PRIVACY & TERMS OF USE
The following is a statement of the privacy policy of SOBI Travel & Events
At SOBI Travel & Events (“I”, “we”, “our”, “us”) we believe that you should always know exactly what kind of data we collect from you, how we use it, and that you should be empowered to make the best decisions about the information that you share with us.
We operate by the principles set out below. Do bear in mind that by using our website, contacting us by telephone or providing information to us in person, by way of email, post and social media, you agree to its terms.
What information do we collect?
The type of information we may collect about you will depend on the nature of your interactions with us. We collect personal information about you whenever you use our services (whether these services are provided by us or by other companies or agents acting on our behalf), including when you request information from us, book your travel arrangements with us, when you use our website or social media platforms, or interact with us in person, via telephone or email.
In addition, we may receive personal information about you from third parties, such as companies involved in your travel plans, including airlines and hotels.
Depending on the circumstances, we may collect:
- Personal information for you and those persons travelling with you;
- Title;
- Your full name;
- Postal address;
- Email address;
- Landline and mobile numbers;
- Passport information (including passport number, title, full name, gender, date of birth, place of birth, nationality, date of issue, date of expiry);
- Financial details and payment method (including card type, cardholder name, card number, start date, expiry date, security code, billing address);
- Details relating to any allergies, disability or a medical condition you may have;
- Dietary requirements, which may disclose your religious beliefs;
- Details of your travel arrangements with us;
- This includes whether you booked directly with us, where you choose to travel to, where you decide to stay, your preferences, travel dates, number of passengers travelling with you and any other information related to your travel with us;
- Your enquiry and purchase history with us;
- Information you choose to submit to us;
- Via the completion of forms, sending us details of your preferences, feedback or testimonials;
- By interacting with us on social media platforms;
- When taking part in any of our competitions;
- Details of the device you are using and how you use our website;
- What you view, click on and access when using our website and marketing emails. This might also include your IP address, geographical location, device information, browser and network type, length of visit and number of page views.
What about data about other people which you provide to us?
If you provide personal data to us about someone else you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy. You must ensure the individual concerned is aware of the various matters detailed in this notice.
How do we use your information?
We use your information for a number of different purposes, which includes to provide you with a service you request from us, to improve our services to you, to enhance your user experience, and to communicate with you.
- To complete and manage a booking you have made with us:
- We are required to use your information to handle your enquiries and deliver the services that you request or purchase from us. This includes arranging your flights, accommodation, ground arrangements and activities.
- Even if you have opted-out of receiving marketing or email communications from us, we may still send you important service communications and provide customer support for our services you are using.
- To help market our products and services to you:
- We may match details common to you across various sources of information, so that we may understand you and your preferences better.
- By knowing more about you, we can focus on those aspects we think are most likely to benefit and be of value to you and personalise your customer experience.
- We will use your information to send you marketing communications and keep you informed of our products and services we think might be of interest or relevance to you. We may send communications via direct mail, email, telephone and social media, or serve adverts via third-party companies.
– To enhance and develop our services as a travel provider:
- We may record and monitor calls and email communications, for the purposes of quality assurance, training and improving our service.
- Information about the way you use our website, will be used by us to review, develop and optimise our website, products and services.
- In order to better understand our customer base, we may carry out analysis and market research to tailor our business approach. This includes using your personal information to carry out profiling and segmentation to inform our market research and client demographics.
– For management and administrative purposes:
- We may retain your information for administrative purposes such as accounting and billing, auditing and gathering statistics for trading reports. This does not include information which can be used to identify you. We retain credit card receipts which includes the card number and expiry date only.
– To comply with our own legal obligations:
- For example health and safety legislation, or to assist in an investigation by law enforcement agencies.
– For your protection and safety:
- In the event of illness or injury or some other related emergency, where there is no time to gain your consent, we may be required to share your personal details to medical personnel.
The legal bases in which we will rely on to process the above are as follows:
- The processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data
- The processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract
- The processing is necessary for compliance with a legal obligation to which we are subject
- The processing is necessary in order to protect the vital interests of the data subject or of another natural person
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us
Who do we share your information with?
The information we collect when you use our website or services is confidential, however we may disclose your personal information to a third party in the following circumstances:
– Suppliers and vendors we work with that provide the services in connection to the provision of our services to you
- This can include for example, airlines, hotels, cruise companies, ground handling agencies, transport and car hire companies. Appropriate personal data will be shared with any relevant suppliers only where necessary for the purposes of booking your travel arrangements.
- This may include the transfer of information outside the European Economic Area (EEA).
- Your information will be sent for operational purposes only and will not be used for marketing communications.
