Radical Travel Group Limited t/a Morag's Lodge
We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. 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.
We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal data unless at least one of the following requirements are met:
- You have given consent to the processing of your personal data for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);
- The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);
- Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications); - Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);
- Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (for instance, protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders).
We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal data, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal data for unrelated purposes, based on our legitimate Interest.
- There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
- For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
- We will adopt an aggregate data model that allows us derive aggregated data from your personal information. Aggregated data is not considered personal data by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
- However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
- We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct legitimate Interest assessments and data protection impact assessments DPIA, prior to carrying out the proposed processing activity.
This section summarises the types of personal data about you that we process:
6.1 Data concerning you as an individual We may collect the following:
6.2 Business Related Information If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you: - business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), - your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and - your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).
6.3 Enquiry and Booking information Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: - records of enquiries and searches for holiday and travel products made by or on your behalf, - details of your personal interests, - needs and other data relevant to your enquiry; - details of results, quotes, proposals, estimates and other information given in response to enquiries; - details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; - details of the passengers / holidaymakers travelling; - details of the provider of the travel services (e.g. tour operator); - dates and times of travel; - price; - payment details (including card details); - passport information and visa information; - foreign exchange requirements and arrangements; and - Sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.
6.4 Survey Information Information collected or generated out of any surveys we conduct.
6.5 Competition Information Information collected or generated out of any competitions or promotions we run.
6.6 Account, Registration and Loyalty Information Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.
6.7 Correspondence Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.
6.8 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 section sets out the ways in which we may collect or generate personal data concerning you.
7.2 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 enquiry or booking for a holiday 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; - and request sales and advertising information, including brochures.
7.3 User Generated Content (UGC) We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let Morag’s Lodges Ltd and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as: - Print materials - on our website - email activities - social posts - images on our trips - provide images to our trade partners to use on their websites, email marketing and other marketing initiatives - make available in our content feeds - We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods - Any other information provided to us by or in relation to you which concerns you as an individual.
7.4 Data obtained from third parties We may obtain personal data concerning you from third parties, including from: - providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; - credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; - Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.
This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.
8.1 Operate our website To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.
8.2 Provide information and respond to enquiries To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.
8.3 Bookings and other contracts To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.
8.4 Payments To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us.
8.5 Communication with customers To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.
8.6 Record Keeping To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.
8.7 Manage and Improve our business To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; - to carry out surveys and analyse the results; to run promotions and competitions; - undertake product or customer research/development; - to assist us in and help us to improve our sales, - editorial, advertising and marketing processes; - to carry out other business development and improvement activities; and - to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings. This is done on the basis of our legitimate interests in ensuring our business to run efficiently.
8.8 Direct marketing To carry out direct marketing to you, see section 10.1 for further information.
8.9 Advertising To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.
8.10 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. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.
8.11 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/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.
Period for retaining your data We will only retain your personal data for as long as necessary to fulfil 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 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 requirements. If you would like to know more about our data retention policy, please ask us.
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 so, such as through an opt-in box on any form or website of ours; and/or - you have made a booking with us and there is our legitimate business interest to do so for similar products or services. If you do not want to receive direct marketing activities anymore, you can manage your communications preferences on your online account or unsubscribe by following the link at the end of every of our electronic communications. 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, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.
10.1 Direct marketing by us We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services: (1) offered by us; (2) which can be booked with third parties through us; (3) which can be booked with other companies within our group (i.e. the Travel Corporation Group); and (4) offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent. Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or sms).
10.3 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 to third parties We transfer your personal data to third parties in the following circumstances:
11.1 Credit Checks etc. We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.
11.2 Bookings and performance of contracts We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; - to apply for visas on your behalf, - to collect payments to be made by you, - to investigate and respond to complaints, and - to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.
11.3 Suppliers of travel and other services We may disclose your personal data to any third party (e.g. supplier, contractor subcontractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you. We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
11.4 Insurance If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
11.5 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, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.
11.7 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 or when required by a public enforcement body, or - for the purposes of customs, visas and immigration. We may disclose your personal data where otherwise required by or permitted by law.
11.8 Direct Marketing by third parties We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent. Please refer to the direct marketing section above for more information.
11.9 Business Customers who are businesses (not individuals) If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data. If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.
Where we provide your personal data to a third party one of the following two circumstances will apply:
We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”). We will only send your personal data outside the EEA to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA. You can find out about what adequate safeguards these are by contacting us using the details provided in Section 4 of this privacy notice.
14.1 Our security measures We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including: - only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; - using secured servers to store your information; - verifying the identity of any individual who requests access to information prior to granting them access to the information - using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions. Unfortunately transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access. For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information. We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.
You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we 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. More information about your rights and our obligations can be found the Information Commissioners Office. https://ico.org.uk/ To exercise any of your rights below, please contact us as per the contact details provided in Section 4. You can also exercise some of these rights directly through our online form https://ttc.com/personal-data-request/ You may request, we tell you whether we are processing personal data about you, to tell you what personal data we are processing, for what purposes, from which sources we have collected it, who we disclose it to and to provide you with a copy of your personal data that we hold. We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case. The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.
