Introduction
Welcome to Scuba Travel’s privacy notice.Scuba Travel 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 visit our website from the UK or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you. This privacy notice does not apply to other websites to which we may provide links.This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below. Alternatively you can download a pdf version of the notice here. Please also refer to the Glossary that we have set out at the end of the privacy notice, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
1. IMPORTANT INFORMATION AND WHO WE ARE
Purpose of this privacy notice
This privacy notice aims to give you information on how Scuba Travel collects and processes your personal data through use of this website, including any data you may provide through your use of this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc. This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party. 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 the other notices and privacy policies and is not intended to override them.
Data Controller
Tony Backhurst Scuba Limited trading as Scuba Travel is the controller and responsible for your personal data (collectively referred to as "Scuba Travel", "we", "us" or "our" in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact details
If you have any questions about this privacy notice or our privacy practices, please contact our data privacy manager in the following ways:
- Our full details are:
- Full name of legal entity: Tony Backhurst Scuba Limited trading as Scuba Travel;
- Data privacy manager: Martin Nordin
- Email address: martin@scubatravel.com
- Postal address: Scuba Travel, The Loft, The Old Mill, Mill lane, Godalming, GU7 1EY
- Telephone number: 01483-411590
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 (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 policy under regular review. This version was last updated on 30/6/2022 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details your personal data changes, during the course of your relationship with us.Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, 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).We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
(A) Identity Data
This includes data relating specifically to your identity, such as your first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.(B) Contact Data
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.(C) Financial Data
This include data relating to your means and methods of payment, such as your bank account and payment card details.(D) Transaction Data
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.(E) Technical Data
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, 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.(F) Profile Data
This includes the data that we receive when you create a profile on our website and make use of that policy, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.(G) Usage Data
This includes information about how you use our website, products and services.(H) Marketing and Communications Data
This includes your preferences in receiving marketing from us and our third parties and also your communication preferences. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 will treat the combined data as personal data which will be used in accordance with this privacy notice.Special Categories of Personal Data
We collect the following special categories of personal data about you. Including details about your:We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellations in clause 7 of our Booking Terms and Conditions (click here for our terms and conditions) will become payable.
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 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 (for example, to provide you with services).In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary date, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions (click here for our terms). We will notify you if we are unable to process a booking or are required to cancel a booking for this reason. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including through:
(A) Direct interactions
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:(B) Third parties
We may receive personal data about you from various third parties as set out below:4. 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:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 | Type of data | Lawful basis for processing including basis of legitimate interest |
---|---|---|
To register you as a new customer. |
(a) Identity; (b) Contact. | Performance of a contract with you |
To process and deliver your booking including:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
|
(a) Identity;
(b) Contact;
(c) Financial;
(d) Transaction;
(e) Marketing and Communications
|
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
|
To manage our relationship with you 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.
|
(a) Identity;
(b) Contact;
(c) Profile;
(d) Marketing and Communications.
|
(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|
To enable you to partake in a prize draw, competition or complete a survey. |
(a) Identity;
(b) Contact;
(c) Profile;
(d) Usage;
(e)Marketing and Communications.
|
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
(a) Identity;
(b) Contact;
(c) Technical.
|
(a) Necessary for our legitimate interests (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);
(b) Necessary to comply with a legal obligation.
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you. |
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e)Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how customers 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, customer relationships and experiences |
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of customers 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 goods or services that may be of interest to you |
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
|
Necessary for our legitimate interests (to develop our products/services and grow our business)
|
For the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure |
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
(f) Profile
(g) Usage
(h) Marketing
|
Necessary for our legitimate interests (protection and assertion of our legal rights, your legal rights and the legal rights of others)
|
For the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice |
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Technical
|
Necessary for our legitimate interests (the proper protection of our business against risks)
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.Automated Decision Making
We will use your personal data for the purposes of automated decision-making in relation to targeted marketing communications.This automated decision-making will involve selecting appropriate and relevant marketing messages for you based on your previous enquiry and transaction history.
The significance and possible consequences of this automated decision-making are technical errors however thorough testing and safeguarding is in place to prevent this from happening.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage 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, in each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any company outside the Scuba Travel 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.Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.
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. Please see our cookie policy for more information.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.
5. HOW WE DISCLOSE YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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.
6. WHEN WE TRANSER YOUR DATA OVERSEAS
Many of our external third parties are based outside the United Kingdom (UK) so their processing of your personal data will involve a transfer of data outside the UK.
Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the UK, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the UK in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the UK, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the UK (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the UK, controls on data protection may not be as wide as the legal requirements within the UK.
For all other transfers of data, whenever your personal data is transferred outside the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
7. HOW WE SECURE YOUR DATA
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. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
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
8. HOW LONG WE RETAIN YOUR 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 legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us
In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for 7 years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may 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.
9. 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:
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 may 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 may 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.10. GLOSSARY
LAWFUL BASIS
means the interest of our business in conducting and managing our business to enable us to give you the best service 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
THIRD PARTIES
YOUR LEGAL RIGHTS
You have the right to:(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) 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
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.