This document and all content of our website is Copyright © 2018 Horizon Sail Limited. All Rights Reserved. Last updated 30 May 2019.
1. Introduction and About Us
– What information we collect about you
– How we collect that information
– What we use information for
– How and with whom we share your information
– How we protect your information
– What choices you have in relation to the collection of your information
We will only use and retain your personal information with your consent and in accordance with applicable data privacy laws.For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) we will be either the “data processor” or “data controller” for any personal information you provide to us in connection with our relationship. The precise role we will be assuming is dependent on the context of our relationship with you and the purpose of the processing being undertaken.This Privacy Notice does not apply to, and Horizon Sail is not responsible for, any third party websites which may be accessible through links from this website (please see section 12 – Online services below for more information).
2. Terms used in this policy
– the recipients of any travel services booked with us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you);
– applying to us for a job or work placement;
– supplying services to us where this involves any personal data.In addition, this policy applies to any personal information collected from third parties where we are the controller of such information.
4. How we collect your personal data
“Personal data” is any information that can be used to identify you or that we can link to you.We will only collect personal information in compliance with your local data protection laws. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.
Generally, this collection will occur:
– when you deal with us either in person, by telephone, letter, email;
– when you visit any of our websites; or
– when you connect with us via social media.
We may collect personal information about you:
– when you purchase or make enquiries about travel arrangements or other products and services;
– when you enter competitions or register for promotions;
– when you subscribe to receive marketing from us (e.g. newsletters);
– when you request brochures or other information from us; or
– when you provide information, or use our services, on social media.
In some circumstances, it may be necessary for us to collect personal information about you from third parties such as, information or service providers, publicly available records, and the third parties described in section 7 (Disclosure of your information) below. This includes where a person makes a travel booking on your behalf which includes travel services to be used by you (e.g. a booking made for you by your friend or family member). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking.
Where you make a travel booking on behalf of another person/s (e.g. a family or group booking), you agree you have obtained the consent of the other person/s for Horizon Sail to collect, use and disclose the other person’s personal information in accordance with this policy and that you have otherwise made the other person/s aware of this policy. You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.
We may collect information from other sources, such as social media platforms that share information about how you interact with our social media content, and any information gathered through these channels will be governed by the privacy settings, policies, and/or procedures of the applicable social media platform, which we strongly encourage you to review.
When you use our online services, we may collect the following:
– information which is automatically provided by your browser to our servers;
– information record on our web servers about your interaction with our website and pages viewed;
– information we capture or place on your computer or generate using cookies or other technologies on our website; and
– information you input into forms and fields on our website.We will handle any unsolicited information in accordance with law, including destroying or de-identifying such information where we are required to do so.
5. How we use your personal data
Depending upon the circumstances in which we gather your personal data, we may use your information to provide you with services and information, or for any of the following purposes:
To enable you to make bookings and to provide you with Horizon Sail’s services that you request. This is done on the basis of our legitimate interests in ensuring our business is run efficiently;
To respond to your enquiries and provide information to you regarding our website, systems and services, including to respond to booking enquiries and searches for travel services, and to keep you updated. This is done on the basis of our legitimate interests in ensuring our business is run efficiently;
To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites;
To carry out our obligations including the collection of payments and administering accounts arising from any contracts entered into between you and us;
To facilitate our internal business operations, including to fulfil our legal or regulatory requirements;
To maintain and develop our relationship with you by communicating with you anything concerning enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. This includes providing relevant marketing communications related to Horizon Sail, and other information or materials, that you request from us or which we feel may interest you where you have indicated that you would like to receive these from us. This is done on the basis of our legitimate interests in ensuring our business is run efficiently;
For our business purposes, including data analysis, submitting invoices, detecting, preventing, and responding to actual or potential fraud, illegal activities, or intellectual property infringement;
To maintain and update our records including our database of contacts;
To evaluate, recruit, and hire personnel;
To help us analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, products, and services;
To measure the popularity and effectiveness of services such as newsletters, in order to improve what we offer to you and other recipients;
To carry out direct marketing to you, see section 8 for further information;
To ensure that content from our online services is presented in the most effective and secure manner for you;
For research, planning, service development, security or risk management;
For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis;
As we believe reasonably necessary or appropriate to: comply with our legal obligations; respond to legal process or requests for information issued by government authorities or other third parties; or protect your, our, or others’ rights.
You are not obligated to provide your personal information, however, we may not be able to do some or all of these things without your personal data.
6. What types of data we may process
Personal information has the meaning given under your local data protection law, and, where the GDPR applies, the meaning of personal data given under the GDPR. Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf.
We therefore typically process the following types of personal information about you:
– Contact information (such as name, residential/mailing address, telephone number, email address);
– Details of any other persons travelling with you, travel preferences, and enquiry/complaint details;
– Sensitive information such as health, special needs, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us;
– Payment account information (credit/debit card details, including card type, card number, security number and expiry date);
– Passport and visa information;
– Loyalty program / frequent flyer details;
– Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or feedback sent to us, or performance of any contract;
– Information collected or generated out of any surveys we conduct;
– Information collected or generated out of any competitions or promotions we run;
– Other details relevant to your travel arrangements or required by the relevant travel service providers (e.g. airlines and accommodation or tour providers).
