Ossian is committed to protecting your privacy and the confidentiality of your personal information. This privacy notice explains how we collect, use and protect your personal information. In this privacy notice, “our” and “we” means Galbraith Leisure Limited trading as Ossian. Any reference to “you” or “your” refers to anyone whose personal information we collect and process.
1. Introduction Our use of your personal information is governed by this privacy notice. We are a controller for the personal information that we collect and use about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this privacy notice. In this privacy notice we explain; • What personal information is • How we collect your personal information • The types of personal information we collect • How we use your personal information • The legal basis for processing your personal information • How we share your personal information • How long we keep your personal information • How we keep your personal information secure • Your rights in relation to your personal information • How to make complaints and how to contact us
2. What is personal information? Personal information is any information that tells us something about you. This includes information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you. Some personal information is classified as special data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justification for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data. Any references to personal information in this privacy notice includes personal data, and where relevant, special categories of personal data.
3. What personal information do we collect? The type of personal information that we collect from you will depend on the service that we are providing to you or the reason that you are engaging with us. In all cases of engagement with you as a client we will collect your full name and contact details (such as phone numbers, email address and postal address) from you. We will also collect your bank details. If we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).
We may also collect information about you from other sources. This may include the following: • Publicly available information, from sources such as Companies House and the Electoral Roll • Information you have shared publicly, including on social media • Information from third party databases or data suppliers, such as credit reference agencies, including details about your home and creditworthiness
If you subscribe to receive news or other market updates from us then in addition to the above we may collect details about the sector in which you work and the type of content that you would like to receive but only with your consent.
4. What is the legal basis of our data processing? Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;
• Where we need information to perform the contract we have entered into with you • Where we need to comply with a legal obligation • Where we have your consent • Where the processing is necessary for us to carry out activities for which it is in our legitimate interest (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:
• processing your personal information in ways that you would reasonably expect and which have a minimal privacy impact, or where there is a compelling justification for this processing. This would include collecting and processing personal data for the purposes of matching you with holidays, activities and properties.
• processing which is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. – this may include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.
• processing which is necessary to improve our knowledge of the holiday and tour operator sector – this will include undertaking market analysis and research so that we better understand trends in the holiday sector and provide better knowledge along with more tailored and relevant services for our customers in the future.
• processing which is necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and creating a better understanding of you as a customer;
• processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialists in such services;
• processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.
In more limited circumstances we may also rely on the following legal bases: • Where we need to protect your interests (or someone else’s interests); and/or • Where it is needed in the public interest or for official purposes we may process special categories of personal information with your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.
How we use your personal information We will share your personal information with our clients, our bank, our suppliers, our insurers, contractors, other necessary statutory bodies and any other third parties necessary to facilitate the
services we provide to you and to meet our legal obligations in respect of these services. We will also retain records of your holiday, tour and sporting history and profile to enable us to provide you with a more informed service.
Other uses of your personal information • If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice. • We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations. • We will share personal information with third party services providers who process personal information on our behalf in order to provide services to us. This includes management service providers, IT systems providers and IT contractors as well as third party referencing or screening agencies. • We may share your personal information with any person working within Ossian and CKD Galbraith LLP on a need to know basis to ensure we are able to perform our obligations to you. • We will hold your personal information on our client management systems and those of CKD Galbraith LLP and use this to provide you with marketing information about similar services offered by us and CKD Galbraith LLP to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.
What happens if you do not provide information that we request? We need some of your personal information to perform the services you have requested from us. If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect personal information from you.
5. How we keep your information secure The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to: • Our client files are stored on secure client management systems. Access is restricted on our client systems to those within Ossian and CKD Galbraith LLP who are required to have access to your information for legitimate business purposes. • All data is hosted in datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to, your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary. We hold the Essentials Cyber Security accreditation. • We ensure access to personal information is restricted to Ossian and CKD Galbraith LLP employees and workers or other persons working within Ossian and CKD Galbraith LLP on a need to know basis.
6. How long do we keep your personal information? We will keep your personal information for at least 7 years. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period or where we may need to retain the information in case of a legal claim.
7. Overseas transfers of your personal information We ensure that the personal information we hold on your behalf is stored in locations within the UK and the European Economic Area (EEA).
8. Your rights in relation to your personal information You have a number of rights in relation to your personal information, these include the right to: • Be informed about how we use your personal information • Obtain access to your personal information that we hold • Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate • Request that we erase your personal information in the following circumstances: • If we or CKD Galbraith LLP are continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected • If we or CKD Galbraith LLP are relying on consent as the legal basis for processing and you withdraw consent • If we or CKD Galbraith LLP are relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us to continue with the processing • If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation) • If it is necessary to delete the personal information to comply with a legal obligation • Ask us to restrict our data processing activities where you consider that:
• personal information is inaccurate
• our processing of your personal information is unlawful
• where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal clai
• where you have raised an objection to our use of your personal information
• Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information • Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and • Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.
If you would like to exercise any of your rights please contact firstname.lastname@example.org
9. Complaints and Contact Detail If you have any complaints about the way we use your personal information please contact email@example.com. If we cannot resolve any issue you have the right to complain to the data protection authority in your country (the Information Commissioner in the UK).
If you have any questions, comments or requests regarding any aspect of this Privacy Notice, please do not hesitate to contact us by sending an email to firstname.lastname@example.org
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