Privacy and Legal
- Important Notice
- How to Contact Us
- Categories of Personal Date We Collect
- The Sources from Which We Obtain Your Personal Data
- How We Use Your Personal Data & Our Basis for Using It
- Who Receives Your Personal Data
- Personal Data About Other People Which You Provide to Us
- Accuracy of Your Personal Information
- International Transfers of Personal Data
- How Long We Will Store Your Personal Data For
- Contractual or Statutory Requirements on You to Provide Personal Data
- Your Rights in Relation to Your Personal Data
- Links to Other Websites
1 Important Notice
1.1
This is the Privacy Notice of Travel Assistance Support Services Ltd (here after referred to as TASSBLUE) and whose registered office is at 28b, Lawrence Road London N15 4EG, UK. Where this Privacy Notice refers to “TASSBLUE”, “we”, “us” or “our”, it is referring to TASSBLUE. This Privacy Notice outlines the procedures through which we gather and handle your personal data and also provides essential legal information and your rights concerning your personal data. We encourage you to read this Privacy Notice to understand how your personal data may be used.
1.2
This Privacy Notice pertains to personal information concerning “you,” referring to Users, customers, potential customers, and individuals who browse our website or interact with us outside our organization. However, if you are an employee, contractor, or involved in work with us, a separate privacy notice will apply to you instead.
1.3
In this Privacy Notice, we use the term “personal data” to refer to this information. Section 3 provides more detailed information about what is included in personal data.
1.4
Please check this Privacy Notice regularly as it may change over time. The last update was made in January 2024.
2 How to Contact Us
2.1
Data controller and contact details
2.1.1
We are a controller of your personal data under relevant data protection laws. As a controller, we use your personal data in accordance with this Privacy Notice.
2.1.2
If you wish to correct your personal data held by us or to opt out at any time from receiving marketing correspondence from us or to alter your marketing preferences please contact : contact@tassblue.com.
2.1.3
To correct your personal data or opt-out of receiving marketing correspondence from us, please contact : contact@tassblue.com. You can also use this email to update your marketing preferences.
2.2
Data Protection Officer
You can reach our Data Protection Officer at 28b Lawrence Road, London, N15 4EG, U.K., or by email at contact@tassblue.com.
3 Categories of Personal Data We Collect
3.1
The categories of personal data we may collect, use, store, share, and transfer about you are:
3.1.1
Advertising Data: This comprises personal data concerning your advertising preferences, including information about your marketing material preferences from us and your communication choices;
3.1.2
Information Technology Data: This refers to personal data related to your use of our website, such as your IP address, login data, traffic data, weblogs, and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform, and other technology used on the devices to access our website;
3.1.3
Individual Data: This comprises personal data related to your identity, such as your first name, middle name, last name, username or similar identifier, marital status, title, date of birth, place of birth, passport number, and gender;
3.1.4
Account and Profile Data: This refers to personal data related to your website account or profile, including your username and password, proposals and bookings made by you, your interests, preferences, feedback, and survey responses;
3.1.5
Usage and Operational Data: This comprises personal data related to your usage and operation of our website, including information about how you use our website, products, and services;
3.1.6
Economic and Financial Data: This includes personal data required for us to process your booking in line with our obligations under the Payment Card Industry Data Security Standard (PCI) (Link) and for the prevention of fraud;
3.1.7
Inquiry and Sales Data: This consists of personal data pertaining to your transactions with us, including payment details, subscription information, and other details of products and services you have purchased from us;
3.1.8
Audio Data: This comprises personal data recorded using our audio recording systems at our locations;
3.1.9
Market Research Data: This involves personal data collected for market research purposes, including price comparison information;
3.1.10
Health Data: This pertains to personal data collected for health and safety reasons, including any accident report or claim log or any information you provide about allergies or other medical conditions during the booking process or in one of our locations;
3.1.11
Communication Data: This refers to personal data related to your communication methods, such as your billing address, residential address, email address, and telephone numbers;
3.1.12
Geographical Data: This comprises personal data involving geographical information, including interests, travel history, and places visited.
3.2
We may also create Personal Data about you, for example, if you contact us by telephone to make a complaint, for example about our services or goods, then we may make a written record of essential conversation details to address the complaint effectively.