We also collect information that is required for use in the business activities of Horizon Sail, including for example, financial details necessary in order to process various transactions, and other relevant personal information you may elect to provide to us.
We will only collect sensitive information in compliance with your local data protection laws, with your explicit consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorised to do so by law.We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.
This information may include:
– your IP address (a unique identifier allocated to your computer for your connection to the internet);
– your computer device details (PC, tablet, smartphone, watch etc.);
– the make and version of web browser you are using;
– your operating system;
– your time-zone;
– your browser plug-ins;
– any web-page you came from, identified as the referrer web page address by your web browser;
– page response times;
– pages and parts of pages you visit;
– usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, etc.;
– services and products you viewed;
– length of visit to website and pages;
– page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).
7. Disclosure of your personal data & how third parties may use your data
We may, in providing our services and operating our business, allow access to your personal data to the different entities within Horizon Sail for our internal administrative purposes such as billing, promoting our events and services, and providing you with services, provided in all instances that such processing is consistent with applicable laws.
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this policy and, in particular, as set out below, and in accordance with applicable laws. Note that, in this policy, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.
We may disclose your personal data to third parties in the following circumstances:
– When you have consented to us sharing your personal data in this way;
– When we deem necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking or services for you or other contract with or in respect of you;
– When such sharing is provided for under contract, including our terms and conditions for any particular service that we may provide to you;
– To collect payments to be made by you;
– To investigate and respond to complaints;
– When such sharing is to law enforcement bodies or other government authority;
– When we need to enforce or apply our terms and conditions to which you have agreed (or other terms that have been agreed to apply to our relationship with you);
– When it is necessary to protect the rights and interests, property, or safety of Horizon Sail, our clients or others;
– When it is relevant in the circumstances to disclose the information to parties with whom we have co-promotional arrangements (such as jointly sponsored events, external venues, or caterers);
– When our agents, suppliers, contractors or sub-contractors who assist us in providing our services require such information (e.g. airlines, coach, ferry or train companies, hire companies, cruise companies, tour operators etc.). For example in fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions.The identities of these parties may change from time to time and are engaged so we can provide our services to you;
– If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.
– When we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, accounts or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services).
Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.
If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.
We also provide anonymous statistical information about users of our websites and related usage information to reputable third parties, including analytics and search engine providersWe may share information that does not reasonably identify you or your organisation as permitted by applicable law.
We may supply personal data to a government authority or regulator where required to:
– comply with a legal requirement,
– for the administration of justice,
– for the purposes of customs, visas and immigration, or
– where reasonably required to protect your vital interests or
– enforce any booking or other contract.
We may disclose your personal data where otherwise required by or permitted by law.
8. Direct marketing
We do not use or disclose your personal data for direct marketing purposes unless: we have obtained your consent to this, such as through an opt-in box on any form or website of ours; and/or
you have made a booking with us and there is a legitimate interest to do so.
In addition to data protection law if we use your personal information for direct marketing purposes we may also be subject to additional rules that regulate direct marketing. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.
8.1 Direct marketing by us
We will use your personal data to send you marketing information (including adverts and details of promotions, new products, forthcoming events or competitions) about travel services offered by us. We will only contact you in the manner you agreed to (e.g. by email). You will be given the opportunity on every e-communication we send you to indicate that you no longer wish to receive our direct marketing material.
8.2 Direct marketing by third partiesWe may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing.
9. Period for retaining your personal data
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.In determining the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and the applicable legal requirements.
10. Security and location of data
10.1 Security measures
We are committed to safeguarding and protecting personal information (in both physical and electronic forms) and we implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal information provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal information transmitted, stored or otherwise processed.
Our security measures include:
– only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymized basis wherever possible;
– using secure servers to store your information;
– verifying the identity of any individual who requests access to information prior to granting them access to information;
– using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions;
– requiring that all employees or contractors of Horizon Sail and third party providers with access to confidential information are subject to access controls and confidentiality obligations.
Horizon Sail regularly reviews security technologies and will strive to protect your personal information as fully as we protect our own confidential information.
Horizon Sail is not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.
Whilst we continually strive to ensure that our systems and controls are updated to reflect technological changes, the transmission of information via the internet or email is not completely secure, and if you submit any information to us over the internet by email you do so entirely at your own risk. We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by email.
If you communicate with us using a non-secure web platforms, you assume the risks that such communications between us are intercepted, not received, delayed, corrupted or are received by persons other than the intended recipient.
You can help us to keep your information secure by:
– Maintaining anti-virus and other malware protection software on your computers and other devices, and maintaining your own measures to protect your personal data. Please do not include sensitive personal data in any e-mails you may send to us, including payment card information;
– Being careful about who you give personal data to. We never contact you to ask you for sensitive personal data, such as payment card information, or sensitive personal data such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know immediately if someone claims to contact you in our name.
