A. Snowtraxx International Website Privacy and Cookies Policy
This section of the policy only concerns our (Alpine Travel International, trading as Snowtraxx International) website and public and customer-accessible web services. Our Operational Data Protection Policy is found in section, ‘B’, below.
1.1. We are committed to safeguarding the privacy of our website visitors and service users.
1.2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
1.4. In this policy, “we”, “us” and “our” refer to Alpine Travel International Ltd, trading as Snowtraxx International. For more information about us, see Section 14.
2. How we use your personal data
2.1. In this Section we have set out:
2.1.1. the general categories of personal data that we may process;
2.1.2. the purposes for which we may process personal data; and
2.1.3. the legal bases of the processing.
2.2. We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit,
page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes
of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3. We may process your account data (“account data“). The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us.
2.4. We may process your personal data that are provided in the course of the use of our services (“service data“). The service data may include your name, email address, postal address and telephone number. The source of the
service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.5. We may process information contained in any enquiry you submit to us regarding our services] (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is our legitimate interests, namely providing you with information related to our services.
2.6. We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title
or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.7. We may process information relating to transactions, including purchases of services, that you enter into with us (“transaction data“). The transaction data may include your contact details, your card details and the transaction
details. The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and our legitimate interests, namely the proper administration of our business.
2.8. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.9. We may process any of your personal data identified in this policy] where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.10. In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.11. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
3. Providing your personal data to others
3.1. We may disclose your personal data to our insurers or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure]
3.2. Financial transactions relating to our website and services may be handled by our payment services providers, Sage Pay (https://www.sagepay.co.uk/).
We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at https://www.sagepay.co.uk/policies
3.3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Retaining and deleting personal data
4.1. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
4.2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3. Notwithstanding the other provisions of this Section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. Security of personal data
5.1. We will take appropriate technical and organisational precautions to secure your personal data and to prevent the loss, misuse or alteration of your personal data.
5.2. We will store all your personal data on secure servers, personal computers and mobile devices, and in secure manual record-keeping systems.
5.3. Data relating to your enquiries and financial transactions that is sent from your web browser to our web server, or from our web server to your web browser, will be protected using encryption technology.
5.4. You acknowledge that the transmission of unencrypted (or inadequately encrypted) data over the internet is inherently insecure, and we cannot guarantee the security of data sent over the internet.
5.5. You should ensure that your password is not susceptible to being guessed, whether by a person or a computer program. You are responsible for keeping the password you use for accessing our website confidential and we will not ask you for your password (except when you log in to our website).
6.1. We may update this policy from time to time by publishing a new version on our website.
6.2. You should check this page occasionally to ensure you are happy with any changes to this policy.
7. Your rights
7.1. In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and
guidance from the regulatory authorities for a full explanation of these rights.
7.2. Your principal rights under data protection law are:
7.2.1. the right to access;
7.2.2. the right to rectification;
7.2.3. the right to erasure;
7.2.4. the right to restrict processing;
7.2.5. the right to object to processing;
7.2.6. the right to data portability;
7.2.7. the right to complain to a supervisory authority; and
7.2.8. the right to withdraw consent.
7.3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by emailing firstname.lastname@example.org.
7.4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
7.5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
7.6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
7.7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
7.8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this
7.9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
7.10. To the extent that the legal basis for our processing of your personal data is:
7.10.1. consent; or
7.10.2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
7.11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
7.12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.13. You may exercise any of your rights in relation to your personal data by written notice to us or by emailing email@example.com, in addition to the other methods specified in this Section.
8. Third party websites
8.1. Our website includes hyperlinks to, and details of, third party websites.
8.2. We have no control over, and are not responsible for, the privacy policies and practices of third parties.
9. Personal data of children
9.1. Our website and services are targeted at persons over the age of 16.
9.2. If we have reason to believe that we hold personal data of a person under that age in our databases, we will delete that personal data.
10. Updating information
10.1. Please let us know if the personal information that we hold about you needs to be corrected or updated.
11. About cookies
11.1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
11.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
11.3. Cookies do not typically contain any information that personally identifies a user.
12. Cookies used by our service providers
13. Managing cookies
13.1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting
cookies via these links:
13.1.1. https://support.google.com/chrome/answer/95647?hl=en (Chrome);
13.1.2. https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
13.1.3. http://www.opera.com/help/tutorials/security/cookies/ (Opera);
13.1.4. https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
13.1.5. https://support.apple.com/kb/PH21411 (Safari); and
14. Our details
14.1. This website is owned and operated by Alpine Travel Ltd trading as Snowtraxx International
14.2. We are registered in Scotland under registration number SC373558, and our registered office is at 5A St Colme Street, Edinburgh, EH3 6AA.
14.3. Our principal place of business is at 6 Hill Street, Edinburgh, EH2 3JZ.
14.4. You can contact us:
14.4.1. by post, to the postal address given above;
14.4.2. using our website contact form;
14.4.3. by telephone, on the contact number published on our website from time to time; or
14.4.4. by email, using the email address published on our website from time to time.
15. Data protection registration
15.1. We are registered as a data controller with the UK Information Commissioner’s Office.
15.2. Our data protection registration number is ZA368407.
16. Data protection lead
16.1. Our data protection lead’s contact details are: Michael Murphy, Snowtraxx International, 6 Hill Street, Edinburgh, EH3 6AA.
Alpine Travel International Limited (trading as Snowtraxx International) takes privacy seriously. The following principles underpin our approach to respecting your privacy.
