Privacy Policy

PACKS Travel Ltd

Company Number 14371910

124 City Road, London, EC1V 2NX, United Kingdom

01 Jan 2024

Introduction

1.1 Important information and who we are

Welcome to .where2's Privacy and Data Protection Policy (“Privacy Policy”).

At PACKS Travel Ltd (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process, and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

Customers
Suppliers
Business contacts
Employees/Staff Members
Third parties connected to your customers
and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2 Your Data Controller

PACKS Travel Ltd is your Data Controller and responsible for your Personal Data. We are not obliged by the GDPR to appoint a data protection officer and have not voluntarily appointed one at this time. Therefore, any inquiries about your data should either be sent to us by email to info@packs.travel or by post to 124 City Road, London, EC1V 2NX, United Kingdom.

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). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3 Processing data on behalf of a Controller and processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). The responsibilities below may be assigned to an individual or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information);
Ensure that Processors authorized to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
Implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
Obtain the prior specific or general authorization of the Controller before engaging another Processor;
Assist the Controller in the fulfilment of the Controller's obligation to respond to requests for exercising the data subject's rights;
Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
Maintain a record of all categories of processing activities carried out on behalf of a Controller;
Cooperate, on request, with the supervisory authority in the performance of its tasks;
Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller; and
Notify the Controller without undue delay after becoming aware of a Personal Data Breach.

2 LEGAL BASIS FOR DATA COLLECTION

2.1 Types of data / Privacy policy scope

“Personal Data” 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 collect, use, store, and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect and when we collect it from you:

Profile/Identity Data: Data relating to your first name, last name, gender, and date of birth.
Contact Data: Data relating to your phone numbers, addresses, email addresses, and phone numbers.
Marketing and Communications Data: Your preferences in receiving marketing information and other communications from us.
Technical Data: Your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
Customer Support Data: Includes feedback and survey responses.
Usage Data: Information about how you use our website, products, and services.
Aggregated Data: We also collect, use, and share Aggregated Data such as how often users claim certain offers and the type of offers they claim. Although Aggregated Data may be derived from your Personal Data, it is not considered Personal Data in law as this data will 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 Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents, and current and prospective business partners.

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). Nor do we collect any information about criminal convictions and offences.

This section reflects the necessary updates to align with the services provided by .where2 under the umbrella of PACKS Travel Ltd, ensuring clarity and compliance with data protection regulations, specifically addressing the types of personal data collected and processed through the .where2 app or services.

2.2 The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

“Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
“Contractual Obligations”: We may require certain information from you in order to fulfill our contractual obligations and provide you with the promised service.
“Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
“Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests - this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom, or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3 HOW WE USE YOUR PERSONAL DATA

3.1 Our data uses

We will only use your Personal Data when the law allows us to.

Set out below is a description containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed below.

Examples provided below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact us.

Activity 1

When a user signs up

Type of data:

Profile/Identity Data
Contact Data
Marketing and communications Data
Technical Data
Customer Support Data
Usage Data

Legal Justification:

Consent

Lawful basis for processing data

When signing up the user agrees to the terms of this privacy policy. As a highly personalisable and curated platform, we need to process this data to tailor the content to each individual user, their location and interest.

Activity 2

When a user creates an activity

Type of data:

Contact Data

Legal Justification:

Consent

Lawful basis for processing data

During the process of creating an activity, the user verifies their phone number and agrees for it to be visible to others whose requests to join were accepted by said user.

Activity 3

When a user activates a voucher or claims a perk

Type of data:

Usage Data

Legal Justification:

Legitimate Interest
Research

Lawful basis for processing data

As a curated marketplace that relies on first-hand user feedback, we need to process this data to know what offers perform best and which b2b partnerships we need to review or terminate.

Activity 4

When a user activates their safety kit

Type of data:

Profile/Identity Data
Contact Data

Legal Justification:

Consent

Lawful basis for processing data

We need to process this data so that we and other users know who to contact in case of an emergency

Activity 5

When a user deactivates their account

Type of data:

Technical Data
Customer Support Data
Usage Data

Legal Justification:

Legitimate Interest

Lawful basis for processing data

We need to process this data in order to improve our product and offerings

3.2 Marketing and content updates

You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about goods or services that may be of interest to you.

3.3 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.

YOUR RIGHTS AND HOW YOU ARE PROTECTED BY US

4.1 Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

Right to be informed. You have a right to be informed about our purposes for processing your personal data, how long we store it for, and who it will be shared with. We have provided this information to you in this policy.
Right of access. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it (also known as a "data subject access request"). See section 4.5 below for more details on how you can make a data subject access request.
Right to rectification. You have a right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Right to erasure. You have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Right to object. You can object to the processing of personal data we hold about you. This effectively allows you to stop or prevent us from processing your personal data. Note that this is not an absolute right and it only applies in certain circumstances, for example:
(i) Where we are processing your personal data for direct marketing purposes.
(ii) Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
(iii) In some cases, we may continue processing your data if we can demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Right to restrict processing. You have the right to request the restriction or suppression of their personal data. Note that this is not an absolute right and it only applies in certain circumstances:
(i) If you want us to establish the data's accuracy.
(ii) Where our use of the data is unlawful but you do not want us to erase it.
(iii) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
(iv) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Right to data portability. You have the right to request the transfer of your personal data to you or to a third party. If you make such a request, we will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

If you wish to make a request under any of these rights, please contact us at info@packs. travel.