We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.
10.2 Location of your personal dataWe (or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within the European Economic Area (“EEA”).
We will only send your personal data outside the EEA if parties with whom we have a contract and with whom we share personal data in accordance with section 7 (Disclosure of your personal data & how third parties may use your data) are located, or have their servers located, outside your country or the country from which the data was provided.
If we transfer your information outside the EEA in this way, we ensure that we have in place adequate safeguards in respect of such transfers to ensure that your privacy rights continue to be protected.
11. Cookies notice
We may, for example, collect information about the type of device you use to access our online services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on our online services, the web pages you view immediately before and after you access our online services, whether and how you interact with content available on our online services, and the search terms you enter on our online services.
Horizon Sail’s website sets different types of cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer. Our website may use the following types of cookies:
Session cookies last only for the duration of your time on our website and are deleted when you close your browser. These facilitate tasks such as website security, allowing a website to identify that a user is navigating from page to page, or basic functionality.
Permanent or Persistent cookies
Permanent or persistent cookies last after a user has closed a browser, and allow a website to remember user actions and preferences. Sometimes these cookies are used to provide targeted advertising based upon the browsing history of the device. We use persistent cookies to allow us to analyse customer visits to our site. These cookies help us to understand how customers arrive at and use our website.
Third party cookies
Strictly necessary cookies
These cookies are essential in enabling users to move around the website and use its features, and ensuring the security of the experience. Without these cookies services users have asked for, such as purchasing products and managing accounts, cannot be provided. These cookies don’t gather information about users for the purposes of marketing.
Performance cookies collect information about how visitors use a web site, for instance which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is only used to improve how a website works, the user experience and to optimise any advertising. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
Functionality cookies allow the website to remember choices you make (eg. your username). The information these cookies collect is anonymised and user’s browsing activity is not tracked across other websites. By using our websites you agree that we can place these types of cookies on your device, however you can block these cookies using your browser settings.
Targeting cookies collect information and are usually placed by third party advertising networks. They remember that you have visited a website and this information is shared with other organisations such as media publishers. These organisations do this in order to provide you with targeted adverts more relevant to you and your interests.
Most web browsers allow you to exercise some control to restrict or block cookies through the browser settings. You should note however, that this may affect your ability to use certain parts of our website or services. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit https://www.allaboutcookies.org.
Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version.
12. Online services
In addition to our website, mobile applications and other online services, which we control directly, we also use and provide links to websites which are controlled by third parties, which may include: Instagram, LinkedIn, Twitter, Facebook and YouTube, where we have certain Horizon Sail accounts and profiles. If you use or follow a link to any of these third-party websites, please be aware that these websites have their own privacy policies and that we cannot accept any responsibility for their use of information about you.
Our online services may include integrated content, links to content or social media features and widgets (such as “Like” and “Share” buttons/widgets) provided and operated by third party companies (eg. Facebook). Social media features may collect information such as the page you are visiting on our website or mobile application, your IP address, and may set cookies to enable the social media feature to function properly. If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them.
We engage third parties that support the operation of our online services, such as analytics providers. These third parties may use technologies to track your online activities over time and across different websites and online platforms. Please see section 11 (Cookies Policy) above for more information.
13. Your rights
You have certain non-contractual rights under applicable data protection legislation, and we have a duty of care to ensure that your personal data is accurate and up to date. Therefore, please contact us (using the details set out in Section 16) to update or correct your information if this changes or if you believe that any information that we have collected about you is inaccurate.
Below we have set out a summary of the rights you may contact us about. If you contact us about these rights, we may ask for proof of your identity before we act, and may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on UK Information Commissioner: http://www.ico.org.uk/.
You can request:
– Access to the personal data we hold about you and information on the purposes;
– Amendments, corrections or updates to your personal data;
– The deletion or removal of your personal data;
– To obtain and re-use your personal information for your own use;
– Personal data that you have provided to us in a structured, commonly used and machine-readable format;
– Restriction of the use and processing of your personal data.
In certain circumstances, the law may allow us the right to refuse your request.
You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.
Where you have consented to our processing of certain personal data, you can at any time withdraw such consent and/or tell us not to contact you with updates and information regarding our products and services.
If you would like to exercise any of the rights set out in this section, please contact us using the details set out in Section 16 below.
The laws we comply with are regulated by the UK Information Commissioner and in addition to your rights above, you may submit a complaint to the Information Commissioner, details of which can be found at https://ico.org.uk/global/contact-us. If you make a privacy complaint, we will respond to let you know how your complaint will be handled. We may ask you for further details, consult with other parties and keep records regarding your complaint.
14. Changes and Status of this policy
15. Further information
To find out more about Horizon Sail please visit https://www.horizon-sail.com/.Horizon Sail at your request, can confirm what information we hold about you and how it is processed. If Horizon Sail does hold personal data about you, you can request that information by contacting us using the details below.
16. Contacting Us
Post: Horizon Sail Ltd
28 Orchard Road, St Annes on Sea
Lancashire, FY8 1PF
Tel: +44 7408 851 908