Uniglobe Gemini Travel Privacy Protection Policy

1. Scope

All data subjects whose personal data is collected, in line with the requirements of the GDPR.

2. Responsibilities

2.1 The GDPR Owner is responsible for ensuring that this notice is made available to data subjects prior to Uniglobe Gemini Travel collecting/processing their personal data.

2.2 All Employees/Staff of Uniglobe Gemini Travel who interact with data subjects are responsible for ensuring that this notice is drawn to the data subject’s attention and their consent to the processing of their data is secured.

3. Privacy notice

3.1 Who are we?

Uniglobe Gemini Travel is the legal trading name of Hardy & Hewett ltd. We are a Travel Management Agency servicing clients in the corporate & leisure spaces.

Our GDPR Owner and data protection representatives can be contacted directly here:

gdpr@uniglobegemini.co.uk

01784 254 850

• The personal data we collect will be used for the following purposes:
• Booking business trips with modes of transport such as trains, flights, hotels, car hire, conferences and events
• Responding to queries and complaints
• Communicating travel related incidents that would impact upon your planned business travel
• Processing of payments
• The possible use of your IP address to recover interest in our services and product offerings
• We may use your details to communicate new and innovative technology offerings to better your current solutions. We do this on the grounds of legitimate business interest, however you’re free to opt out at any time.

Our legal basis for processing for the personal data:

Contract ➢ Example, making and completing a travel booking request

Vital Interests ➢ Travel alerts and anything pertaining to your business trips which may affect your safety and security.

Consent ➢ Anything pertaining to direct consumer-based marketing.

Any legitimate interests pursued by us, or third parties we use, are as follows:

Marketing to our business customers regarding innovative technology advancements and anything that may better their current solution.

We do not process any special categories of data

3.2 Consent By consenting to this privacy notice you are giving us permission to process your personal data specifically for the purposes identified. Where we are asking you for sensitive personal data we will always tell you why and how the information will be used.

You may withdraw consent at any time by clicking on the unsubscribe link on our marketing notices. You can also contact us by phone, email or letter. All details of which can be found on the Uniglobe Gemini Travel website.

3.3 Disclosure Uniglobe Gemini Travel will pass on your personal data to third parties only for the purposes of finalizing and booking a trip requested by yourself, or your organisation. During the booking process, you will be aware of any third partner we’re planning to book with, as normally, this is confirmed by yourself or your organisation ahead of booking

3.4 Retention period Uniglobe Gemini Travel will process personal data for the length of any given contract with the organization we’re booking for. After which, we will then keep and store data for a further 7 years which falls in line with our obligations within the industry we operate.

3.5 Your rights as a data subject At any point while we are in possession of or processing your personal data, you, the data subject, have the following rights:

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply to have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right to be subject to the legal effects of automated processing or profiling.

Right to judicial review: in the event that Uniglobe Gemini Travel refuses your request under rights of access, we will provide you with a reason as to why. You have the right to complain as outlined in clause 3.6 below.

All of the above requests will be forwarded on should there be a third party involved (as stated in 3.4 above) in the processing of your personal data.

3.6 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Uniglobe Gemini Travel (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Uniglobe Gemini Travel’s data protection representatives GDPR Owner.

The details for each of these contacts are:

4. Online privacy statement

Personal data

Under the EU’s General Data Protection Regulation (GDPR) personal data is defined as:

“any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

How we use your information

• This privacy notice tells you how we, Uniglobe Gemini Travel, will collect and use your personal data for:
• Booking business trips with modes of transport such as trains, flights, hotels, car hire, conferences and events
• Responding to queries and complaints
• Communicating travel related incidents that would impact upon your planned business travel
• Processing of payments
• The possible use of your IP address to recover interest in our services and product offerings
• We may use your details to communicate new and innovative technology offerings to better your current solutions. We do this on the grounds of legitimate business interest, however you’re free to opt out at any time.

Why does Uniglobe Gemini Travel need to collect and store personal data?

In order for us to provide you with a service we need to collect personal data to plan and book business travel service efficiently. We also use this data to provide robust and intuitive reports, which can be obtained by the client directly or by ourselves in house. In any event, we are committed to ensuring that the information we collect and use is appropriate for this purpose, and does not constitute an invasion of your privacy.