3.3
We collect and use aggregated data, such as statistical or demographic data, for various purposes (“Aggregated Data”). This data is derived from your personal data but does not directly or indirectly disclose your identity. For instance, we may aggregate Operational Data to determine the percentage of users accessing a specific feature on our website. However, if we combine or connect Aggregated Data with your personal data in a way that can directly or indirectly identify you, we treat the combined data as personal data and handle it in accordance with this Privacy Notice.
3.4
Furthermore, we may collect specific sensitive data known as “Special Categories of Data.” This Privacy Notice outlines how we handle these types of personal data. The Special Categories of Data include information about sexuality, religious beliefs, or health.
3.5
We do not collect any information about Criminal convictions and Offences.
4 The Sources from Which We Obtain Your Personal Data
4.1
We obtain your personal data from the following sources:
4.1.1
Directly from you through various means, such as in-person (at our locations or otherwise), via our website, email, digital communication tools, writings, or telephone conversations. This may include personal data you provide when you:
(a) request sales/promotional materials such as leaflets;
(b) make an appointment;
(c) use our “Live Chat” facility on our website or otherwise contacting our Customer Service Team;
(d) apply for our products or services;
(e) browse or create an account on our website;
(f) subscribe to our service or publications;
(g) request marketing materials to be sent to you;
(h) enter into a competition or promotion;
(i) complete a survey from us;
(j) save a proposal;
(k) enter details at an event;
(l) send an email to us;
(m) register to memberships/promotional activities.
4.1.2
Automated technologies, such as call recording, cookies, server logs and other similar technologies.
4.1.3
Third parties, such as:
(a) analytics providers;
(b) advertising networks;
(c) search information providers;
(d) providers of technical, payment and delivery services;
(e) data brokers or aggregators;
(f) partnerships;
(g) travel agents.
5 How We Use Your Personal Data & Our Basis for Using It
5.1
Where we are relying on a basis other than consent
When processing your personal data, we may rely on one or more of the following legal bases. Below, we have outlined the purposes for processing your personal data and the relevant legal basis we will rely on, as permitted by the law:
5.1.1
To manage your requests and provide our products and services, we will use the information you provide. This involves arranging travels, tours, ground transportation, and ticket issuance. We will process this personal data based on the following legal basis:
(a) the processing is required to fulfill a contract you are part of or to take steps at your request before entering into a contract;
5.1.2
We will use your personal data to provide suggestions and recommendations about our products and services that may interest you. Additionally, we will measure the effectiveness of promotional campaigns and advertising and ensure that our marketing is relevant to you. The legal basis for processing this personal data is:
(a) the processing is necessary for our or a third party’s legitimate interests, except when your interests or fundamental rights and freedoms require protection of personal data;
5.1.3
We will use your personal data to handle your inquiries, send you requested information, and provide important real-time updates about products and services you have ordered from us (e.g., changes in time or location due to unforeseen circumstances). The legal bases for processing this personal data are:
(a) the processing is necessary for our or a third party’s legitimate interests, except when your interests or fundamental rights and freedoms require protection of personal data;
(b) the processing is required to fulfill a contract you are part of or to take steps at your request before entering into a contract;
5.1.4
We will use your personal data to develop, deliver, and enhance our products and services, as well as for marketing, managing customer relationships, and improving customer experiences. The legal basis for processing this personal data is:
(a) the processing is required for our or a third party’s legitimate interests, except when your interests or fundamental rights and freedoms necessitate protection of personal data;
5.1.5
Where you have submitted a job application we may keep your details on file for a reasonable period in case a suitable position becomes available in the future. During this time, we may also send you information about job opportunities. The legal basis for processing this personal data is:
(a) the processing is essential for our or a third party’s legitimate interests, except when your interests or fundamental rights and freedoms require protection of personal data;
5.1.6
We will use your personal data to enhance our website’s usability for you and our customers, identify usage trends, and conduct internal research, analysis, testing, monitoring, customer communication, risk management, and administrative purposes. This data will also assist in defining customer types for our products and services, keeping our website up-to-date and relevant, and developing our marketing strategy. The legal basis for processing this personal data is:
(a) the processing is necessary for our or a third party’s legitimate interests, except when your interests or fundamental rights and freedoms require protection of personal data;
5.1.7
We will use your personal data to safeguard our rights or property/assets (including our website), enhance our IT services and network security, prevent fraud, and support any business reorganization or group restructuring exercise. The legal basis for processing this personal data is:
(a) the processing is required for our or a third party’s legitimate interests, except when your interests or fundamental rights and freedoms necessitate protection of personal data;
5.1.8
We will process your personal data to meet our legal obligations, such as health and safety legislation or to cooperate with investigations (e.g., by the Police). The legal basis for processing this personal data is:
(a) the processing is required to comply with a legal obligation we are subject to;
5.1.9
In life or death situations where there is no time to obtain your consent (e.g., during an accident and the need to provide personal details to medical personnel), we will process your personal data. The legal basis for processing this personal data is:
(a) the processing is necessary to protect the vital interests of the data subject or another natural person;
5.1.10
When we are officially designated to carry out a role by an official authority (e.g., the government) or perform tasks in the public interest (e.g., as designated by the government or considered in the public interest), we will process your personal data. The legal basis for processing this personal data is:
(a) the processing is necessary for performing a task in the public interest or exercising official authority vested in us.
