We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal data is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal data.
We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal data unless at least one of the following requirements are met:
• You have given consent to the processing of your personal data for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your
photos/videos of experiences of our trips on social media and sharing emails of copassengers, that have agreed to stay in touch);
• The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior
to entering into a contract (for instance, when you request a quote from us);
• Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
• Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);
• Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (for instance, protecting our customers, our employees and other
individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour,
activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime,
fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes;
managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed
criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our
customers, colleagues, shareholders and other stakeholders).
We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal data, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal data for unrelated purposes, based on our legitimate Interest.
- There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate. - For circumstances where we may have other secondary purposes, for processing already existing data which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
- We will adopt an aggregate data model that allows us derive aggregated data from your personal information. Aggregated data is not considered personal data by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
- However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
- We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct legitimate Interest assessments and data protection impact assessments DPIA, prior to carrying out the proposed processing activity.
This information may also include:
- data inputted into forms and fields; - registrations for any accounts, - forum, - feedback mechanism, - social functionality, - newsletters or other features of our site; - usernames and passwords, - log-in / out history, and settings; - actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.
This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this. 8.1 Operate our website To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request. 8.2 Provide information and respond to enquiries To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide. 8.3 Bookings and other contracts To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide. 8.4 Payments To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us. 8.5 Communication with customers To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide. 8.6 Record Keeping To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so. 8.7 Manage and Improve our business To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; - to carry out surveys and analyse the results; - to run promotions and competitions; - undertake product or customer research/development; - to assist us in and help us to improve our sales, - editorial, advertising and marketing processes; - to carry out other business development and improvement activities; and - to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings. This is done on the basis of our legitimate interests in ensuring our business to Page 9 of 16 run efficiently. 8.8 Direct marketing To carry out direct marketing to you, see section 10.1 for further information. 8.9 Advertising To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual. 8.10 Anything you have specifically consented to 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. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so. 8.11 Consequences of Not Providing your Data You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.
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.
To determine 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 whether we can achieve those purposes through other means, and the applicable legal requirements.
If you would like to know more about our data retention policy, please ask us.
We (and any affiliate, subcontractor 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 to companies either within our group or to parties with whom we have a contract based on the Standard Contractual Clauses as published by the European Commission. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside the EEA. You can find out about what adequate safeguards these are by contacting us using the details provided in Section 4 of this privacy notice.
14.1 Our security measures We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including: - only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible; - using secured servers to store your information; - verifying the identity of any individual who requests access to information prior to granting them access to the information - using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions. Page 13 of 16 Unfortunately transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access. For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain 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. We also encourage you to be careful about who you give personal data to. We never contact you to ask you for your 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 if you someone purports to contact you in our name.
You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we 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 The Data Protection Commissioner for Ireland at https://www.dataprotection.ie/To exercise any of your rights below, please contact us as per the contact details provided in Section 4. You can also exercise some of these rights directly through our online form https://ttc.com/personal-data-request/ You may request, we tell you whether we are processing personal data about you, to tell you what personal data we are processing, for what purposes, from which sources we have collected it, who we disclose it to and to provide you with a copy of your personal data that we hold. We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case. The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy. 15.1 Rectification You have the right to have your personal data amended if it is inaccurate or incomplete.
15.2 Right to object 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.
15.3 Erasure You have the right to have your personal information deleted or removed in the following circumstances: - The data is no longer necessary for the purpose for which it was originally collected or otherwise processed; - Where you withdraw your consent, where consent was used as the legal basis for processing; - Personal data has been unlawfully processed; - When you object to the processing and we have no overriding legitimate interest for continuing the processing; - Erasure is required for compliance with a legal requirement; or - Data has been collected in relation to the offering of online services to a child. When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete. We have the right to refuse to act on a request of erasure if the data is necessary for: - Exercising the right of freedom of expression and information; - Compliance with a legal obligation; - The establishment, exercise or defence of legal claims; 15.4 Portability You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:: - the processing is based on consent or on a contract; and - the processing is carried out by automated means.
15.5 Restrict ProcessingYou have the right to obtain from us the restriction of processing of your personal data where one of the following applies: - You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data; - The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead; - We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise or defence of legal claims; - You have objected to processing pending the verification whether our legitimate grounds override yours. Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so. We will inform you before the restriction of processing is lifted.
15.6 Right to withdraw your consent You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 4 of this policy. See also section 12 for details as to how to object to our direct marketing communications.
This document, and all content of our websites is Copyright© 2019 Shamrocker Adventures Limited. ALL RIGHTS RESERVED.
Also known as the 'Cookie Directive', the instrument that defines the requirements for consent for cookies across the EU is Directive 2009/136/EC of the European Parliament and of the Council, an excerpt of which is reproduced below: “Member States shall ensure that the storing of information, or the gaining of access to Page 2 of 4 information already stored, in the terminal equipment of a subscriber or user is only allowed on condition that the subscriber or user concerned has given his or her consent, having been provided with clear and comprehensive information”. The UK introduced the amendments on 25 May 2011 through The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011. The relevant section is below: “6. - (1) Subject to paragraph (4), a person shall not store or gain information, or to gain access to information stored, in the terminal equipment of a subscriber or user unless the requirements of paragraph (2) are met. (2) The requirements are that the subscriber or user of that terminal equipment - (a) is provided with clear and comprehensive information about the purposes of the storage of, or access to, that information; and (b) has given his or her consent. (3) Where an electronic communications network is used by the same person to store or access information in the terminal equipment of a subscriber or user on more than one occasion, it is sufficient for the purposes of this regulation that the requirements of paragraph (2) are met in respect of the initial use. (3A) For the purposes of paragraph (2), consent may be signified by a subscriber who amends or sets controls on the internet browser which the subscriber uses or by using another application or programme to signify consent.” In summary, to comply with the law, we need to give clear information about what the cookies are used for, why, and obtain consent from you, the user. These are the objectives this Policy is set out to achieve.
As cookies are stored in the web browser used to access the website, users need to change the settings pertaining that browser in particular. Below are some of most popular browsers and corresponding links to the vendors’ guidance on disabling cookies: - Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-deletemanage-cookies https://support.microsoft.com/en-gb/help/278835/how-to-delete-cookie-files-in-internetexplorer - Firefox: https://support.mozilla.org/en-US/kb/how-do-i-turn-do-not-track-feature -Chrome: https://support.google.com/chrome/answer/95647?hl=en-GB - Safari: https://support.apple.com/kb/PH5042?locale=en_GB - Opera: Page 4 of 4 https://www.opera.com/help/tutorials/security/privacy/ In addition, Google Analytics gives you the option to install an opt-out browser add-on for Internet Explorer 11, Firefox, Chrome, Safari, and Opera: https://tools.google.com/dlpage/gaoptout
Several websites explain how cookies work, offering more detail, such as www.aboutcookies.org, and www.allaboutcookies.org. (we have no affiliation with these websites).