Clients’ correction request in the file.
SECURING PERSONAL INFORMATION
Mabey Ski Ltd is committed to ensuring the security of our Client’s Personal Information and we take several security measures to protect against unauthorised access to or unauthorised alteration, disclosure or destruction of Personal Information which you provide to us.
Our Privacy Officer continually reviews and updates our security policies and controls as technology changes to ensure ongoing information security.
PROVIDING ACCESS TO PERSONAL INFORMATION
A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. A request to access Personal Information should be forwarded to the Privacy Officer at the following email address: [email protected]
Upon request, we will also tell Clients how we use their Personal Information and to whom it has been disclosed, if applicable.
We will make the information requested available within 30 business days or provide written notice of an extension where additional time is required to fulfil the request.
You will generally not have to pay a fee to access your Personal Information or exercise any rights under the applicable date protection laws. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Where a fee is to be applied, we will inform the Client of the cost and request further direction from the Client on whether or not we should proceed with the request.
If a request is refused in full or in part, we will notify the Client in writing, providing the reasons for refusal and the recourse available to the Client.
The Privacy Officer is responsible for ensuring Mabey Ski Ltd.’s compliance with this policy, the Personal Information Protection Act, and any equivalent laws in any other any jurisdiction that we may be subject to from time to time.
Clients should direct any complaints, concerns or questions regarding Mabey Ski Ltd.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the Client may also write to the UK Information Commissioner.