Privacy Policy

Holiday Gems Limited takes your privacy very seriously. Please read this Privacy Policy carefully as it contains important information on who we are, sets out the basis on which any personal information we collect from you, or that you provide to us will be processed, stored and shared by us in respect of your relationship with us as a customer or potential customer. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

Holiday Gems Limited is a member of the Travcorp Holdings Group. The Travcorp Holdings Group also includes Destination 2 Limited

This Privacy Policy covers websites (“Sites”) owned and controlled by us only. Links to other websites and any information collected by these sites are not covered by this Privacy Policy.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.

The information we collect may be collected via our Sites, our call centre, our questionnaires/surveys, our representatives or appointed agents in overseas destinations, our hotel, airline and supplier partners within the UK or overseas or our social media channels

Please read the following information carefully. You are responsible for ensuring that the other people that you are acting on behalf of (such as those included with you on a booking), are aware of the content of this Privacy Policy and you have checked with them that they agree to their personal information being given to us to make a booking on their behalf.

By making a booking or otherwise giving your personal information to us, we will transfer, store or process it as set out below. We will take all reasonably necessary steps to ensure that your personal information is treated securely and in accordance with this Privacy Policy.

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	Holiday Gems Limited trading as Holiday Gems
Our data privacy manager	Jill Pilling
Personal information	Any information relating to an identified or identifiable individual
Special category personal information	Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership Genetic and biometric data Data concerning health, sex life or sexual orientation

What types of personal information do we collect about you and why do we collect it:

We may collect and use certain personal information about you and about any other person you include on your booking. We may also collect and use certain personal information about you from our hotel, airline and supplier partners within the UK or overseas in the interests of fraud detection and fraud prevention.

Personal information you give to us:

• When you make a booking with us we may ask for your name, address, e-mail address, telephone number, date of birth, passport details, details of party members, details of next of kin, payment card details, meal preferences and nationality. We need this information to enable us to arrange the travel and other services you are requesting.
• We may have to ask if you have any special requirements. You may give us information concerning dietary requirements, health/medical conditions, disabilities, sexual orientation, race or religion (known as special category personal information). This special category personal information is used to determine your fitness to travel; provide you with special assistance; or fulfil special dietary requirements. We may have to share that data with our third-party suppliers (who help manage our business and deliver services such as those parties who provide wheelchairs at airports) and transfer it outside the European Economic Area (EEA), as described in this Privacy Policy. If you do not want to provide this information to us, or after you have provided us with information you ask our data privacy manager to stop processing the information, it may mean that we will not be in a position to provide all or parts of the services you have requested. Please be aware that if we have to cancel your booking arrangements you may incur cancellation charges in accordance with our terms and conditions. where you (or any passenger travelling) provides us with special categories of personal information you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which it was collected.
• If you contact us online, we may keep a record of your email correspondence.
• If you contact us by telephone, we may record and/or monitor telephone conversations for training and customer services reasons.
• If you enter a competition or complete a survey, we will collect your name and relevant contact information.
• If you report a problem with our services, we will collect your name and relevant contact information.
• If you make a complaint in connection with our services, we will collect your name and relevant contact information.

Personal information we collect and/or observe about you

Based on how you have used our services in the past and your activity on our website and our call centre, we collect the following personal information from you:

• Details of the services we have provided to you in the past, including your previous travel arrangements.
• Details of your visits to our Site, and of the resources that you access. We may use visitor information to measure the entry and exit points of visitors to the Site and respective numbers of visitors to various pages and sections of the Site and details of searches performed. We may also use this information in the future to measure the usage of advertising banners, and other "click throughs" to and from the Site. We have security processes in place to ensure that your personal information is held on a central database and is not accessible by any unauthorised persons. However, persons such as IT systems suppliers may need to have access to the system from time to time.
• Details of the website(s) you visited before you use a link to our Site, pages visited in our Site, and time spent on each. Information about your computer, or mobile device. This is statistical data about our users’ browsing actions.

Personal information we collect and use for legal, compliance, regulatory and crime/fraud detection and prevention purposes

We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order.

