Privacy Notice – Parnassus Luxury Travel Limited

Introduction

Parnassus Luxury Travel Limited (trading as “Osborne & Denee”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you correspond with us, when you purchase a product or service via us and when you visit our website (regardless of where you visit it from) and it tells you about your privacy rights and how the law protects you.

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Parnassus Luxury Travel Limited (trading as “Osborne & Denee”) collects and processes your personal data through your use of this website, including any data you may provide through this website, when you sign up to our newsletter, purchase a product or service or otherwise interact or communicate with us.

This privacy notice applies to our potential clients and clients (including individuals associated with corporate clients), individuals who visit our website and others who we deal with (such as suppliers and individuals associated with them).  The specific types of data we collect about you will depend on the relationship between us.

It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and privacy policies and is not intended to override them.

In this privacy notice we refer to “data protections laws”.  These include the General Data Protection Regulation and the Data Protection Act 2018.

Controller

Parnassus Luxury Travel Limited (trading as “Osborne & Denee”) is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice).

We have not appointed a data protection officer.  However, we do have a data protection manager who is responsible for overseeing questions in relation to this privacy notice and our privacy practices. If you have any questions about this privacy notice, including any requests to exercise your legal rights (see paragraph 10 for more details about your rights) please contact the data protection manager using the details set out below.

Contact details

Full name of legal entity: Parnassus Luxury Travel Limited

Data Protection Manager: Theo Osborne

If you have any questions about this privacy notice or our privacy practices, please contact our data protection manager in one of the following ways:

Email address: theo@osborneanddenee.com

Postal address: 5-6 Kendrick Mews, London, SW7 3RH

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review. This version was last updated on 23^rd July 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2. Data you provide to us about other individuals

Given the nature of the products and services which we provide, it is likely that you will provide us with personal data relating to other individuals (such as, if you are an individual client, details of your family members or if you are a corporate client, details of employees).  Before you provide their personal data to us you must ensure that you have the right to provide that personal data to us and that we may collect, use and disclose that personal data as set out in this privacy notice without us having to take any further steps.

You must ensure that those individuals are made aware of the matters set out in this privacy notice, such as who we are, what we will do with their personal data, who we may disclose their personal data to and their rights in relation to their personal data.

3. The data we collect about you

Personal data means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

The types of personal data that we collect about you will differ depending on our relationship with you.  For example, the types of personal data we collect about individual clients will be different to the types of data we might collect about individuals associated with our corporate clients.  In addition these will be different to the types of data we collect about our suppliers (or individuals associated with them), which in turn will be different to data we collect from visitors to our website.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes name(s), marital status, title, date of birth, gender and passport details (which includes copies of passports).
• Contact Data includes address(es), email address(es) and telephone numbers (including mobile, landline and/or office numbers).
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website (including details about CPU (central processing units) and GPU (graphic processing units) used in your device.
• Profile Data includes purchases or orders made by you, your interests, preferences (including likes and dislikes), feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Correspondence Data includes correspondence between you and us including e-mails, letters and notes of telephone conversations or meetings.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

There are certain types of more sensitive personal data, known as Special Categories of Personal Data that we may collect about you. These include details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions and information about your health.  This type of information would include any details about disability or mobility issues or dietary requirements.

There are some other types of Special Categories of Personal Data which we do not collect. These include trade union membership details and genetic and biometric data.

We do not collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you (or our client or supplier), and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (or our client or supplier) (for example, to provide you with products or services) or we may not be able to comply with legal obligations which we are subject to. In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity, Contact, Profile, Correspondence and Financial Data and Special Categories of Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • enquire about our products or services;
  • apply for our products or services;
  • enter a competition, promotion or survey;
  • where you are a supplier, where we contact you in relation to products or services which you may or which you do supply us with; or
  • give us feedback or contact us.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
• Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Technical Data from analytics providers such as Google based outside the EU;
  • If you are an employee, worker or contractor of (or in a similar relationship with) one of our corporate clients, our client may provide us with your Identity Data and Contact Data;
  • If you are one of our suppliers or business contacts then we may receive your Identity and Contact Data from your employer or the organisation which you are connected with, from our business contacts who recommend you or from publically available resources, such as websites and brochures.

5.  How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you (“Contract Reason”).
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests Reason”). This means it is in the interests of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
• Where we need to comply with a legal obligation that we are subject to (“Legal Obligations Reason”).
• Where it is necessary in order to protect the vital interests of you or someone else, and you or that other person are unable to provide your consent (“Vital Interests Reason”).
• Where you have provided your explicit consent to us using your personal data for a specific purpose (“Consent Reason”). However, you have the right to withdraw consent at any time (see paragraph 10 for more details).