4.2 Your control over PACKS Travel Ltd’s use of your Personal Data

You may delete your account at any time – this will remove your account page from our systems and our related software.

We guarantee this will delete all stored data.

You can access information associated with your account by logging into your account you created with us.

Your account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and by signing off after you have finished accessing your account.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to info@packs.travel.

4.3 How PACKS Travel Ltd protects customers' Personal Data

We prioritize the security of your data and are committed to protecting it from inappropriate disclosure. Only a limited number of employees, who have special access rights and are bound by confidentiality obligations, can access Personal Data collected by us. When employing subcontractors to store data, we ensure control over your Personal Data is not compromised, nor exposed to security risks that wouldn't exist if the data remained under our direct control. Despite our efforts, no data transmission over the internet can be guaranteed as completely secure. There is always a risk of unauthorized access by third parties not under the control of PACKS Travel Ltd. We strive to protect your Personal Data, but cannot guarantee its absolute security during transmission to us. If you have concerns about the security of your interactions with us, please reach out immediately.

4.4 Opting out of marketing promotions

You have the option to stop receiving marketing communications from us at any time by clicking the unsubscribe link at the bottom of our emails. Opting out of marketing messages will not affect the storage of Personal Data provided to us through other interactions unrelated to your marketing preferences.

4.5 How to request your data and the process for obtaining it

Accessing your Personal Data, or exercising any of your rights, will not incur a fee. However, if your request is unfounded, we reserve the right to refuse compliance. To confirm your identity and ensure your right to access the data or exercise your rights, we may request specific information from you. This is a security measure to prevent unauthorized disclosure of your Personal Data. We might also contact you for more information regarding your request to expedite our response.

YOUR DATA AND THIRD PARTIES

5.1 Sharing your data with third parties

Non-Personal Data may be shared with third parties. Your Personal Data, however, may be shared with subcontractors or affiliates under strict confidentiality obligations and only for the purposes for which it was disclosed to them, according to our instructions.

In the event of a change in control, acquisition of our business or assets, or in connection with the licensing of our technology, we may share Personal Data with involved parties. Should PACKS Travel Ltd be sold or undergo a sale or transfer, we reserve the right, at our discretion, to transfer, sell, or assign your Personal Data to a third party as part of or in connection with that transaction. Following such a transfer, the privacy policy of the acquiring entity will apply to your Personal Data. In any case, your data will remain protected under this Privacy Policy as it may be amended.

Your Personal Data may also be shared if required for legal reasons or to enforce our terms or this Privacy Policy.

5.2 Third-Party Links

Our Site may include links to third-party websites, plug-ins, and applications. Interacting with these links or enabling those connections may allow third parties to collect or share data about you. We do not have control over these third-party websites and are not responsible for their privacy practices. We advise you to read the privacy policy of every website you visit after leaving our Site to ensure you are informed about how your data may be used.

HOW LONG WE RETAIN YOUR DATA

We will retain your Personal Data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. In some instances, we may retain your Personal Data for a longer period, particularly in the case of a complaint or if we reasonably believe there is a potential for litigation in relation to our relationship with you.

INTERNATIONAL TRANSFER OF DATA

Your information, including Personal Data, may be transferred to—and maintained on—computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. Specifically, if PACKS Travel Ltd has facilities in the US or other countries or jurisdictions outside the US, your information may be processed there. By using our services, you consent to the transfer of your information, including Personal Data, outside of the US.

NOTIFICATION OF CHANGES AND ACCEPTANCE OF POLICY

We regularly review our Privacy Policy and will post any updates on this web page. This policy was last updated on 20 December 2022. Your continued use of PACKS Travel Ltd services after any changes or revisions to this Privacy Policy signifies your agreement with the terms of the newly updated or revised policy.

INTERPRETATION

The word "including" is used extensively throughout this document to mean "including, but not limited to," for the purpose of providing examples that should help clarify statements made. Email addresses mentioned in this policy should be used only for the stated purposes, and any unrelated inquiries will likely not be answered. Our policy is to avoid responding to emails that do not pertain to legitimate business inquiries or concerns that have been specifically addressed through the provided contact information.

Employees of PACKS Travel Ltd are not authorized to make any representations or commitments on behalf of the company beyond what is stated in official documents or through authorized channels. Any communication received from an email address associated with PACKS Travel Ltd that contradicts this policy, our terms of service, or any other official communication will be overridden by the official, published documents and statements. The only exception to this rule is communication that is explicitly identified as coming from the legal department of PACKS Travel Ltd.

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