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TGM SNOWSPORTS LIMITED – PRIVACY POLICY

TGM Snowsports Ltd is a company registered in England and Wales whose registered address is 35 St Davids Road South, St Annes On Sea, Lytham St Annes, Lancashire, FY8 1TJ (“we”, “us”, “our”) and is committed to protecting the privacy and security of personal information.  This privacy policy outlines how we use the information that we collect from you as one of our customers or through your use of our website.  It makes you aware of how and why personal information will be used, namely for the purposes of the performance of our contract with our customers and how long it will usually be retained for.  It provides you with certain information that must be provided under the General Data Protection Regulation ((EU) 2016/679) (GDPR).

This policy primarily covers how we use information relating to our customers and users of our website.  It is important that you read this policy, together with any other privacy notice or privacy policy we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information.

Our legal status

We are a “data controller” for the purposes of the Data Protection Act 2018 and the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) whilst providing our services to customers and users of our website.

What information is collected from customers and website users?

We collect and process the following personal information about customers, prospective customers and users of our website:

  • Contact details such as your name, address, telephone numbers and email address;
  • Contact details of all travellers for group bookings;
  • Your date of birth and gender;
  • Bank and transaction details such as details about payments to and from you and any regular payments you arrange to pay to us;
  • Details of your travel preferences and previous travel arrangements, such as holidays and any other purchases;
  • Records of your correspondence with us, either through our website or by telephone, e-mail or post; and
  • Details of your use of our website including, but not limited to, cookies, traffic data, location data and other communication data and the resources and services that you access via the website.

Special categories of personal data

We may sometimes need to collect the following “special categories” of sensitive personal data from our customers.  This may include:

  • Information relating to health, medical conditions, allergies, medication, disabilities and special requirements of children or adults travelling with us.

We will use information about physical or mental health, or disability status, to ensure your health and safety when travelling with us and to make any necessary adjustments.  We need to process this information to exercise and perform obligations in connection with our contract with you and our health and safety obligations.

Where do we collect your information from?

Most of the information we collect will come directly from our customers and website users.  Where you provide to us personal details of other individuals you are booking travel on behalf of, you must be sure that they agree to their information being provided to us for that purpose.

How do we collect your information?

We will collect personal information through different methods including:

  • Direct interactions with you via our website, telephone, email or otherwise;
  • Through the service we provide to our customers; and
  • Automated technologies or interactions. As users interact with our website, we may automatically collect technical information about your equipment, browsing actions and patterns.

How we will use information about you:

We need all the categories of information in the list above (see What information we collect from our customers and website users above) primarily to allow us to perform our contract with our customers and to enable us to comply with our legal obligations. In some cases, we may use your personal information to pursue legitimate interests of our own or those of third parties, provided your interests and fundamental rights do not override those interests. The situations in which we will process your personal information are listed below:

  • To interact with our customers and take steps to enter into a contract;
  • To carry out our obligations arising from any contract entered into with our customers;
  • To manage our relationship with our customers;
  • To ensure that content on our website is presented in the most effective manner for users;
  • Where you agree, to provide you with information, products or services that you request from us or which we feel may interest you;
  • To allow you to participate in interactive features of our services, when you choose to do so;
  • To notify you about changes to our services or to our website; and
  • To operate and improve the website.

We will only use personal information for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  If we need to use personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Why do we need this information?

We will only use personal information when the law allows us to. Most commonly, we will use personal information in the following circumstances:

  1. Where we need to perform a contract we are about to enter into or have entered into with customers and prospective customers.
  2. Where we need to comply with a legal obligation.
  3. 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.
  4. Where we have obtained your consent (for example to send third party direct marketing communications to you via email or text message). You have the right to withdraw consent to such marketing at any time.

Our marketing communications

We may use the personal information of customers and users of our website to contact you to inform you about services we believe might be of interest to you via email or text message (we call this marketing communications).  Users of our website may receive marketing communications from us unless you have opted out or unsubscribed to receiving that marketing.

You can ask us to stop sending you marketing communications at any by following the unsubscribe links on any marketing communications sent to you or by contacting us at any time.

Where you opt out of receiving these marketing communications, this will not apply to personal information provided to us as a result of the provision of our services and we will still be required to contact you in relation to the services we provide.

If you fail to provide personal information:

If you fail to provide certain information when requested either by law, or under the terms of a contract we have with you and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you.

Automated decision-making:

You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making.

Data sharing

We may share personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.   Third party providers we may share your information with include:

  • Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • Snowsport schools, activity providers and instructors;
  • Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. Analytics and search engine providers that assist us in the improvement and optimisation of our website;
  • Auditors, accountants and financial organisations;
  • Insurers, solicitors, professional advisers and consultants
  • HMRC;
  • Central and local government;
  • Local authorities;
  • Debt collection agencies;
  • Police forces, courts and tribunals.

Any third parties will be bound by contractual provisions with us and only have access to personal data to perform the described purposes and may not use it for other purposes. Further, they must process the personal data in accordance with this Privacy Policy and as permitted by the GDPR and the Data Protection Act 2018.

Data security

We have put in place appropriate security measures to prevent personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal information to those employees, agents, contractors and other third parties who have a business need-to-know. They will only process personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data security breach and will notify you and the Information Commissioner’s Office of a suspected breach where we are legally required to do so.

Data retention

We will only retain personal information 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. Details of retention periods for different aspects of personal information are available upon request.  After this period, we will securely destroy personal information in accordance with data protection law.

International transfers of data

It may be necessary to transfer and store personal information at a destination outside EEA in order for us to fulfil our obligations to customers in regards to the provision of our services (e.g. to make bookings on our customers’ behalf).  We will take all steps reasonably necessary to ensure that personal information is treated securely and in accordance with this policy and, in the event that personal information is transferred outside the EEA, shall ensure that this is carried out subject to the requirements of the GDPR.  This means that your personal information will be subject to one or more of the appropriate safeguards set out in data protection law to ensure your personal information is adequately protected.  Further details on the safeguards in place to protect your personal information when transferred outside the EEA are available upon request.

Your rights

Under certain circumstances, by law you have the right to:

Right to request a copy of your information

You can request a copy of your information which we hold (this is known as a subject access request).

Right to correct any mistakes in your information

You can require us to correct any incomplete or inaccurate information.

Right to request erasure of your personal information

This enables you to ask us to delete or remove personal information where there is no good reason for us to continue to process it.

Right to object to processing

You have the right to object to processing 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.

You can ask us to stop contacting you for direct marketing purposes. If you would like to do this, please email us at contact us using the details below.

Right to request the restriction of processing

You have the right to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.

Right to request the transfer of your personal information to another party

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal information, or request that we transfer a copy of your personal information to another party, please contact us using the contact details below.

Right to withdraw consent

In the limited circumstances where you may have provided consent to the collection, processing and transfer of personal information for a specific purpose has been provided, individuals have the right to withdraw consent for that specific processing at any time. To withdraw your consent, please contact us using the contact details below. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

Please note, there are some specific circumstances where these rights do not apply and we can refuse to deal with your request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

Complaints

If you have a concern about the way we are collecting or using personal information, we would ask that you raise your concern with us in the first instance by e-mailing us.

Alternatively you can make a complaint to the Information Commissioner’s Office at https://ico.org.uk/concerns/ or write to Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Contact details

If you have any questions about this privacy policy or how we handle personal information, please contact us.

Changes to this privacy policy

We reserve the right to update this privacy policy at any time, and we will provide you with a new privacy policy when we make any substantial updates.

TGM Snowsports Ltd – Privacy Policy
V1.2 revised 19/11/2024