Data protection and privacy policy

1. Background

This privacy notice lets you know what happens to any personal data that you give to us, or any that we may collect from or about you. It applies to all products and services, and instances where we collect your personal data.

This privacy notice applies to personal information processed by or on behalf of Hadler Tours Limited trading as Worldwide Christian Travel.

Use the links below to find out more about how we use your personal information:

• Who are we and how do you contact us and our Data Protection Officer?
• What kinds of personal information about you do we process?
• What is the source of your personal information?
• What do we use your personal information for?
• What are the legal grounds for our processing of your personal information (including when we share it with others)?
• What should you do if your personal information changes?
• For how long is your personal information retained by us?
• What are your rights under data protection laws?

Changes to this privacy notice

We may change this privacy notice from time to time by updating this page in order to reflect changes in the law and/or our privacy practices. We encourage you to check this privacy notice for changes whenever you visit our website – https://www.christian-travel.com.

Hadler Tours and our Data Protection Officer

We are Hadler Tours Limited, 36 Coldharbour Road, Bristol, BS6 7NA. We are a data controller of your personal data. Hadler Tours or types of companies which provide your product or service, are named at the start of these terms and conditions. Hadler Tours means Worldwide Christian Travel.

We have a dedicated data protection officer (“DPO”). You can contact the DPO using the details below or by writing to the above address, marking it for the attention of the DPO or going to Contact Us.

2. What kinds of personal information about you do we process?

Personal information that we’ll process in connection with all of our products and services, if relevant, includes:

• Personal and contact details, such as title, full name, contact details and contact details history
• Your date of birth, gender and/or age
• Your passport information, if needed for the product or service
• Your nationality, if needed for the product or service
• Family members, if relevant to the product or service
• Products and services you hold with us, as well as have been interested in
• Marketing to you and analysing data, including history of those communications
• Information about your health, including dietary requirements, or if you are a vulnerable customer, to be passed on to airlines and hotels where relevant
• Information about your employment status, if relevant
• Your residency and/or citizenship status, if relevant, such as your nationality, your length of residency in the UK and/or whether you have the permanent right to reside in UK

3. What is the source of your personal information?

We’ll collect personal information from the following general sources:

• From you directly, and any information from group members, associates or beneficiaries of products and services

4. What do we use your personal data for?

We use your personal data, including any of the personal data listed in section 1 above, for the following purposes:

• Managing the product or service you have with us
• Managing any aspect of the product or service
• To perform and/or test the performance of, our products, services and internal processes
• To improve the operation of our business and that of our business partners
• To follow guidance and best practice under the change to rules of governmental and regulatory bodies
• For management and auditing of our business operations including accounting
• To monitor and to keep records of our communications with you and our staff (see below)
• To administer our good governance requirements, such as internal reporting and compliance obligations or administration required for Annual General Meeting (“AGM”) processes
• For market research and analysis and developing statistics
• For direct marketing communications and related profiling to help us to offer you relevant products and service. This will only be used to inform you when a leader that you have travelled with confirms a new tour, you can opt out of such approaches at any time
• To develop new products and services and to review and improve current products and services
• To comply with legal and regulatory obligations, requirements and guidance
• To provide insight and analysis of our customers both for ourselves and for the benefit of business partners either as part of providing products or services, helping us improve products or services, or to assess or improve the operating of our businesses
• To share information, as needed, with business partners (for example, land service agents, airlines, government organisations where appropriate), service providers or as part of providing and administering our products and services or operating our business
• To facilitate the sale of one or more parts of our business

5. What are the legal grounds for our processing of your personal information (including when we share it with others)?

We rely on the following legal bases to use your personal data:

• Where it is needed to provide you with our products or services, such as:
• a) Assessing an application for a product or service you hold with us, including consider whether or not to offer you the product
• b) Managing products and services you hold with us, or an application for one
• c) Updating your records, to contact you about your account and doing this for recovering debt (where appropriate)
• d) Sharing your personal information with business partners and services providers when you book a service to help manage your service
• e) All stages and activities relevant to managing the product or service including enquiry, application, administration and management of accounts, requests for transfers of equity
• Where it is in our legitimate interests to do so, such as:
• a) Managing your products and services relating to that, updating your records, to contact you about your account and doing this for recovering debt (where appropriate)
• b) To perform and/or test the performance of, our products, services and internal processes
• c) To follow guidance and recommended best practice of government and regulatory bodies
• d) For management and audit of our business operations including accounting
• e) To carry out monitoring and to keep records of our communications with you and our staff (see below)
• f) To administer our good governance requirements, such as internal reporting and compliance obligations or administration required for AGM processes
• g) For market research and analysis and developing statistics
• h) For direct marketing communications and related profiling to help us to offer you relevant products and services, including deciding whether or not to offer you certain products and service. We will send marketing to you by SMS, email, phone or post
• i) Where we need to share your personal information with people or organisations in order to run our business or comply with any legal and/or regulatory obligations
• To comply with our legal obligations
• With your consent or explicit consent:
• a) For some direct marketing communications
• b) For some of our profiling and other automated decision making
• c) For some of our processing of special categories of personal data such as about your health or if you are a vulnerable customer
• For a public interest, such as:
• a) Processing of your special categories of personal data such as about your health

