This policy sets out the basis on which XO Travel. Company Registration Number 15956472 together with our subsidiaries, from time to time, collectively called XOTravel or “we”) collects personal data from you and how we process such data.

Collection of information

• For the purposes outlined in Clause 2, we may collect and process the following about you:
• Information you give us – information that you provide us (which may include your name, address, email address, telephone number and other personal description) by filling in forms on our Site or when you use certain features on our Site.
• Information we collect about you – information automatically collected when you visit our Site, for example

1) Technical information, including the Internet Protocol (IP) address used to connect your computer to the internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

2) Information about your visit, including the full Uniform Resource Locators (URLs), click stream to, through and from our site (including the date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

• We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists:
• Information gathered through the on line job application process will be held for a minimum of 12 months unless otherwise instructed.
• Information gathered via website enquiry/use will be held for a minimum of 6 months unless otherwise instructed.
• Data retention will be support of ongoing business relationships or where specific permissions have been given by the donor.

Uses of information

a) We use information held about you for the following purposes:

• Providing, improving and developing our services;
• Researching, designing and launching new features or products;
• Presenting content and information in our Site in the most effective manner for you and for the device you use;
• Providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
• For direct marketing purposes (please see further details in Clause 2.b below);
• Communicating with you and responding to your questions or requests; and
• Purposes directly related or incidental to the above.

b) We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:

• The personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 1.a. above;
• The type of services or products that may be offered or advertised will be Our Services and Expertise and those of our associated companies;
• The relevant information may be sent to you by email, phone or given at conferences and events;
• You may opt out any time by email viagdpr@skylordtravel.comor by clicking the unsubscribe tab on the website. We will cease to send you marketing information without charge.

Disclosure of your information

We will keep your personal data we hold confidential, but you agree we may provide information to:

• Any member of our group, which means our subsidiaries or associated companies defined in section 1159 of the Companies Act 2006;
• Persons under a duty of confidentiality to us;
• Persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world.

Cookies

• Our site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
• A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.
• We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site. Session cookies only last for as long as the session (usually the current visit to a website or a browser section). No PII is collected by cookies used on this website.
• We use the following cookies:
• Analytical/performance cookies – they allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies – these are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies – these cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.
• We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies) web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

Security

• All information you provide to us is stored on our secure servers.
• We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
• We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
• Please note, however, 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.

Data transfer

• The data that we collect from you may be transferred to, and stored at, a destination outside England and Wales. It may also be processed by persons referred to in Clause 3 above who operate outside England and Wales.
• By submitting your personal data you agree to this transfer, storing or processing of data outside England and Wales. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy policy.

Your rights

• You have the right to:
• To be informed whether we hold personal data about you.
• Access any information/personal data we hold about you.
• Require us to correct any inaccuracy or error in the data we hold about you.
• To have the data erased.
• Restrict processing.
• To data portability.
• Object about data being held.
• In relation to automated decision making and profiling.

If you have any questions, comments or requests regarding personal data please address them to: Privacy Officer
Email Address: enq@skylordtravel.com
Tel; 020 3875 5430
The Green House

18 Wadsworth Road Perivale UB6 7JD