For the purposes of EU and UK data protection laws and any applicable national implementing laws, regulations and secondary legislation relating to the processing of personal data (together “Data Protection Law”), the data controller is SKYJUNXION DMCC of Jumeirah Lakes Towers, P.O. Box: 338003, Dubai, United Arab Emirates.
LEGAL BASIS FOR PROCESSING
We will only use your personal data when the law allows us to. Most commonly we will use your personal data in the following circumstances:
· To fulfil our contractual obligations to you.
· Where it is necessary for our legitimate business interests (or those of a third party) and your interests and fundamental rights do not override those interests.
· To comply with a legal obligation.
To the extent we process your personal data for any other purposes, we ask for your consent in advance or require that our partners obtain such consent.
PERSONAL DATA WE MAY COLLECT ABOUT YOU
We may collect and process personal data about you. Personal data, or personally identifiable information, means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data). We collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data: includes first name, surname, user name or similar identifier, gender, date of birth.
Contact Data: includes address, telephone number and email address.
Financial Data: includes payment card details.
Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us.
Travel Data: includes names of guests travelling with you and your preferences for your stay, etc
Technical Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this Website or the Services.
Profile Data: includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
Usage Data: includes information about how you use our Website and Services, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website and Services (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Marketing and Communication Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Location Data: We also use GPS technology to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in your settings.
Special Category Data: We do not collect, store and/or use special category data about you. i.e. 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. We also do not collect information about criminal convictions and offences. We will only collect and use such data where we have obtained explicit consent from you.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
HOW PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you including via:
Direct Interactions: When you access the Website, you may give us Identity, Contact, Financial Data and Travel Data when you fill in forms or correspond with us by post, phone, email or otherwise. This includes personal data you provide when you register to use our Website or to receive our newsletter, subscribe to use our Services, create an account to use our Website or Services, request marketing to be sent to you, search for a product or place an order on our Website, participate in discussion boards or other social media functions on our Website, enter a competition, promotion or survey, attend a conference or webinar, give us feedback or contact us and when you report a problem with our Website or Services.
Purchases: If you make purchases via our Website or within any Services, or register for an event or webinar, we may require you to provide your Identity, Contact, Financial, Travel and Transaction Data.
Automated Technologies or Interactions. As you interact with our Services, Website or emails, we automatically collect Technical Data about your device, browsing actions, patterns, Location Data and Usage Data. We collect this personal data by using cookies, server logs, web beacons, pixels, and similar technologies about your device, and your use of our Website and Services. We may also receive Technical Data and Location Data about you if you visit other websites using our cookies. Please see the Cookie section below for further details.
Use of our other websites: We may receive personal data about you if you use any of the other websites we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with data collected on this Website.
PERSONAL DATA WE RECEIVE FROM OTHER SOURCES
We work closely with third parties (including, for example, business partners, providers of travels services, hotels, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive the following personal data about you from them:
Technical Data: from analytics providers, advertising networks and search information providers.
Contact, Transaction and Financial Data: from providers of technical, payment and delivery services.
Identity and Contact Data: from providers of chat/communication/helpdesk services with customers.
Email Communications and Contact Data: from email communications service providers.
Business Contact and Financial Data: from CRM service providers who manage contacts and keep a record of communications/ interactions with customers.
Contact Data and Financial Data: from cloud accounting systems that store emails and names of persons sent invoices by email.
Travel Data, Location Data, Technical Data: from providers of travel services and travel related services to which you have given us permission to collect data from within your settings or the privacy policies of these other online services. For example, this can be via social media or by choosing to send us data when accessing our Website or services from your smartphone; or it can be from the integrations and connections that you choose to install when using the Website or Services.
PERSONAL DATA WE COLLECT FROM OTHER SOURCES
We also collect personal data about you from publicly available sources. We may combine this information with personal data provided by you. This helps us update, expand, and analyse our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. We also use this for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying Contact Data. The personal data we collect includes:
Identity, Contact and Profile Data: that is published about you on social media profiles: LinkedIn.
COOKIES AND OTHER WEB TECHNOLOGIES
What are cookies
A cookie is a small amount of data that a website you visit places on your computer. Web pages have no memory. If you are surfing from page to page within a website, you will not be recognised as the same user across pages. Cookies enable your browser to be recognized by our Website. So cookies are mainly used to remember the choices you have made – choices such as the language you prefer and the currency you use. They will also make sure you are recognized when you return to a website. Cookies can be “persistent” or “session” cookies. We use persistent cookies and session cookies.
