1.1 HINDSIGHT is a trading name of Global Travel Ventures Limited (“we”, “us”, or “our”, “GTV”) are committed to protecting and respecting your privacy.
1.4 For the purpose of data protection laws, the data controller in respect of the Website and Mobile Applications is Global Travel Ventures Limited of One St Aldate’s, Oxford Town Hall, OX1 1DE.
1.5 Any changes we may make to this policy and how we use your data in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this policy.
1.6 Questions, comments and requests regarding this policy are welcomed and should be emailed to our Customer Relations team via the “Contact Us” page on our site.
2. Information that we may collect from you
Personal Information is information that identifies you specifically (such as your name, address, phone number, email address, age or date of birth, your internet protocol address (“IP address”)). The types of Personal Information we collect and share depend on the service you have with us. We only collect such information when you choose to supply it to us. You confirm that the information you enter about yourself and any other passengers for whom you are booking is true, and that when you are submitting personal data belonging to anyone other than yourself you have permission from those passengers, or parental or guardian’s consent where that person is a child under 16. Examples of the confidential Personal Information we may collect and maintain include the below:
2.1 Information you give us
Some parts of the Booking Service require you to actively submit information in order for you to benefit from specific features, or make ticket bookings, or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for tickets, order tickets on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include Personal Information.
2.2 Information we collect about you
Automated anonymous information may be collected when you interact with us via the Website and with our emails, which may include but is not limited to:
• Technical information such as your computer’s or mobile device’s operating system and browser type, the address of a referring website, if any, and the path you take through our web pages;
• Remarketing information which lets us reach out to you when you search on Google using our keywords or visit other websites. You may be shown an ad that might encourage you to return to our site and complete a purchase; third-party vendors, including Google, show our ads on sites across the Internet.
• Clickstream information such as the address (or URL) of the website that you came from before visiting our site, which pages you visit on the site, which browser you used to view the site and any search terms you may have entered on the site, among other things; and
• Web beacons to allow us to know if a certain page was visited or an email was opened, when you open the email, your IP address, your browser or email client type, and other similar details.
• When you use our site on your mobile device, we may collect information about the type of device and operating system you use. We may ask you if you want to receive push notifications about activity in your account.
If you opt in to these notifications and later no longer want to receive them, you may turn them off through your operating system. We don’t access or track any location-based information from your mobile device unless you’ve given us permission.
2.3 Location data
Information about your location or approximate location may be used by our Booking Service. We may obtain and use this information in two main ways:
• Internet traffic information, such as your IP address: this information is provided automatically as you use our Booking Service and can allow us to infer your approximate location – for example your city or county, and country. We use this information:
• for analysis purposes to understand the distribution of our customers;
• to tailor messages or advertisements shown on our Website or mobile Applications, for example if we identify that you are likely to be located in Oxford, we may show you promotions relating to journeys starting in Oxford.
• Location information provided by your browser or device: Many web browsers, particularly on mobile phones and tablet devices, are able to accurately report your location, for example using GPS technology. The same is true for apps on mobile phones and tablets. These browsers and devices normally ask your permission before sharing your location with a website or app, and you can usually disable the feature altogether in the device settings. We use this information for features that need to know your location – such as search functionality features.
2.4 Information we receive from other sources
We may receive information about you if you use any other websites we operate or the other services we provide. In this case, we will have informed you when we collected that data that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
3. Uses made of this information
We use information held about you in the following ways:
3.1 Information you give to us
We will use this information:
• To carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, tickets and services that you request from us;
• To provide you with information about other tickets, products and services we offer that are similar to those that you have already purchased or enquired about;
• To provide you, or permit selected third parties to provide you, with information about products or services we feel may interest you. If you are an existing customer, we will only contact you by telephone, e-mail or SMS with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form or registration form) or in the preferences section of your account;
• To notify you about changes to our service;
• To ensure that content from our site is presented in the most effective manner for you and for your computer.
3.2 Information we collect about you
We will use this information:
• To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• To allow you to participate in interactive features of our service, when you choose to do so;
• As part of our efforts to keep our site safe and secure;
• To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• To make suggestions and recommendations to you and other users of our site about products or services that may interest you or them;
• To resolve any problems that your report to us (troubleshooting).
3.3 Information we receive from other sources
We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
4. Disclosure of your information
We may share your Personal Information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
4.1 We may share your information with selected third parties (including third parties outside of the EU) for the purpose of:
• processing a booking reservation, or otherwise in relation to fulfilling a booking you have made via the Booking Service;
• for customer services where you may have a query or complaint regarding the Booking Service;
• for marketing services (where you have consented to receive such marketing services);
• for processing payment (including fraud screening);
• for advertising on our Website in our emails and elsewhere on the internet, including targeted advertising of GTV’s own products and services and certain third parties’ products or services (and for these purposes we and certain third parties we work with will collect information about your browsing activity so we can help make the advertising referred to above more relevant to you);
• collecting your comments if you choose to provide feedback through our Website; and
• for undertaking any other permitted use of your Personal Information on our behalf.
These service providers will only have access to the Personal Information needed to perform the relevant service and may not use your Personal Information for any other purpose. They will also be required to use your Personal Information strictly in accordance with data protection laws, including maintaining adequate security measures to protect such Personal Information.
We may also share your personal information:
• with legal or regulatory authorities (including the Department for Transport) where we are lawfully requested or required to do so, or voluntarily to the Police and similar law enforcement agencies (including, but not limited to, fraud prevention and detection), other government agencies or third parties.
4.2 We may disclose your Personal Information to third parties:
• In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
• If GTV or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets;
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
5. Where we store your personal data
5.1 We take the security of your data very seriously. We employ physical, electronic and administrative security measures to protect the information that we collect about you from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage. You acknowledge and agree that we shall not be responsible for any unauthorised use, distribution, damage or destruction of personal data, except to the extent we are required to accept such responsibility by the data protection laws.
5.3 All information you provide to us is stored on secure servers hosted within Amazon Web Services or on our encrypted computers. Any payment transactions will be encrypted and we will not store the full PAN plus any of the following: cardholder name, expiration date and/or service code (“Cardholder Data”) ourselves but this will be securely processed by our payment service provider. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to prevent unauthorised access.
6. Your rights
6.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by writing to us at GTV, One St Aldate’s, Oxford Town Hall, OX1 1DE.
6.2 The Website and Mobile Application may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7. Access to information
The data protection laws give you the right to access information held about you. Your right of access can be exercised in accordance with the data protection laws. You may obtain these details by writing to us at Global Travel Ventures, One St Aldate’s, Oxford Town Hall, OX1 1DE, England. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you and we may require proof of your identity before we supply the information to you.
8. Deactivating your account
Upon request from you (by contacting us at: Global Travel Ventures, One St Aldate’s, Oxford Town Hall, OX1 1DE, England) we will deactivate your account and render your Personal Information unusable as soon as reasonably possible, in accordance with applicable law. We do retain personal information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our terms and conditions, and take other actions otherwise permitted by law.