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To respond to enquiries and to send you information which you have requested	Contract Reason Legitimate Interests Reason (to carry out our obligations in relation to the contract with our client or supplier, to run our business and to grow our business)
To register you as a new client (or to register a corporate client which you are representing)	Contract Reason Legitimate Interests Reason (to carry out our obligations in relation to the contract with our client or supplier)
To fulifil, process and deliver your (or our client’s) order including: (a) Manage payments, fees and charges; (b) Collect and recover money owed to us; (c) Booking holidays, tours, transport and other products/services our client has ordered; (d) Contacting you about products or services (including to send you travel documentation and itineraries, to provide you with updates such as flight time changes or to update you in relation to Foreign Office advice)	Contract Reason Legitimate Interests Reason (to carry out our obligations in relation to the contract with our client, to run our business and to recover debts due to us)
To manage our relationship with you (or our client or supplier) which will include: (a) Notifying you about changes to our terms or privacy notice (b) Asking you to leave a review or take a survey (c) Receiving feedback and dealing with complaints.	Contract Reason Legal Obligations Reason Legitimate Interests Reason (to carry out our obligations in relation to the contract with our client or supplier, to keep our records updated, to provide client service and to study how clients use our products/services)
To keep a record of your interests and preferences in relation to our products and services	Legitimate Interests Reason  (to ensure that if you use our services again we understand your preferences and we can offer relevant and tailored products and services to you)
To enable you to partake in a prize draw, competition or complete a survey	Contract Reason Legitimate Interests Reason (to study how clients use our products/services, to develop them and grow our business)
To provide your personal data to someone in an emergency (such as an accident)	Vital Interests Reason
To comply with our legal obligations, including in respect of health and safety and prevention of fraud and in relation to any disputes or legal claims	Legal Obligations Reason Legitimate Interests Reason (to protect and defend our business)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	Legitimate Interests Reason (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Legal Obligations Reason
To understand the effectiveness of the advertising we serve to you	Legitimate Interests Reason (to study how clients use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, client relationships and experiences	Legitimate Interests Reason (to define types of clients for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about products or services that may be of interest to you	Legitimate Interests Reason (to develop our products/services and grow our business) Consent Reason

Purposes relating to sensitive information

As explained in paragraph 3 above, there are certain types of Special Categories of Personal Data which we may collect and use about you.  In addition to having one of the lawful bases highlighted above in place in respect of collecting and using that data, there are extra conditions we must have in place to collect and use Special Categories of Personal Data, given its sensitive nature.

Where we do collect and use Special Categories of Personal Data we rely on one of the following extra conditions to do so:

• We have your explicit consent to processing the Special Categories of Personal Data;
• Where it is necessary to protect your vital interests or those of another person where are not physically or legally able to give your consent.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Transaction, Technical, Usage, Correspondence and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. You may also receive marketing communications if you are one of our current or prospective suppliers or business contacts.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time using the details set out at the beginning of this privacy notice.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions between us.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

6. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table in paragraph 5 above.

• Third parties which need your personal data in relation to the contract which we have entered into with you, for example, hotels, airlines, tour operators and destination management companies. The third parties will depend upon the products or services which we are providing to you.
• Marketing agencies acting as processors who provide marketing services to us.
• Marketing platforms (such as Mailchimp) acting as processors on our behalf.
• Service providers acting as processors who provide IT software and storage.
• Our contractors and sub-contractors acting as processors on our behalf.
• Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
• Law enforcement agencies, courts, immigration authorities, customs and excise authorities, border control agencies, security agencies, anti-terrorism agencies and other similar authorities/bodies.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

Except for governments and other similar official bodies, we require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

7. International transfers

Some of the external third parties listed in paragraph 6 above are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.  Given the nature of the products and services which we provide, it is likely that we will need to transfer your personal data (including sensitive information) outside of the EEA (including to the travel destination) in order to fulfil the contract which we have entered into with you.

Subject to certain exceptions set out below, when we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring appropriate safeguards are implemented.  These may include:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

We may also transfer personal data about you outside of the EEA where there are no safeguards in place but where the data protection laws allow us to. Those situations include the transfer of personal data outside of the EEA where:

• you have explicitly consented after being informed of the risks of the transfers without appropriate safeguards in place;
• it is necessary for the performance of a contract between you and us or for pre-contractual steps taken at your request;
• it is necessary for the performance of a contract made in your interests between us and another person;
• it is necessary to protect the vital interests of you or other persons, where you are physically or legally incapable of giving your consent; or
• it is necessary to establish, exercise or defend legal claims.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

8. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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 unauthorised 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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our clients or potential clients (including Contact, Identity, Transaction, Correspondence, Usage and Profile Data) for ten years after they cease being clients.

If you are a supplier we will keep your Contact and Identity Data for as long as is necessary to fulfil the purpose we collected it for.

We will keep Financial Data for up to 1 month from the point of collection.

Technical Data will be kept depending on the type of cookies or other technologies used.  For example, for session cookies, Technical Data will only be kept until you close your browser and for other types of cookies, Technical Data will be kept for one year.

In some circumstances you can ask us to delete your data, see paragraph 10 below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (i) if you want us to establish the data’s accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us using the details set out at the beginning of this privacy notice.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.