5.2
Special Categories of Data
We may lawfully process Special Categories of Data for specific purposes. Below are the purposes and legal bases on which we process these Special Categories of Data (as allowed by the law):
5.2.1
We may need to process your health information for specific reasons, such as arranging special assistance, dietary preferences, or assessing your fitness to fly. In relation to the processing of such Special Categories of Data:
(a) The legal basis we rely on to process such Special Categories of Data is:
(i) 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;
(ii) the processing is necessary in order to protect the vital interests of the data subject or another natural person;
(b) Furthermore, we can only process such Special Categories of Data when:
(i) The processing is necessary in order to protect the vital interests of you or another individual where you or the individual is physically or legally incapable of giving consent;
(ii) The processing is necessary for reasons of public interest in the area of public health, such as:
(a) protecting against serious cross-border threats to health;
(b) ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices;
5.2.2
We may need to disclose any Special Categories of Data we hold on you in cases of substantial public interest, such as preventing an epidemic, responding to illness or injury, or managing emergencies at our locations. We will ensure suitable measures are taken to protect your rights when disclosing this information. In relation to the processing of such Special Categories of Data:
(a) We process such Special Categories of Data based on the following legal basis:
(i) The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
(b) Additionally, we can only process such Special Categories of Data where:
(i) The processing is necessary for reasons of public interest in the area of public health for example:
(a) protecting against serious cross-border threats to health;
(b) ensuring high standards of quality and safety of healthcare and of medicinal products or medical devices;
5.2.3
In relation to processing such Special Categories of Data:
(a) We rely on the following legal basis:
(i) The processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract.
(b) Additionally, we can only process such Special Categories of Data where:
(i) You have given explicit consent to the processing of this information.
(c) We rely on the following legal basis to process such Special Categories of Data:
(i) 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;
(d) Additionally, we can only process such Special Categories of Data where:
(i) You have given explicit consent to the processing of this information for the specific purpose. You have the right to withdraw this consent at any time. However, please note that if you withdraw consent, we may not be able to fulfil your services/bookings, and it may result in the cancellation of your services/bookings.
We will strive to minimize the collection of sensitive personal data unless there is a specific lawful reason, such as in emergency situations.
6 Who Receives Your Personal Data
6.1
We may disclose your personal data to:
6.1.1
We may share your personal data with third-party suppliers or subcontractors who process data on our behalf to provide you with our services. Such disclosure will only occur to process your personal data for the purposes outlined in this Privacy Notice;
6.1.2
We may share your personal data with our group companies, affiliates, or third-party data processors who process data on our behalf to facilitate our regular business operations. Such disclosure will only be for the purpose of processing your personal data as outlined in this Privacy Notice;
6.1.3
HMRC (The UK), legal and other regulators, or authorities when required to do so by law or to report any potential or actual breach of applicable law or regulation;
6.1.4
external professional advisers such as accountants, bankers, insurers, auditors, and lawyers for the purpose of seeking their professional advice and services;
6.1.5
law enforcement agencies, courts, immigration authorities, customs and excise authorities, or other relevant parties, to the extent necessary for the establishment, exercise, or defence of legal rights;
6.1.6
third parties where necessary for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
6.1.7
third parties which are considering or have decided to buy some or all of our assets or shares, merge with us or to whom we may transfer our business (including in the event of a re-organisation, dissolution or liquidation);
6.1.8
third parties operating plugins or content (such as Facebook, Twitter, Instagram, Tik-Tok) on our website which you choose to interact with;
7 Personal Data About Other People Which You Provide to Us
7.1
If you provide us with personal data about someone else, you must ensure that you are allowed to share that information with us. By doing so, we may collect, use, and disclose that personal data as described in this Privacy Notice without needing additional permissions from you.