6. When do we share your personal information with other organisations?

We may share information with the following third parties for the purposes listed above:

• Business partners (for example, land service agents, airlines) or others who are a part of providing your products and services
• Governmental and regulatory bodies such as the Civil Aviation Authority CAA), the Association of British Travel Agents (ABTA) Information Commissioner’s Office (ICO)
• Other organisations and businesses who provide services to us such as IT software and maintenance providers, document storage providers and suppliers of other back office functions

7. How and when can you withdraw your consent?

Where we are relying upon your consent to process personal data, you can withdraw this at any time by contacting us using the details below.

8. Is your personal information transferred outside the UK or the EEA?

We are based in the UK but sometimes your personal information may be transferred outside of the European Economic Area (EEA). Organisations that are based outside of the EEA may not be subject to the same level of controls in regard to data protection as exist within the UK and the EEA.

9. What should you do if your personal information changes?

You should tell us so that we can update our records using the details in the Contact Us section of our website. We will then update your records if we can.

10. Do you have to provide your personal information to us?

We are unable to provide you with our products or services if you do not provide certain information to us. We will make this clear in cases where providing some personal information is optional.

11. Do we do any monitoring involving processing of your personal information?

In this section monitoring means any: listening to, recording of, viewing of, intercepting of, or taking and keeping records (as the case may be) of calls, email, text messages, social media messages, in person (face to face) meetings and other communications.

We may monitor where permitted by law and we will do this where the law requires it, or to comply with regulatory rules, to prevent or detect crime, in the interests of protecting the security of our communications systems and procedures and for quality control and staff training purposes. This information may be shared for the purposes described above.

12. How long is your personal information retained by us?

Unless we explain otherwise to you, we will hold your personal information based on the following criteria:

• For as long as we have reasonable business needs, such as managing our relationship with you and managing our operations
• For as long as we provide goods and/or services to you and then for as long as someone could bring a claim against us; and/or
• Retention periods in line with legal and regulatory requirements or guidance.

13. What are your rights under data protection laws?

Here is a list of the rights that all individuals have under data protection laws. They do not apply in all circumstances. If you wish to use any of them, we will explain at that time if they are engaged or not.

• The right to be informed about the processing of your personal information
• The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed
• The right to object to processing of your personal information
• The right to restrict processing of your personal information
• The right to have your personal information erased (the “right to be forgotten”)
• The right to request access to your personal information and to obtain information about how we process it
• The right to move, copy or transfer your personal information (“data portability”)
• Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you
• You have the right to complain to the Information Commissioner’s Office, which enforces data protection laws: https://ico.org.uk/. You can contact us using the details below.

14. Your right to object

You have the right to object to certain purposes for processing, in particular to data processed for direct marketing purposes and to data processed for certain reasons based on our legitimate interests. You can contact us by going to the Contact Us section of our website to exercise these rights.

15. What are your marketing preferences and what do they mean?

We may use your home address, phone numbers, email address and social media or digital channels (for example, Facebook and message facilities in other platforms) to contact you according to your marketing preferences. You can stop our marketing at any time by contacting us using the details below or by following the instructions in the communication.

16. Data security

The transmission of information via the internet is not completely secure, and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to this web site, therefore any transmission is at your own risk. Once we have received your information, we will take all reasonable steps to keep your personal data secure and to try to prevent any unauthorised access to it. All information you provide to us is stored on our secure servers. We do not store any payment information, all payment transactions are processed through either Barclaycard or Global Payments and will be encrypted using SSL technology.

17. Links to third party web sites

Our site contains links to and from the websites of our suppliers and other third parties. If you follow a link to any of these other websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies or for these third party websites. Please check these policies before you submit any personal data to these websites.

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19. Contact us

If you have any questions about this privacy notice, or if you wish to exercise your rights or contact the DPO, you can contact us by going to the Contact Us section of our website. Alternatively, you can write to Hadler Tours Limited, 36 Coldharbour Road, Bristol, BS6 7NA, marking it for the attention of the DPO.