A persistent cookie is stored on a user’s device in between browser sessions which allows the preferences or actions of a user across the website (or in some cases across different websites) to be remembered. We use persistent cookies to save your login information for future logins to the Website or Services.
A session cookie allows our Website or Services to link your actions during a browser session. We use session cookies to enable certain features of the Website or Services, to better understand how you interact with the Website or Services and to monitor aggregate usage by users and web traffic routing on the Website. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Website or Services and then close your browser.
Which cookies we use and why
The table below explains the cookies we use and why we use each of them.
|__cf_bm||Cloudflare||Analytics cookies/Functional||This cookie, set by Cloudflare, is used to support Cloudflare Bot Management.||30 mins|
|__cfruid||Cloudflare||Analytics cookies /Functional||Cloudflare sets this cookie to identify trusted web traffic.||Session|
|hubspotutk||Hubspot||Tracking cookies||This cookie keeps track of a visitor’s identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor.||6 months|
|_undefined||Wistia||Analytics cookies /Functional||Wistia sets this cookie to collect data on visitor interaction with the website’s video-content, to make the website’s video-content more relevant for the visitor.||Persistent|
You can set up your browser options, to stop your computer accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use the whole of the Website or all functionality of the Services.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
Do not track
We do not support Do Not Track (“DNT”).
Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the “Preferences” or “Settings” page of your web browser.
As well as using cookies, our Website sometimes uses web beacons. A web beacon is a tiny graphic image of just one pixel that’s delivered to your computer either as part of a web page request or in an HTML email message. Either directly or through service providers, we use these pixels as part of our online advertisements either on our Website or on third-party websites to learn whether a user who is being shown an online advertisement also makes a reservation; to track conversion with partner websites and to analyse the traffic patterns of users to optimise the travel-related services we bring to you.
USES MADE OF PERSONAL DATA
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 bases 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 basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing|
|To register you as a new customer||(a) Identity (b) Contact||(a) Performance of a contract with you|
|To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to us||(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)|
|To enable travel service providers to provide services to you on our behalf: (a) To process and confirm your travel reservations(b) To disclose personal data about you to hotel, airline, cruise, car rental, and other travel suppliers whose products you have purchased,||(a) Identity Data(b) Contact Data(c)Travel Data (d) Financial Data(e) Transaction Data||(a) Performance of a contract with you (b) Necessary for our legitimate interests (to enable travel service providers to provide you with services you have ordered.) Please note we have not placed any limitations on these travel service providers from using or disclosing your personal data. Therefore, we encourage you to review the privacy practices of any travel service provider whose products you purchase on the Website. In addition, these travel service providers may also contact you as necessary to obtain additional information about your confirmed reservations.(c) Necessary to comply with a legal obligation.|
|To enable you to partake in a prize draw, competition or complete a survey||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications||(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 this Website (including troubleshooting, data analysis, testing, system maintenance, support, updates, reporting and hosting of data)||(a) Identity(b) Contact(c) Technical||(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 Website and Services content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our Website and Services, marketing, customer relationships and experiences||(a) Technical (b) Usage||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 that may be of interest to you||(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications||Necessary for our legitimate interests (to develop our Services and grow our business)|
We will not sell or rent your personal data to anyone.
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.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURE OF YOUR PERSONAL DATA
· Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you to provide services such as IT and system administration services, email communications, hosting services, backup services, credit card processing, research, development, marketing and customer support.
· Travel service providers to provide and process services you request or in the event that you make a new, or update an existing travel reservation, as necessary, in order to respond to your request for customer service, they may access your personal data. We only share information about travel services either reserved or purchased via our Website or Services.
· Analytics and search engine providers that assist us in the improvement and optimisation of our Website and Services.
· Professional advisors acting as service providers to us in relation to the Website or Services – including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance and accounting services.
· Tax authorities, regulators and other authorities who require reporting of processing activities in certain circumstances.
· Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose personal data about identifiable individuals to our advertisers, but we may provide them with Aggregated Data about our users (for example, we may inform them that 250 men aged over 25 have clicked on their advertisement on any given day). We may also use such Aggregated Data to help advertisers reach the kind of audience they want to target (for example, women living in London). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience.
· Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.
Personal data we disclose to third parties. We may disclose your personal data to third parties:
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
· If we or a member of our group of companies or substantially all of their assets are acquired by a third party, in which case personal data held by them about their customers will be one of the transferred assets.
· Including Aggregated Data in the normal course of operating our business; for example, with other Website or Services users, our customers or publicly to show trends or benchmark the general use of our Website and Services.
