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Privacy Policy

Last updated: Nov 19, 2015


1. About This Document

This document sets out our privacy policy in respect of customer personal data, which will govern the way in which we process any personal data that you provide us with. It serves as an expression of our commitment to protecting your private personal information, but is not a contract. Please see Section 18 below for the rights which the law provides you with in relation to your personal data.


2. Your Consent

This Privacy Policy is incorporated into and forms part of our Terms of Use, which outline the terms and conditions you agree to when accessing and using this website. By accessing and using this website and providing personal information to us, or by booking any travel services with us, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy.


3. Copyright Notice

This document, and all content of our websites is Copyright© [2015 INSIGHT VACATIONS LTD]. ALL RIGHTS RESERVED.


4. About Us

This is the privacy policy of [Insight Vacations Ltd (referred to as "we", "us" or "our"). We are incorporated under the laws of [IRELAND. Our incorporation number is 2TA001564 and our incorporation address or registered office is Travel House,Rue De Manoir, St Peter Port, GuernseY, GY12JH. We are a member of the Irish Travel Agent Association (ITAA) and licensed and bonded by the Civil Aviation Authority Licence Number TA0713.


5. Contacting Us

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail to reservations@insightvacations.com, telephone on 01 775 3803 or by post to 27, Merrion Square North, Dublin 2, Ireland.


6. Our Commitment

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data that you entrust to us.


7. Who Our Privacy Policy Covers

7.1 Our customers Our privacy policy sets out how we process personal data (including information) relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.


7.2 Examples of who this policy covers We include in this privacy policy personal data we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and tour group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).


7.3 When we are a data processor only Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data.


7.4 Terms used in this policy When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.


8. What Laws We Comply With

We process your personal data in accordance with the following data protection law(s): EUROPEAN COMMUNITIES (ELECTRONIC COMMUNICATIONS NETWORKS AND SERVICES) (PRIVACY AND ELECTRONIC COMMUNICATIONS) REGULATIONS 2011 (which covers, among other things, the use of telephone numbers, fax numbers and e-mail addresses for unsolicited direct marketing).] Our regulator is Commission for Comunications Regulator www,comreg.ie We also comply generally with the laws of Europe in relation to the processing of your personal data, and not any other laws.


9. What Types Of Personal Information We Process

This section summarizes the types of personal information about you that we collect, use, and disclose:-

9.1 Data concerning you as an individual
This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, and utility bills, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you (such as to verify you identity, address, and credit status), your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

9.2 Business Related Information If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

9.3 Enquiry and Booking Information Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other data relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

9.4 Performance Information Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

9.5 Survey Information Information collected or generated out of any surveys we conduct.

9.6 Competition Information Information collected or generated out of any competitions or promotions we run.

9.7 Account, Registration and Loyalty Information
Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

9.8 Correspondence Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

10. How We Collect Or Generate Your Personal Information

This section sets out the ways in which we may collect or generate personal information concerning you.

10.1 Visiting our website By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

10.2 Data you provide Your personal information will include data you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

10.3 Data obtained from third parties We may obtain personal information concerning you from third parties, including from: providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

10.4 Data generated by us We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or data gained from your use of our website. We may record telephone calls with you.


11. What Do We Use Your Personal Information For?

This section sets out the uses which we make of your personal data:

11.1 Operate our website To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

11.2 Provide information and respond to enquiries To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

11.3 Bookings and other contracts To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to collect, use, and disclose any transactions authorised or made with us which relate to you.

11.4 Payments To collect and make payments due and administer our accounts.

11.5 Communication with customers To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

11.6 Record keeping To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

11.7 Manage and Improve our business To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

11.8 Direct marketing To carry out direct marketing to you. See next section below for further information.

11.9 Advertising To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

11.10 Anything you have specifically consented to For any purpose which we have obtained your consent to.


12. Use Of Your Personal Information For Direct Marketing

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

12.1 Direct marketing by us Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal data to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

12.2 Direct marketing by third parties Where you have expressly consented to this, we may disclose your personal information which is contact data (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, advertisments and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.


13. Disclosure Of Your Personal Data

We disclose your personal data to third parties in the following circumstances:-

13.1 Credit Checks etc.
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

13.2 Bookings and performance of contracts
We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

13.3 Suppliers of travel and other services
We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

13.4 Insurance
If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

13.5 Business Function Outsourcing
Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

13.6 Public Forums etc.
Where any facility on our website is clearly designed to make certain of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

13.7 Legal Requirements
We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

13.8 Direct Marketing by third parties
We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

13.9 Customer Representatives
If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.


13.10 Business Acquirers If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.


14. How Third Parties Will Handle Your Personal Data

Where we provide your personal information to a third party one of the following two circumstances will apply:-

14.1 Processing on our behalf
In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

14.2 Processing on their own account
In other cases, your personal information may need to be provided to them to be held and collected, used or disclosed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.


15. Location Of Your Personal Information

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise collect, use and disclose that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.


16.   Keeping Your Data Secure

16.1 Our security measures

16.1.1 Our general commitment
We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful collection, use and disclosure of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

16.1.2 Transmissions between your web browser and our servers
We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

16.1.3 Storage of your personal information
The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

16.2 Your security measures
For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.


17. How Long Do We Keep Your Personal Data For?

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.


18. Your Rights

18.1 Access to your personal data
You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold. We may charge a fee for handling your request, in an amount prescribed by law. This fee is €15 as at the date of this policy.  The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

18.2 Use causing substantial distress or damage
You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

18.3 Use for direct marketing
You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

18.4 Correction of inaccuracies
You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

18.5 Compensation
You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.


18.6 Complaints to applicable authority
The laws we comply with are regulated by [the Commission for communication Regulator (www.comreg.ie) in Ireland.  In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator, who has powers to compel us to comply with applicable laws and fine us for non-compliance.  However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.  


19. Changes To This Privacy Policy

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes. You should check the top of the document to see the latest version in force. Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.


20. Applicable Law And Disputes

This policy is subject to the law of Ireland and you must bring any claims against us exclusively in the courts of Ireland.