Introduction

When you interact with us we collect your personal data. JG Travel Group is committed to protecting your privacy. Please read the following policy that explains how we use and protect your information. We are the data controller of the information you provide to us.

On 25th May 2018 the regulations about how your personal data are used and stored changed. The new European regulations often referred to as GDPR (General Data Protection Regulation) supersede the Data Protection Act 1998. We have tried to provide a relevant and accurate summary within this policy to help you understand your rights whilst also allowing us to hold and use relevant information about you for your benefit.

1. The JG Travel Group of companies

The JG Travel Group (JGTG) is made up of a number of related businesses all of which provide travel products and services to members of the public:

National Holidays, Just Go! Holidays, Omega Breaks, Cruise Connections and Albion Journeys

2. Explaining the legal bases we rely on

The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

• Consent

  In specific situations, we can collect and process your data with your consent.

  For example, when you tick a box to receive email newsletters.

  When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.

• Contractual obligations

  In certain circumstances, we need your personal data to comply with our contractual obligations. For example, when we are booking a hotel, flight or event ticket on your behalf we may need to pass on your information.

• Legal compliance

  If the law requires us to, we may need to collect, process and share your data.

  For example, when required by Government or Health Services for Track & Trace reasons during the Covid-19 pandemic. In addition we can pass on details of people involved in fraud or other criminal activity affecting the Partnership to law enforcement.

• Legitimate interest

  In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.

For example, we will use your purchase, enquiry and web browsing history to send you or make available personalised offers.

We also combine the booking history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services. We will also use your address details and email address to send you direct marketing information by post and email, telling you about products and services that we think might interest you.

3. When do we collect personal information about you?

• When you request information about our products and services e.g. brochure request.
• When you make a booking both through our website or over the phone.
• When you sign up for the newsletter on our website.
• When you create an online account.
• When you browse our websites.
• When you engage with us on social media.
• When you contact us by any means with queries, complaints etc.
• When you enter prize draws or competitions.
• When you choose to complete any surveys we send you.

4. What personal information do we collect about you?

• In the natural course of requesting product information for example a brochure we will ask for your name, address and telephone number.

• In the natural course of making a reservation we will ask for your name, address, gender, date of birth, email address and phone numbers, both home and mobile if different.

• Any special requirements you may have such as dietary and any disabilities which we should know about in order to ensure you have a safe and enjoyable trip. We will collect and process payment card details for the purposes of the transaction at that time but this data is not retained for future transactions or reference.

• Passport details where advance passenger details are required.

• If you create an online account we will store an encrypted version of your login password.

• Calls to the JG Travel Group offices are recorded for training purposes. These will contain any personal data you have provided to us during that call.

• If you engage with us via social media, your social media username.

• We log your preferences as to how your data can be used e.g. for direct marketing.

• IP addresses and cookies:

  We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

• For the same reason, we may obtain information about your general internet usage by using a cookie which is stored on the hard drive of your computer. Cookies are used to assist the operation of our website and are designed to deliver a better and more personalised service.

  They enable us:

  To estimate our audience size and usage pattern.

  To store information about your preferences, and so allow us to customise our website and electronic and postal communications according to your individual interests.

  To speed up your searches.

  To recognise you when you return to our website.

5. How we use the information we collect about you and why we would do this

• JG Travel Group will only process (collect, store and use) the information you provide if there is a reason for doing so in a manner compatible with the EU’s General Data Protection Regulation (GDPR).

  We will endeavour to keep your information accurate and up to date, and not keep it for longer than is necessary. JG Travel Group is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.

  Personal data may be held in addition to these periods depending on individual business needs. The JG Travel Group Document Retention Policy will define how long we securely retain each set of personal data.

  Generally we collect information at the time of booking or making a request for information in order to provide you with a service, a service which you have requested and to fulfil our legal obligations as far as providing a holiday are concerned.

  The data privacy law allows this as part of our sole interest in striving to understand our customers and answering their needs and wants as far as service and product design are concerned.

• We will contact you via telephone, SMS text, letter and/or email when appropriate to keep you informed about travel updates that might affect your upcoming trip e.g. coach pickup times.

• We ask for your consent to use your personal data and preferences to keep you informed by email, post and telephone about our products and services including special offers and promotions. We may use email addresses provided as part of the checkout process, even if checkout is not completed. We’ll do this on the basis of our legitimate business interest. You are free to change your preferences at any time and to opt in or out of any or all of these channels by contacting us directly.

• We might also receive your personal data from third party sources who collect information about you and based on your interests will pass your contact information to us using either consent, where you have given your specific agreement for your information to be passed to us for a specific purpose or using legitimate Interests as the legal basis to send you marketing information and exciting offers. Where legitimate Interest is the legal basis you will always be given the option to object to this processing at the point of collection and can update your preferences with us at any time. Please see section 10. An overview of your different rights.

6. Do we share your information with anyone else?

• Yes, but only as necessary and when legally required to do so in the fulfilment of our obligation to provide you with a product or service you have requested or booked. We may contract with partners who process personal data on our behalf in line with our instructions and our data privacy policy.

• During Covid-19 and to follow Government guidelines, we will pass your details to our partners for Track & Trace purposes.

