At Beyond Business Travel we take your privacy seriously and we are committed to protecting your personal data. We aim to be clear about how we use personal data and this privacy notice will inform you as to how we look after your personal data, what personal data we process and why. It includes the relevant requirements of the General Data Protection Regulation. It applies both when you visit our website (regardless of where you visit it from) and when you use our services.
This privacy notice will give you information about:
1. Who we are and who is responsible for your personal data
2. Where you can contact us if you have any questions about how your personal data is processed by us
3. What types of personal data we process and where we get that personal data from
4. How we use your personal data and what our legal basis for doing so is
5. Who we disclose your personal data to and why
6. Whether we transfer any of your data internationally
7. How we store your data securely
8. How long we hold your personal data for
9. Your rights to complain and how you go about making a complaint
10. The Glossary
Changes to This Data Protection Notice
Like any business, our business will change over time and so will the way we use and protect your personal data. As a result, we may need to make changes to this General Data Protection Notice. These changes will not reduce your rights or the level of protection we apply to your personal information. The most up to date General Data Protection Notice will always be published on our website and we will clearly identify the changes we have made in any updates. You can contact us anytime via https://beyondbusinesstravel.com/ or telephone 028 908 50615 or email GDPR@beyondbusinesstravel.com.
Important information and who we are
This privacy notice aims to give you information on how Beyond Business Travel collects and processes your personal data through your dealings with us, including your use of this website or when you use any service we offer.
This website is not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Beyond Business Travel is the controller and responsible for your personal data (collectively referred to as “Beyond Business Travel”, “we”, “us” or “our” in this privacy notice). When we refer to Beyond Business Travel we mean:
Beyond Business Travel
Address: 3 Scottish Provident Building, 7 Donegall Square West, Belfast BT1 6JH
Telephone: 028 9085 0615
Where you can contact us if you have any questions about how your personal data is processed by us
We have appointed a Data Protection Officer who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Protection Officer at GDPR@beyondbusinesstravel.com or telephone 028 9085 0615.
What types of personal data we process, where we get that personal data from
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may need to collect, use, store and transfer various kinds of personal data about you which we have grouped together as follows:
• Personal Data includes first name, last name, title, date of birth and gender.
• Contact Data includes address, company name, email address and telephone numbers.
• Travel Data includes travel itinerary details, passport information, form of payment, airline card, preferences and any other information shared with us to assist with travel plans.
• Marketing and Communications Data includes your preferences in receiving marketing from us.
We also collect, use and share Aggregated Data such as statistical data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data) unless we have your explicit consent to do so. Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data we may not be able to perform the contract we have or are trying to enter with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through: Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• Use our services;
• Participate in our events;
• Give us some feedback.
Automated technologies or interactions: As you interact with our website, we may automatically collect Technical Data about your browsing actions. We collect this personal data by using cookies.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Personal data will normally be part of a travel itinerary and is required to process the reservation and issue relevant tickets and provide other travel related services;
• Enhanced customer service;
• Fulfil customer requests;
• Provide accurate call reporting, data analysis;
• Manage support queries;
• Invoicing purposes;
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
• Where we need to comply with a legal or regulatory obligation.
To make suggestions and recommendations to you about services that may be of interest to you:
• Necessary for our legitimate interests (to develop our products/services and grow our business)
In accordance with the obligations that data must be adequate, relevant and limited to what is necessary for the purposes for which it is processed, we do not collect any data which is not necessary for it to fulfil its contractual obligations. It does not collect data for a general or unspecified future use.
The requirement for personal data to be accurate and kept up to date, is dependent on clients notifying us of changes to the data which it has previously provided. There are requirements in the relationship with both parties that the data provided to us is accurate. We will not be able to tell without notification where information has changed. Upon notification of changes, we will erase or rectify data immediately.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
We will never sell your personal data or share it with third parties who might use it for their own purposes.
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Data Sharing: who we disclose your personal data to and why
• Suppliers, service providers and employees of The Company;
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
• We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
• If necessary: (a) under applicable law including laws outside your country of residence; (b) to comply with legal processes; (c) to respond to requests from public and government authorities including public and government authorities outside your own country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect yours and our own rights, privacy, safety or property; (g) to permit us to pursue available remedies or limit the damages we may sustain.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented:
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
How we store your data securely
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
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.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
In some circumstances you can ask us to delete your data.
What rights you have in relation to your personal data and how you can exercise these rights
We want to ensure you remain in control of your personal data. Part of this is making sure you understand your legal rights, which (for individuals) are as follows:
• the right to confirmation as to whether or not we have your personal data and, if we do, to obtain a copy of it (this is known as a subject access request);
• the right to have inaccurate data rectified; and
• the right to object to your data being used for marketing or profiling.
If you would like further information on your rights or wish to exercise them, please write to: The Data Protection Officer, Beyond Business Travel, Scottish Provident Building, 7 Donegall Square West, Belfast BT1 6JH or email: GDPR@beyondbusinesstravel.com You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond: We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. Please keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so. If you are not happy with our response, or you believe that your data protection or privacy rights have been infringed, you should contact the UK Information Commissioner’s Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues: www.ico.org.uk. Address: Information Commissioner’s Office, 3rd Floor, 14 Cromac Place, Belfast, BT7 2JB Tel: 028 9027 8757 or 0303 123 1114 Email: firstname.lastname@example.org.
We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.