We also process your personal information for crime/fraud prevention and detection purposes. For the avoidance of doubt, we also work closely with our UK and overseas hotel, airline and supplier partners and may request from them (including and not limited to), check-in information, accommodation registration details, passports and CCTV footage and by accepting this Privacy Policy and booking with us, you understand that we may request this information and/or give authority to the relevant Law Enforcement agency, Court and/or Law Firm in the UK or overseas to request this information from any establishment you may have visited or checked in to.

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our Site. However, we may also collect information:

• another person making a booking on your behalf
• your travel companion
• our promotion partners
• social media
• from a third party with your consent; or
• from cookies on our website—for more information on our use of cookies, please see our cookies policy.
• from our hotel, airline and supplier partners within the UK or overseas

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

There may be more than one legal basis for us processing your data depending on the specific particular purpose for which we are doing so. Please contact us at customerliaison@holidaygems.co.uk if you need details about the specific legal basis upon which we are relying to process your personal data where more than one ground is set out in the table below

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our contract with you or to take steps at your request before entering into a contract. For example, to manage your booking with us, complete your travel arrangements and to take payment for your booking For our legitimate interests, e.g. to contact you in relation to an online booking request, which due to technical reasons and/or other factors remains in your shopping basket
To prevent and detect fraud against you and/or us	For our legitimate interests or those of a third party, ie to minimise fraud that could be damaging for us and for you
Conducting checks to identify our customers and verify their identity Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. under health and safety regulation or rules issued by our professional regulator	To comply with our legal and regulatory obligations
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Providing Advanced Passenger Information (API) to border control, customs and law enforcement officers at ports of entry and exit on your itinerary	To comply with our legal and regulatory obligations
Recording calls made to our call centre so we can review how we handle calls and make any necessary improvements	For our legitimate interests
Provide you with special assistance in relation to special categories of personal information	For the performance of our contract with you or to take steps at your request before entering into a contract; to comply with our legal and regulatory obligations; with your consent
Improve our products and services	For our legitimate interests
Ensuring business policies are adhered to, eg policies covering security and internet use	For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, ie to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, eg in relation to our financial performance, customer base, product range or other efficiency measures	For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: Existing and former customers or enquirers Third parties who had previously expressed an interest in our services Third parties with whom we have had no previous dealings	For our legitimate interests or those of a third party; to promote our business
For debt collection and credit vetting to project our business against financial loss	For our legitimate interests or those of a third party, ie to ensure our customers are likely to be able to pay for our products and services
For resolving complaints dealing with disputes and legal proceedings	To comply with our legal and regulatory obligations

Promotional communications

If you have made an enquiry or purchase on our Site or through our call centre, your personal information may be used by us in the ways the law allows, to contact you by post or electronic means (email or text message) about our services, including exclusive offers, promotions or new services. We may also send you information about The Travcorp Holdings Group products and services that we believe may be of interest to you.

If you have not made an enquiry or purchase, we will only send you information and offers by email or text message if you sign up (opt in) to receive such marketing.

We will always treat your personal information with the utmost respect and never sell or share it with other organisations for marketing purposes.

What you need to do if you don’t want to receive our promotional communications

You have the right to opt out of receiving promotional communications at any time by:

• contacting us at customerliaison@holidaygems.co.uk
• using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

• • any member of our Group for business purposes, (those business purposes include holding your data on central/shared systems for administering bookings and supporting customers in destination countries). We may also share your personal information within our Group to personalise the service and offers you receive (for example, by being aware of previous travel experiences, transactions or preferences, and tailoring the way we provide our products and services to you based on your preferences and profile). Our Group means our subsidiaries and our ultimate holding company and its subsidiaries. Currently, this consists of Travcorp Holdings Limited and Destination 2 Limited.
• third parties we use to help deliver our services to you, eg payment service providers.
• our travel partners, such as airlines, airports, hoteliers and ground handing agents, so that they can provide you with the arrangements and assistance you require.
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
• third parties approved by you, e.g. social media sites you choose to link your account to or third-party payment providers;
• email database provider;
• our insurers and brokers;
• our bank;
• our card payment facilitators, that help us process customer payments and assist us in detecting and preventing fraudulent payments or bookings.
• UK and Overseas Law Enforcement agencies, Courts and Law Firms.