You have the right to have your personal data amended if it is inaccurate or incomplete.
15.2 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.
15.3 Erasure You have the right to have your personal information deleted or removed in the following circumstances:
- The data is no longer necessary for the purpose for which it was originally collected or otherwise processed; - Where you withdraw your consent, where consent was used as the legal basis for processing; - Personal data has been unlawfully processed; - When you object to the processing and we have no overriding legitimate interest for continuing the processing; - Erasure is required for compliance with a legal requirement; or - Data has been collected in relation to the offering of online services to a child. When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete. We have the right to refuse to act on a request of erasure if the data is necessary for: - Exercising the right of freedom of expression and information; - Compliance with a legal obligation; - The establishment, exercise or defence of legal claims;
You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:: - the processing is based on consent or on a contract; and - the processing is carried out by automated means.
15.5 Restrict Processing
You have the right to obtain from us the restriction of processing of your personal data where one of the following applies: - You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data; - The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead; - We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise or defence of legal claims; - You have objected to processing pending the verification whether our legitimate grounds override yours. Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so. We will inform you before the restriction of processing is lifted.
15.6 Right to withdraw your consent
You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 4 of this policy. See also section 12 for details as to how to object to our direct marketing communications.
15.7 Complaints to the Data Protection Authority
The laws we comply with are regulated by the Information Commissioners Office in the United Kingdom and for other member states, the independent supervisory authority responsible for monitoring the application of the regulation]. In addition to your rights above, it is open to you, if you have a complaint or a 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 complaint or concerns you have. You can contact us using the details provided in Section 4 of this our privacy notice.
We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.
15.9 Applicable Law and Disputes
This document, and all content of our websites is Copyright © 2020 Morag’s Lodges
Limited. ALL RIGHTS RESERVED.
Also known as the 'Cookie Directive', the instrument that defines the requirements for consent for cookies across the EU is Directive 2009/136/EC of the European Parliament and of the Council, an excerpt of which is reproduced below: “Member States shall ensure that the storing of information, or the gaining of access to information already stored, in the terminal equipment of a subscriber or user is only allowed on condition that the subscriber or user concerned has given his or her consent, having been provided with clear and comprehensive information”. Page 2 of 4 The UK introduced the amendments on 25 May 2011 through The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. The relevant section is below:
“6. - (1) Subject to paragraph (4), a person shall not store or gain information, or to gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met.
(2) The requirements are that the subscriber or user of that terminal equipment - (a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent.
(3) Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use.
(3A) For the purposes of paragraph (2), consent may be signified by a subscriber who amends or sets controls on the internet browser which the subscriber uses or by using another application or programme to signify consent.” In summary, to comply with the law, we need to give clear information about what the cookies are used for, why, and obtain consent from you, the user. These are the objectives this Policy is set out to achieve.
Cookies can be categorised in many ways, one is with regards to their longevity, i.e. for how long they are stored in your browser. According to this classification, cookies can either be: - Session cookies: temporary cookies that identify and track users within our website. These are automatically deleted by your browser when you close your browser or end the session; and - Persistent cookies: cookies which enable our website to „remember‟ who you are and your preferences within our website. These cookies are stored in your browser (the specific location depends on the browser and version) for a period of time. We assess the cookies present in our website periodically, to ensure they are aligned with the requirements of current legislation. For instance, we remove persistent cookies set to hold data for an excessive period of time, which do not meet the principle of storage limitation, as per Article 5.1.e of the General Data Protection Regulation (GDPR).
What the cookies do
Reason to have the cookies in our website
Enhance our website’s functionality
Cookies allow us to enhance the functionality of our website so that we can personalise your experience and allow you to use many of the useful features of our website. These cookies are strictly necessary for the proper functioning of the website.
Enhance our website’s performance
This type of cookies helps us understand how our website are being used, mainly for analytical purposes, so that we can work on providing an improved user experience.
Cookies used for this purpose do not collect information that identifies a user, but the data is aggregated and made anonymous.
For example, data on error messages displayed to users will be collected and the developer team will assess whether the problem is prevalent and solve it.
Web beacons and parameter tracking
These cookies and similar software known as web beacons are used to count the number of users visiting our website, or the number of actions made by the users.
Internet Protocol (IP) address and traffic data
A set of data such as IP addresses, access rates, and page views are recorded in our servers.
These data do not allow to identify any individual, i.e. no personal data is collected.
As cookies are stored in the web browser used to access the website, users need to change the settings pertaining that browser in particular. Below are some of most popular browsers and corresponding links to the vendors‟ guidance on disabling cookies:
- Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-deletemanage-cookies https://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internetexplorer
- Safari: https://support.apple.com/kb/PH5042?locale=en_GB
In addition, Google Analytics gives you the option to install an opt-out browser add-on for Page 4 of 4 Internet Explorer 11, Firefox, Chrome, Safari, and Opera: https://tools.google.com/dlpage/gaoptout
Several websites explain how cookies work, offering more detail, such as www.aboutcookies.org, and www.allaboutcookies.org. (we have no affiliation with these websites).