Will Uniglobe Gemini Travel share my personal data with anyone else?

We may pass your personal data on to third-party service providers contracted to Uniglobe Gemini Travel in the course of dealing with you. Any third parties that we may share your data with are obliged to keep your details securely, and to use them only to plan and book business travel, for the businesses and individuals we service. When they no longer need your data to fulfil this service, they will dispose of the details in line with Uniglobe Gemini Travel’s procedures. 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.

How will Uniglobe Gemini Travel use the personal data it collects about me?

Uniglobe Gemini Travel will process in the following ways:

How we collect your data?

➢ When you request information for travel services

➢ From an agent

➢ Family member

➢ Employee

➢ Authorized representative

➢ Personal travel profiles

➢ Online booking portal

• How we store your data?

➢ Internal corporate servers (encrypted)

➢ Third party service providers

• How we secure your data?

➢ All personal date is secured within an encrypted system

➢ All online systems (booking and reporting tools) use HTTPS technology

➢ All portals for these reporting and booking functions are username and password protected

➢ Regularly monitor and assess systems for vulnerability and cyber attacks

• How long we retain your data?

➢ Uniglobe Gemini Travel will process personal data for the length of any given contract with the organization in question.

➢ After which, we will then keep and store data for a further 7 years which falls in line with our obligations within the industry we operate.

The information you provide in a manner compatible with the EU’s General Data Protection Regulation (GDPR). We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. Uniglobe Gemini Travel 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.

Under what circumstances will Uniglobe Gemini Travel 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 measures and procedures to minimize the risk of unauthorized access or disclosure.

• We will contact to inform you on travel related news pertaining to the individuals trip.

• We’ll inform you of new and innovative solutions that may better your current solution, which you can always opt out of receiving if you so wish

• We will send booking confirmations

• We will send you itineraries for confirmed trips

• We will contact you for payment or financial request.

• We will contact you to make you aware of any changes to our business, these may include change of address

• We may contact you in order to follow up from a complaint made by you, or a member of your organization

• We will reach out to you annually to ask you to complete our customer survey

Can I find out the personal data that the organisation holds about me?

Uniglobe Gemini Travel at your request, can confirm what information we hold about you and how it is processed. If Uniglobe Gemini Travel does hold personal data about you, you can request the following information:

• Identity and the contact details of the person or organisation that has determined how and why to process your data. In some cases, this will be a representative in the EU. • Contact details of the GDPR Owner where applicable.

• The purpose of the processing as well as the legal basis for processing.

• If the processing is based on the legitimate interests of Uniglobe Gemini Travel or a third party, information about those interests.

• The categories of personal data collected, stored and processed.

• Recipient(s) or categories of recipients that the data is/will be disclosed to.

• If we intend to transfer the personal data to a third country or international organisation, information about how we ensure this is done securely. The EU has approved sending personal data to some countries because they meet a minimum standard of data protection. In other cases, we will ensure there are specific measures in place to secure your information.

• How long the data will be stored.

• Details of your rights to correct, erase, restrict or object to such processing.

• Information about your right to withdraw consent at any time.

• How to lodge a complaint with the supervisory authority.

• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.

• The source of personal data if it wasn’t collected directly from you.

• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing.

What forms of ID will I need to provide in order to access this?

Uniglobe Gemini Travel accepts the following forms of ID when information on your personal data is requested:

➢ Passport

➢ Driving Licence or proof of address We will only keep these details as verification for subject access request, after which, it will be deleted. Your subject access request will be recorded in our subject access request log

4.1 Complaints

In the event that you wish to make a complaint about how your personal data is being processed by Uniglobe Gemini Travel (or third parties as described in 3.4 above), or how your complaint has been handled, you have the right to lodge a complaint directly with the supervisory authority and Uniglobe Gemini Travel’s data protection representatives GDPR Owner.

The details for each of these contacts are:

Document Owner and Approval

The GDPR Owner is the owner of this document and is responsible for ensuring that this record is reviewed in line with the review requirements of the GDPR.

A current version of this document is available to all members of staff internally and is published at www.uniglobegemini.co.uk/privacy-policy/

Signature: M.Hewett                  Date:25.05.2018