Effective date: 25 May 2018
We committed to protecting and respecting your privacy. This policy (together with our terms and conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
For the purpose of the Data Protection Act 1998 (the Act) and the EU General Data Protection Regulation 2016/679 (GDPR), the data controller is:
Zaļā iela 1
The Lawful Basis for the Processing:
We provide a service which enables you to enquire, and then enter into booking arrangements with ourselves ( smartofficedist) and our approved partners. Our service requires us to collect your personal data in order for us to perform our obligations under our contract with you and those with the partners who engage with our platform.
Information We may Collect from You and Why We Collect it:
When you make a booking or other purchase via this website, we will collect certain personal data about you and about any other person you include on your booking. The sort of personal data we collect will be information such as name, address, email address, telephone number, date of birth, and personal travel preferences. We need to collect this information in order to arrange the travel and other services you are requesting. In some cases, we may also need to collect more sensitive personal data such as information concerning medical conditions, disabilities and special requirements, so as to be able to consider your particular needs in relation to a booking.
We may also Collect Personal Data about You in the Following Circumstances:
If you enter a competition or promotion via this website, complete a survey, or if you report a problem with this website.
If we ask you for your contact details for future marketing use (which may be by email, post or phone text messages) or if you actively sign up to receive email newsletters from us (although you will be given the option to opt-out of such use).
If you contact us, we may keep a record of your email or other correspondence, and if you call us by telephone, we may monitor and/or record phone conversations for training and customer service reasons.
We may collect details of your visits to this website (including, but not limited to, traffic data and location data) whether this is required for our own purposes or otherwise, and the resources that you access.
We may collect information about your computer including, where available, your IP address, operating system and browser type, for system administration purposes and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We may collect other forms of data but only with your express consent (opt-in). We will use your data to inform you of news, offers, and events. You can unsubscribe from our news service at any time by pressing the unsubscribe link on our emails.
Transfer of your Information:
When you make a travel booking or other purchase via this website, certain of the personal data you provide will need to be passed to and processed and stored by relevant third parties, such as partner surf camps, so that they can provide you with the arrangements you require. Some of these third parties may be based 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.
We may disclose your personal information to any member of our Group for business purposes, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006, and to relevant third parties for the purpose of fraud protection and credit risk reduction.
How We Use Your Information:
smartofficedist is registered under the Data Protection Act (application status: under review).
We use information held about you for the purposes as stated within our Notification to the Office of the Information Commission, and in the following ways:
To carry out our obligations arising in connection with any contracts entered into between you and us, or between you and a third-party supplier;
To communicate with you regarding your booking or other purchase;
To ensure that content from our website is presented in the most effective manner for you and for your computer;
To allow you to participate in interactive features of our service, when you choose to do so.
To notify you about changes to our service;
For improving the quality of our service and the products offered via this website;
For internal research/analysis and customer profiling;
For resolving complaints and dealing with disputes;
For preventing and detecting fraudulent or criminal activity;
For debt collection or credit vetting;
Information we receive from other sources. We may combine this information with information you give to us and information we collect about you from other sources. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
If you have made an enquiry or purchase on this website, your personal data may be used by us and other Star Surf Camps companies to contact you by electronic means (e-mail or text message) with information and offers relating to products or services similar to those about which you enquired or which you purchased.
We will only do this if you did not opt out of such marketing at the point where we collected your contact details. If you have not made an enquiry or purchase, we will only send you information and offers by email or text message relating to products and services offered by Star Surf Camps companies if you sign up (opt in) to receive such marketing. The Star Surf Camps companies that may use your data for marketing purposes are:
For Travel and Travel-related Products and Services:
Errant Surf trading as Errantsurf.com;
smartofficedist trading as smartofficedist.com;
For Production and Manufacturing Services:
Supersaturated Studio trading as Supersaturatedstudio.com.
Opting Out Of Marketing Use:
You have the right at any time to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by ticking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by sending an unsubscribe request to firstname.lastname@example.org or The Data Management Department, Zaļā iela 1 LV-1010 Rīga Latvia.
Your Right to Access any Personal Data we hold:
You are entitled to ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. The Data Protection Act 1998 (the “Act”) gives you the right to check that your personal data is being processed lawfully (“subject access right”). Your subject access right can be exercised in accordance with the Act. Any subject access request must be made in writing to email@example.com. or The Data Management Department, Zaļā iela 1 LV-1010 Rīga Latvia. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We promise to respond to your request without delay and in any event within 30 days, the request is complex or you have made numerous requests in which case we may be able to extend our response time by a further 2 months.
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 website, 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. Any 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 our website, you are responsible for keeping that password confidential. We ask you not to share a password with anyone.
Links to Third-Party Websites:
Our website contains links to and from the websites of our principals, suppliers, advertisers 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.
Where you make a booking, appropriate personal data will be passed on to the relevant suppliers of your chosen arrangements together with any other third party who needs this information so that we can arrange for your holiday to be provided. Suppliers and other third parties are likely to include the following, depending on the arrangements booked:
Hotels and the providers of other forms of accommodation;
In-country transport operators;
Overseas ground agents;
Tour managers and guides;
Excursion and activity operators;
Travel insurance providers
Credit card companies / banks in respect of payments
The information may also be provided to government/ public authorities such as customs or immigration if required by them, or as required by law. We may also make personal data available to other companies who provide services on our behalf, such as mailing brochures and marketing material.
We only provide third parties with the personal data they require in order to deliver their services. Other than in relation to government / public authorities (over whom we have no control), we will take appropriate steps which are intended to ensure that anyone to whom we pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.
On-Site Advertising and Behavioural Advertising:
We use Google Analytics and other providers to provide us with statistical information about use and traffic on our websites and social media platforms. These services use IP addresses and other information from cookies to tell us, for example, the number of page views, number of users, what browsers users are using and location data of users. This statistical information allows us to understand our audiences, reach our target audiences, develop and customise our product and services, maximise compatibility for most of our users and determine how much to charge for advertising.
For analytics, we collect and process your information on the basis of our legitimate business and operational interest. Find out more information about our providers below:
Google — Including Analytics, Remarketing, AddServices and Maps
Tidio — Live Chat Programme
Facebook — Connect/ Pixelcode