• We will always use your personal data in a way that is fair and reasonable and as a minimum, comply with prevailing legislation and observe generally accepted principles governing data protection.
• We aim to be transparent and provide accessible information about how we use your personal data – what information we collect, what we do with it, with whom we share it and who you should contact if you have any concerns.
• We will take all reasonable steps to protect your data from misuse and keep it secure.
Under the General Data Protection Regulations (GDPR) and ABTA Code of Conduct 2000, we are a data controller registered with the Information Commissioners Office, registration number ZA368407.
We will collect certain personal data from you. This data will include, where applicable, the names, addresses and other contact detail of you and your party members, credit/debit card or other payment details, and specific information about, and requirements of, the party members, including some sensitive data as defined by the Regulations, such as any disability or medical condition which may affect the chosen Tour arrangements and any dietary restrictions which may disclose the religious beliefs of an individual. The personal data we will request from you will be used to:
• ensure we understand your requirements and provide you with specific information about the products and/or services in which you are interested;
• have all information to be able to process any booking and communicate the arrangements with you;
• to put in place and manage the agreed tour arrangements for you and your party including the involvement of any third parties services;
• manage the financial transactions between us;
• carry out anti-fraud and anti-money laundering checks and verify your identity (as is necessary for compliance with our legal obligations and/or as is necessary for our legitimate business interests; and/or,
• assess financial and insurance risks, including carrying out credit reference checks and credit scoring assessments.
If we need any other personal details, we will look to obtain your consent at the time of request.
By providing other people’s personal data to us, you must be sure that they agree to this and you are allowed to provide it. You should also ensure that, where appropriate, they understand how their personal data may be used by us.
We will need to pass on your personal details, and those of the party members you act for, to the companies and organisations who need to know them so that your Tour can be provided (for example your airline, hotel, other supplier, credit/debit card company or bank). Such companies and organisations may be outside the European Union, Norway, Iceland or Liechtenstein if your Tour is to take place or involves suppliers outside these countries.
We will share your personal data with third party service providers that we contract with to perform technical operations on our behalf, such as any order fulfilment partners, debt recovery agents, and digital agencies, hosting providers, data storage providers and other technical partners who help us administer our website, or process the data submitted to it; as is necessary for compliance with our legal obligations and/or as is necessary to maintain our legitimate interests.
In providing us with personal data including sensitive data, you consent to us processing that data in relation to making travel arrangements, communicating arrangements to you, making the necessary bookings, administrating the tour and ensuring the ancillary arrangements.
Sharing personal data with regulatory authorities
So that you can travel, it may be mandatory (as required by government authorities at the point(s) of departure and/or destination) to disclose and process your personal data for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate. Such disclosure is necessary to protect your vital interests or those of others.
In an emergency
Your insurance company, their agents and medical staff may exchange relevant personal data and special categories of personal data with us in circumstances where we/they need to act on your behalf or in the interest of other customers or in an emergency, because is in the public interest or we have official authority.
We may use personal data to respond to and to manage security operations, accidents or other similar incidents, including medical and insurance purposes and it is in our or a third party’s legitimate interests and these are not overridden by your interests or rights.
To personalise your experience
We may use your personal data to better understand your interests so that we can try to predict what other products, services and information you might be most interested in. This enables us to tailor our communications to make them more relevant and interesting for you, and it is in our legitimate interests to do so.
Special categories of personal data
Where we need to process special categories of personal data, for example health data for medical reasons, we will only do so if one or more additional conditions apply. For example, we have your explicit consent; it is necessary to protect the vital interests of you or another individual and you are physically or legally incapable of giving consent; it is necessary to establish, exercise or defend legal claims; or it is necessary for reasons of substantial public interest.
All personal data you give us in connection with your booking including sensitive data, will be kept by us only as long is necessary for the purpose for which it was gathered; unless it is required to ensure the performance of any agreement we have with you or to take steps to enter into an agreement; or to manage our compliance with a legal obligation; or it is in the legitimate interests pursued by the Company except where such interests are overridden by your interests, rights or freedoms as a data subject; after which time it will be archived, deleted or made anonymous.
Occasionally, we may look to sell and or share clients’ names and addresses (but not sensitive data) to other companies or organisations who offer goods or services which we feel may interest you. We will contact you to ask you for your express consent first before doing this.
Except where expressly permitted by the General Data Protection Regulations, we will only deal with the personal details you give us as set out above unless you agree otherwise.
Accessing and updating your personal data; and complaints
You have a right to ask for a copy of the personal data we hold about you. You can write to us asking for a copy of other personal data we hold about you, include any details to help us identify and locate your personal data.
We want to make sure that the personal data we hold about you is accurate and up to date. If any of the details we hold are incorrect, please let us know.
You can also ask for your personal data to be rectified or erased, to object to the processing of your personal data and, where technically feasible, to ask for personal data you provided to be transmitted to another organisation.
We will update or erase your data, unless we have to keep it for legitimate business or legal purposes.
You can also contact us if you have a complaint about how we collect, store or use your personal data, submitting your request or complaint to the Data Protection Lead;
by post: Data Protection Lead, Alpine Travel International Limited,6 Hill Street, EdinburghEH2 3JZ.
by email: firstname.lastname@example.org; or,
by telephone: 0131 225 4668.
We aim to resolve complaints but if you are dissatisfied with our response, you may complain to the Information Commissioner’s Office.
Please note that we may ask you to verify your identity before we can act on your request or complaint. We may also ask you for more information to help ensure that you are authorised to make such a request or complaint when you contact us on behalf of someone else.
Last update: 05 June 2018