– Government and law enforcement agencies
- We may be required by law to disclose information to government and public authorities such as customs, immigration and security services, or regulatory authorities, courts and legal agencies.
– Third party service providers and partners in connection with our business
- On occasion, we share information with service providers who support our business. This can include creative and digital agencies that assist with our marketing campaigns; distribution centres which provide services that involve data processing and delivery of our marketing collateral; and insights and analytics companies which specialise in data profiling and segmentation.
- We may also disclose data to external professional advisers such as accountants, bankers, insurances, auditors and lawyers.
- These agencies and partners must adhere to strict confidentiality obligations in a way that is consistent with this Privacy Policy and the agreements we enter into with them.
– Non-personally identifiable information;
- We may share non-personal, non-identifiable data with hotels, cruise companies, airlines and tourist boards when they take part in joint marketing activities with us. This may include aggregated information such as our dominant customer profiles, the number of times users have visited a particular page on the website, or engaged with specific marketing communications.
- We will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure and only uses it for the purposes of providing the agreed services. Our suppliers and service providers will not be permitted to use your personal information for their own marketing, unless you have consented to receive such communication directly with them.
How long do we keep your information?
Unless a longer retention period is required or permitted by law, we will only hold your personal information on our systems for the period necessary to fulfil the purposes set out in this Privacy Policy, or until you request for it to be erased.
We will periodically review the information we hold and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.
How do we protect your information?
Keeping your information secure is very important to us and we store and process your data in accordance with the high standards required under data protection legislation. We implement security measures which are intended to prevent unauthorised access or unlawful processing, and accidental loss or destruction of, or damage to, personal data.
We take great care to ensure the physical and digital security of our premises, equipment, devices and systems by implementing appropriate password protection and access restrictions. Access to your information is only granted to those that need to use it in the course of their work.
Your personal data may be stored, used and otherwise processed within the UK and/or any other country(ies) of the European Economic Area (EEA). For operational reasons, your personal information may also be stored or processed by some of our service providers, which operate outside of the EEA. Some of the data protection and security laws for these countries operate differently and may not be to the same level we have under EU legislation, however we shall take care to ensure that they have appropriate security measures in place and will take the steps necessary for compliance with the General Data Protection Regulation.
What are your rights?
In accordance with data protection legislation, as of 1 January 2019, you have the following rights:
- Right to be informed of the ways in which we use your information
- Right to access and receive a copy of your personal information being held, processed and to whom it may have been disclosed
- Right to correct inaccurate or incomplete personal information
- Right to request that we move, copy or transfer your personal information to another service provider
- Right to restrict or limit the way we use your information
- Right to object to our use of your personal information in certain circumstances
- Right to delete and remove your personal information from our systems
If you are looking for further details about your privacy rights, please refer to the Information Commissioner’s Office (ICO), which regulates data protection and privacy matters in the UK.
How can you manage your information and what are the opt-out options?
If you believe that any of your personal information we are holding is incorrect, incomplete or needs updating, please contact us by using the details under the “Contact” section on our website.
If you no longer wish to hear from us or would like to withdraw your consent in relation to profiling, you can opt out or unsubscribe by following the link contained in any marketing communications that you receive from us, or by sending us your name, full address and email to sonja@sonjabilli.com
We will comply with your requests unless we have a lawful reason not to do so. Please note that you cannot opt out from receiving all communications from us, including administrative messages and service status announcements, which are necessary when related to any enquiries or purchases made with us.
About us
SOBI Travel & Events Limited is a company which is registered in England and Wales under company number:11366520. For our registered address please refer to the contact details below.
Under EU and UK data protection laws, we are considered the “data controller” of the personal information that we collect, use and process in connection with this Privacy Policy.
If another company has provided an element of your enquiry or booking separately from us, such as an airline, hotel or cruise company, they too will be a “data controller” and you can access the separate privacy policies of those providers from them directly.
For any information requests, notification of incorrect data, questions or comments concerning this Privacy Policy, please contact us at:
Sonja Billi
Owner and Managing Director
SOBI Travel & Events
302 Old Brompton Road
London, SW59JF - UK
sonja@sonjabilli.com
By accepting this policy statement you consent to the use (including processing and storage), transfer and disclosure of your information and data referred to in this policy statement for the purposes set out above.
Last updated: January 2019
Changes to this policy
We may occasionally revise this Privacy Policy. The most current version of the policy will govern our processing of your personal data and can be found at www.sonjabilli.com. If we make any changes to this policy, we will notify you via a notification on our website or an email to the email address you have provided to us. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised Privacy Policy.