Culture Trip respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit and use our websites (theculturetrip.com and our related websites) (“Website”) or our Culture Trip branded app) or our Culture Trip branded app (“App”) and tells you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
This privacy notice aims to give you information on how Culture Trip collects and processes your personal data through your use of our Website or App, including any data you may provide through our Website or App when you sign up to our newsletter, make a purchase or set-up a user account.
The Website and App are not intended for children (i.e. individuals aged 18 or under) and we do not knowingly collect data relating to children.
It is important that you read this privacy notice together with any other notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices we give and is not intended to override them.
The Culture Trip Limited is the controller and responsible for your personal data (referred to as “Culture Trip”, “we”, “us” or “our” in this privacy notice).
Culture Trip is made up of different legal entities (The Culture Trip Ltd, The Culture Trip ISL Ltd and The Culture Trip USA Ltd). This privacy notice is issued on behalf of the Culture Trip Group so when we mention “Culture Trip”, “we”, “us” or “our” in this privacy notice, we are referring to the relevant company in the Culture Trip Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Culture Trip Limited is the controller and responsible for the Website and App.
We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise Your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: The Culture Trip Limited
Email address: email@example.com
Postal address: Data Protection Officer, First Floor, 75 Davies Street, London W15JN, London, UK
The Website and App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites or apps and are not responsible for their privacy statements. When you leave our Website or App, we encourage you to read the privacy notice of every website or app you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been permanently removed (i.e. anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together below:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Website or App feature or content.
We do not willingly collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We use different methods to collect data from and about you including through Direct interactions, Automated technologies or interactions, Third parties or publicly available sources.
Direct interactions.You may give us your Identity, Contact by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
We will only use your personal data when the law allows us to. Our ethos is to use your personal data in an ethical and transparent way, and we will never sell it. Most commonly, we will use your personal data in the following circumstances:
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To allow you to open an account via our Website or App|
|Necessary for our legitimate interests to offer a better service and user experience|
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Responding to your queries or complaints regarding the Website or App
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (to keep our records updated, to study how customers use our products/services, to respond to user’s questions on the use of our Website or App)
To enable you to partake in a prize draw, competition or complete a survey
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and Website and App (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant App and Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to provide a good experience to our users, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, App, products/services, provision of content, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services or content that may be of interest to you
Necessary for our legitimate interests (to develop our products/services and grow our business)
To track your viewing habits and engagement with affiliate links and adverts on the Website and App
Necessary for our legitimate interests to develop and grow our business
To send you our email newsletter, including stories, photos, videos, insider tips, news and product updates, if you have subscribed to receive this. We vary the frequency of these emails, but we aim to email you regularly. Our newsletters may include personalised stories and offers (show me an example)
Consent – we will only send you these types of emails if you have signed up to receive them.
To allow you to book a travel service(s) for example: an experience, a place to stay (e.g. in a hotel) or transport (e.g. car hire, flights) via our Website or App, for yourself and any other travellers who you may book the relevant travel service(s) for.
(c) Payment details
(d) Booking information
(e) Special assistance or dietary requirements
(f) Any other information that you volunteer as part of the booking to us.
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to be efficient about how we fulfil our contracts, to study how customers use our products/services, to develop them, to provide a good experience to our users, to grow our business and to develop our marketing strategy)
To deliver items you have ordered e.g. as part of an experience booking
Performance of a contract with you
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
So that we can provide you with a great user experience, we may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need. This is how we decide which adverts and content may be relevant for you.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising and providing you with personalized content.
We have established the following personal data control mechanisms:
Opting out for App Users: If you do not want your experience on the App to be tailored to you based on your viewing habits on the App, go to your profile->settings and slide the ‘Personalisation’ to ‘Off’. If you change your mind and would like to receive a personalised experience, you can simply slide the ‘Personalisation’ button back to ‘On’.
Opting out for Website users who are logged into their Culture Trip Account: If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, go to profile->settings and uncheck the ‘Personalisation’ checkbox. If you change your mind and would like to receive a personalised experience, you can simply re-check the box.
Opting out for Website users who do not have a Culture Trip Account: If you do not want your experience on the Website to be tailored to you based on your viewing habits on the Website, please click here to opt out from personalisation. If you change your mind and would like to receive a personalised experience, you can simply click here. If you click the link to opt-out, we will place a ‘do not track’ cookie on your browser. Please note that if you delete all cookies on your browser, or if you use a different browser to access the Website you will have to click this link again in order to stop us personalising your experience on our Website.
Tracking and advertising: We use products offered by Google and Facebook in order to show you adverts which we think are likely to be relevant to you. If you do not want to receive personalized advertising, and marketing please follow the instructions in the paragraph below.
If you want to change the personalized advertisement settings you can use the ads settings to manage the Google ads and opt out of interest-based ads by following THESE instructions.
Facebook may also collect information about how you use our website, such as which pages you visit through first-party cookies, to enable both Facebook and Culture Trip to provide more relevant messages to you across Facebook. You can opt out of Facebook first-party cookies by updating your Facebook Privacy Settings and control the information Facebook uses to show you advertisements by managing your Ads Preferences
Do Not Track: For California residents, “Do Not Track” (DNT) has been promoted by US regulatory authorities for the internet industry to develop and implement a mechanism that allows internet users to control the tracking of their online activities across websites. Culture Trip currently does not respond to DNT browser signals.
Marketing emails: You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you, or by contacting us at any time.
We may have to share your personal data with the parties set out below for the purposes set out in the ‘How we use your personal data’ section above:
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party data processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We share your personal data within the Culture Trip Group. This will involve transferring your data outside the United Kingdom and European Economic Area (UK and EEA).
Some of our external third parties are based outside the UK and EEA so their processing of your personal data will involve a transfer of data outside the UK and EEA.
Whenever we transfer your personal data out of the UK and EEA, we ensure a similar degree of protection is afforded.
This could be achieved using one of the following ways:
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK and EEA.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data 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.
We retain your personal data while your account is in existence or as needed to provide you the Website and App services. This includes data you or others provided to us and data generated or inferred from your use of our Website or App.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
If you wish to exercise any of the rights set out above, please contact us by emailing firstname.lastname@example.org
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Other companies in the Culture Trip Group acting as joint controllers or processors and who are based in the US and Israel.
We use external third party service providers to help us provide our Website and App (e.g., maintenance, analysis, audit, marketing and development). They will have access to your information as is necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
We use external third parties such as social networks through the use of social plugins (e.g. share/like buttons).
We use external third party service providers to help us with providing travel services to you, these may include travel service suppliers such as sales/reservation system providers, software companies, hotel suppliers, experience providers. This is not an exhaustive list.
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing processing of your personal data 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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data 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 data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.