We only allow our service providers to handle your personal information if we are satisfied, they take appropriate measures to protect your personal information. We may also share personal information with external auditors, e.g. in relation to the audit of our accounts.

We may disclose and exchange information with law enforcement agencies, regulatory bodies and external law firms (acting on your instructions) to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We will not share your personal information with any other third party.

Where your personal information is held

Information may be held at our offices, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

How long your personal information will be kept

Where you have made a booking or other purchase with us, your personal information will be retained to ensure we provide the best possible customer service to you. We retain your personal information for as long as is necessary for us to use your personal information as set out in this Privacy Policy. We will not retain your personal information for longer than necessary for the purposes set out in this policy.

Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

• service providers located outside the EEA;
• government bodies or other authorities, such as those responsible for immigration, border control, law enforcement, security and anti-terrorism.
• if you are based outside the EEA.

These transfers are subject to special rules under European and UK data protection law.

These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information please contact our Data Privacy Manager (see ‘How to contact us’ below).

Your rights in relation to any personal information we hold about you

You have the following rights, which you can exercise free of charge:

Request access to your personal information	The right to be provided with a copy of your personal information (the right of access) We may ask for proof of identity and sufficient information about your interactions with us that we can locate your personal information. That may include information about your previous booking(s) or other purchases. If someone is acting on your behalf, they will need to provide written and signed confirmation from you that you have given your authority to that person/company for them to make the request. We may not provide you with a copy of your personal information if it includes the personal information of other individuals or we have another lawful reason to withhold that information
Request rectification of the personal information we hold about you	The right to require us to correct any mistakes in your personal information
Withdrawing your consent	Where we rely on your consent as the legal basis for processing your personal information, as set out in section above titled ‘How and why we use your personal information’, you may withdraw your consent at any time. If you would like to withdraw your consent to receiving any direct marketing to which you previously opted-in, please see the section titled “What you need to do if you don’t want to receive our promotional communications’ for further details. If you would like to withdraw your consent to us processing any special categories of personal information, please contact our data privacy manager. Please note if you ask us to stop processing this information, it may mean we won’t be able to provide all or parts of the services you have requested. If we have to cancel your booking or other purchase as a result, you may incur a cancellation charge If you withdraw your consent, our use of your personal information before you withdraw is still lawful
Request erasure of your personal information	The right to require us to delete your personal information In certain situations, you may ask for your personal information to be removed from our systems by e-mailing or writing to us at the address at the end of this Privacy Policy. Provided we do not have any continuing lawful reason to continue processing or holding your personal information, we will make reasonable efforts to comply with your request
Request restriction of processing of your personal information	The right to require us to restrict processing of your personal information—in certain circumstances, eg if you contest the accuracy of the personal information This enables you to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want to establish the accuracy of the personal information; (b) where our use of the personal information is unlawful but you do not want us to erase it; (c) where you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal information to you or to a third party	Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract, as set out in section titled ‘How and why we use your personal information’, you have the right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that personal information to a third party. You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if it contains the personal information of other individuals or we have another lawful reason to withhold that information.
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision-making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

• email, call or write to our Data Privacy Manager—see below: ‘How to contact us’
• let us have enough information to identify you (eg your full name, address and booking reference number, date of departure (past or present), if you were the lead name on the booking or a passenger on the booking, departure and arrival airport, the accommodation you stayed at, board basis, duration, was the booking ATOL, Flight-Plus or accommodation only, how many passengers were on the booking. If you have not made a booking please provide us with information of how you have communicated with us; for example have you made a holiday enquiry)
• let us have proof of your identity and address; and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that our Data Privacy Manager can resolve any query or concern you may raise about our use of your information.

The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 4 June 2018 and last updated on 13th October 2023.

We may change this privacy notice from time to time—when we do we will inform you via our website.

How to contact us

Please contact our Data Privacy Manager by post, email or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below:

Do you need extra help?

If you would like this notice in another format (for example audio, large print, braille) please contact us (see ‘How to contact us’ above).