7.2
Before providing us with someone else’s personal data, you must ensure that the individual concerned is aware of the information mentioned in this Privacy Notice. This includes details about our identity, how to contact us, our personal data collection and usage practices, our disclosure practices, the individual’s right to access their personal data and lodge complaints about its handling, and the possible consequences if the personal data is not provided.
8 Accuracy of Your Personal Information
8.1
Keeping your personal data accurate and up-to-date is vital, and we take reasonable precautions to ensure its accuracy. However, we do not verify the accuracy of the personal data you provide. If your personal data changes while you are using our services, please inform us by updating your account on our website or contacting us. We will not be liable for any losses resulting from inaccurate, inauthentic, deficient, or incomplete personal data provided by you.
9 International Transfers of Personal Data
9.1
We may transfer, store, and process your personal data outside the European Economic Area (EEA). This may happen when you book or purchase a product/service for a destination outside the EEA. Such transfers are necessary for the performance of the contract between us and to provide you with the requested product/service.
9.2
In relation to transfers of personal data outside the European Economic Area, we will take necessary steps to comply with the General Data Protection Regulation (EU) 2016/679 (Link). This includes ensuring that:
9.2.1
uses the standard data protection contractual clauses between us and the recipient as the relevant safeguard for transferring personal data outside the European Economic Area. If you wish to obtain a copy of these clauses, you can contact us using the contact details provided in section 2; or
9.2.2
any such transfer is made on the basis of an adequacy decision, namely:
(a) the Privacy Shield for transfers to the US; or
(b) the European Commission has decided that the relevant non-EU country ensures an adequate level of protection.
10 How Long We Will Store Your Personal Data For
We will retain your personal data only for as long as necessary to comply with legal obligations and any group data retention policy from relevant companies. For personal data related to your bookings, we will store it for 8 years from the date of service. For marketing-related data, we will keep it for 8 years from your last interaction with us. We conduct annual reviews to ensure data retention compliance.
11 Contractual or Statutory Requirements on You to Provide Personal Data
11.1
In certain circumstances the provision of personal data by you is a requirement:
11.1.1
to comply with the law or a contract; or/
11.1.2
necessary to enter into a contract.
11.2
You must provide necessary personal data to comply with the law, and failure to do so will result in us being unable to fulfil your product or service request.
11.3
You have the choice to provide us with the personal data necessary for entering into a contract or meeting contractual requirements. However, if you choose not to provide this data, it may result in us not being able to fully perform our contract with you. For instance, we might be unable to offer certain products or services or fulfil the contract at all due to the lack of essential personal data. For more details, please refer to https://tassblue.com/terms-and-conditions/.
12 Your Rights in Relation to Your Personal Data
12.1
Subject to relevant data protection laws, you have certain rights regarding the processing of your personal data, including the ability to withdraw your consent (as stated in section 5.2.3) and other rights such as:
12.1.1
the right to request access to your personal data that we process or control;
12.1.2
the right to request corrections to any inaccuracies in your personal data or to request completion of any incomplete data, considering the purposes of our processing;
12.1.3
the right to request, on legitimate grounds as specified in law:
(a) erasure of your personal data that we process or control; or
(b) restriction of processing of your personal data that we process or control;
12.1.4
the right to object, on legitimate grounds as specified in law, to the processing of your personal data;
12.1.5
the right to receive your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller, where applicable under the law; and
12.1.6
the right to lodge complaints with the Information Commissioner’s Office (Link) or other relevant supervisory body regarding the processing of your personal data. For further information, please contact : contact@tassblue.com.
If you wish to exercise any of the rights mentioned above, please contact us using the contact details provided in section 2.
13 Links to Other Websites
13.1
This policy applies solely to our website. If you visit another website through a link on our site, please read and understand that website’s privacy policy separately. We have no control over unrelated third-party websites and cannot be held responsible for how your personal data is used by those websites.
January 2024