• All of our partners e.g. coach operators, airlines, hotels also have to conform to the GDPR standard and when they no longer need your data to fulfil this service, they will securely dispose of your personal data in line with JG Travel Group’s procedures.

• Hotels may need to retain your reservation data in order to comply with their own income tax and audit purposes.

• If you purchased your holiday quoting a code from a regional newspapers readers offers section you authorise us to pass the data to the publisher of the newspaper.

• If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.

• We do not sell, transfer or otherwise disclose this personally identifiable information outside this company, except where disclosure is required by law.

7. Under what circumstances will JG Travel Group contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous data security measures and procedures to minimise the risk of unauthorised access or disclosure.

8. How we will protect your personal data

• We will treat your data with the utmost care and take appropriate measures to protect it.
• Our business systems are protected by robust technologies and policies to ensure the personal information stored is suitably protected.
• We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage
• We secure all transactional areas of our website using https technology.
• Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone
• We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security
• Any personal data shared with hotels, coach operators and airlines is password protected.

9. How long will we keep your personal data

We will only keep your personal data for as long as necessary for the purpose for which it was collected. At the end of that retention period, your data will be deleted or anonymised so that it can be used in a non-identifiable way for analysis and business planning.

10. An overview of your different rights

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.
• Review by a Partner of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
• That we erase your personal data in certain circumstances. You may ask us to remove your personal data from our systems however this will only be done where we do not have any continuing lawful reason to continue to retain or process your personal data.
• You have the right to make a complaint to the data protection regulator in the UK about the use of your personal data where you believe your legal rights have been infringed, or where you believe your personal data has been used in a way which doesn’t comply with the law. We encourage you to contact us first and we will endeavour to seek to resolve any issues or concerns in the first instance. The contact details for the Information Commissioner’s Office are available on their website (www.ico.org.uk).

You can contact us to request to exercise these rights at any time as follows:

To ask about the information we hold about you can either

• email dpo@jgtravelgroup.com,
• write to The Data Protection Officer, JG Travel Group, 1st Floor, 111 High Street, Cheltenham, Gloucestershire, GL50 1DW or
• We will provide you with a request form to complete and, following proof of your identification, we will be able to answer your questions.

To simply ask for your information to be amended or preferences to be updated then please visit your online account or email us at dpo@jgtravelgroup.com

Social Media

Please view our social media policy here >>

Our organisation utilises Force24’s marketing automation platform.

Force24 cookies are first party cookies and are enabled at the point of cookie acceptance on this website. The cookies are named below:

F24_autoID

F24_personID

They allow us to understand our audience engagement thus allowing better optimisation of marketing activity.

f24_autoId – This is a temporary identifier on a local machine or phone browser that helps us track anonymous information to be later married up with f24_personid. If this is left anonymous it will be deleted after 6 months . Non-essential, first party, 10 years, persistent.

f24_personId – This is an ID generated per individual contact in the Force24 system to be able to track behaviour and form submissions into the Force24 system from outside sources per user. This is used for personalisation and ability to segment decisions for further communications. Non-essential, first party, 10 years, persistent.

The information stored by Force24 cookies remains anonymous until:

• Our website is visited via clicking from an email or SMS message, sent via the Force24 platform and cookies are accepted on the website.
• A user of the website completes a form containing email address from either our website or our Force24 landing pages.

The Force24 cookies will remain on a device for 10 years unless they are deleted.

Other Tracking

We also use similar technologies including tracking pixels and link tracking to monitor your viewing activities

Device & browser type and open statistics

All emails have a tracking pixel ( a tiny invisible image ) with a query string in the URL. Within the URL we have user details to identify who opened an email for statistical purposes.

Link Tracking

All links within emails and SMS messages sent from the Force24 platform contain a unique tracking reference, this reference help us identify who clicked an email for statistical purposes.

Our organisation also utilises the UniFida customer data platform.

UniFida uses Matomo cookies which track browsing behaviour to analyse marketing performance and to ensure that any marketing communications that we send are as relevant as possible.

 

Cookie name	Type	Description	Duration
_pk_id*	Browsing behaviour & analytics	This cookie is set to let Matomo and UniFida know the pages in a user’s route into, through and out of the website for a better understanding of media performance and user journeys - to personalise what you see on the Site or mobile app and to tailor any marketing communications that we send to you	392 days
_pk_ses*	Browsing behaviour & analytics	This cookie is set to let Matomo and UniFida know the pages in a user’s route into, through and out of the website for a better understanding of media performance and user journeys - to personalise what you see on the Site or mobile app and to tailor any marketing communications that we send to you	<1 Day
Henhed-piwik	Browsing behaviour & analytics	This cookie is set to let Matomo and UniFida know the pages in a user’s route into, through and out of the website for a better understanding of media performance and user journeys - to personalise what you see on the Site or mobile app and to tailor any marketing communications that we send to you	< 1 Day

We also use cookies from a company called Adalyser

This is an analytics platform that is used to measure response to TV advertising.

Cookie name	Type	Data Stored	Purpose
__adal_ca	Persistent	Traffic source and campaign data	Store which advertising campaign drove a user to visit
__adal_cw	Persistent	Visit timestamp	Tie back conversion events to earlier visits
__adal_id	Persistent	Device ID - generated	Uniquely identify a device