In the event that you make a new, or update an existing travel reservation, a third party service provider, as necessary, in order to respond to your request for customer service, may access your Information.
Our Services are global and your personal data may be stored and processed in any country where we have operations, our staff are located or where we engage service providers engaged in, among other things, the fulfilment of your order, the processing of your payment details or the provision of support services. This will involve a transfer of your personal data to countries outside of your country of residence, where data protection rules are different from those of your country of residence.
Processing of your personal data will involve a transfer of data to countries outside the European Economic Area (“EEA“), Switzerland or the UK.
Our Website and Services are accessible via the internet and may potentially be accessed by anyone around the world. Other users may access the Website or Services from outside the EEA, Switzerland or the UK. This means that where you chose to post your personal data on our Website or within the Services, it could be accessed from anywhere around the world and therefore a transfer of your personal data outside of the EEA, Switzerland or the UK may be deemed to have occurred.
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. For example all information you provide to us is stored on our secure servers. Any credit card information or payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website or Services, you are responsible for keeping this password confidential. We ask you not to share any password with anyone. 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 personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we will endeavour to protect your personal data, we cannot guarantee the security of your personal data transmitted to our Website or the Services. Any transmission is at your own risk. Once we have received your personal data, we will use strict procedures and security features to try to prevent unauthorised access.
LINKS TO OTHER WEBSITES
Marketing: We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
Promotional Offers from us: We will send you marketing emails if you “opt in” to receive marketing emails when registering on our Site, or if you have enquired about, or purchased any of our goods or services from us and you have not opted out of receiving such marketing.
Third Party Marketing: We will obtain your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opt out: Please note that, if you change your mind about being sent marketing emails you can “opt out” at any time by clicking the “unsubscribe” link at the bottom of any marketing email. Once you “opt out”, you will no longer receive any marketing emails from us. We will continue to communicate with you regarding your service billing and support via email and where we send push notifications from time to time in order to update you about any service updates, events and promotions we may be running. If you no longer wish to receive these communications, please disable these in the settings on your device.
AGE OF USERS
We do not knowingly collect any information from anyone under eighteen years of age. If you are under eighteen, please do not submit any information to our Website or Services.
The use of any of our Services is only allowed with the valid consent of a parent or a guardian. When we receive information from a child under the age of 18, we reserve the right to delete it.
Our Website and Services are not intended for use by anyone under eighteen years of age and we never collect personal data from persons under 18 years of age, unless it is provided by a parent or guardian and then only with their consent. The only personal data collected would be, first name, surname, date of birth and passport information where this is necessary in order for a travel reservation to be made by an adult that includes anyone under 18 years of age.
If you are under eighteen, please do not submit any personal data to our Website or Services. If we discover that we have received personal data from anyone under the age of 18, without the required consent from a parent or guardian), we reserve the right to delete such personal data.
We retain personal data for as long as reasonably necessary to fulfil the purposes for which it was provided or collected, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect of our relationship with you, to comply with law enforcement requests, maintain security, prevent fraud and abuse, resolve disputes, enforce our legal agreements, or fulfil your request to “unsubscribe” from further messages from us.
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, regulatory, tax, accounting or other requirements.
This will be for as long as we provide access to the Website or Services to you, your account with us remains open or any period set out in any relevant contract you have with us. After you have closed your account or ceased using the Services as set out below.
We will retain some anonymised information after your account has been closed and we may use this for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Please note: After you have closed your account or deleted information from your account, any information you have shared with others will remain visible. We do not control data that other users may have copied from the Website or Services. Your profile may continue to be displayed in the services of others (e.g. search engine results) until they refresh their cache.
You have the right under Data Protection Law, free of charge, to request:
· Access to your personal data.
· Rectification or deletion of your personal data.
· A restriction on the processing of your personal data.
· Object to the processing of your personal data.
· A transfer of your personal data (data portability) in a structured, machine readable and commonly used format.
· Withdraw your consent to us processing your personal data, at any time.
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 could 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.
REPRESENTATION FOR DATA SUBJECTS IN THE EU AND THE UK
We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://prighter.com/q/18985410
By email: email@example.com
By post: Skyjunxion DMCC, Jumeirah Lakes Towers, P.O. Box: 338003, Dubai, United Arab Emirates.
Third Party Supplier List
|Wistia Inc.||Website analytics services||https://wistia.com/privacy|
|Cloudflare Inc.||Website analytics services||https://www.cloudflare.com/en-gb/privacypolicy|
|Hubspot Inc.||CRM and Marketing||https://legal.hubspot.com/privacy-policy|