Privacy Policy
Travolution UK Ltd Privacy Policy
Travolution UK Ltd (a company registered in the United Kingdom withregistered number 16729512 )(" Travolution UKLtd ", " we ", " us "," our ") are committed to protecting and respecting yourprivacy.
This privacy policy (the " Policy ") sets out thetypes of personal data we collect and use when you access and visit anyof the websites offered by Travolution UK Ltd (each a" Website " together the " Websites ") orwhen you interact with us directly.
Travolution UK Ltd is the controller of your personal data collectedand this policy also explains how we may use that information and, incertain circumstances, who we may share it with.
The websites under Travolution UK Ltd are:
travolutionawards.com
travolutionsummit.com
travolutionevents.com
1. Introduction
This Policy covers our collection, processing and use of personaldata when you use any of our Website. When you supply any personal datato us we have legal obligations towards you in the way we use that data.For ease of reading, we have divided this Policy into severalsections:
Introduction
What is personal data and what do we collect
How and why do we use/share your information
For how long do we keep your information
Security
Your Rights
Contact Details
It is important that you read this Policy together with any otherprivacy notice or fair processing notices that we may provide on theWebsite at or around the time that we collect or process personal dataabout you (for example, fair processing notices that we may display toyou at the time that you sign up to receive e-mail updates from us) sothat you are fully aware of how and why we are using that data.
This Policy supplements other notices including our Websites’respective Terms and Conditions and Cookies Policies and is not intendedto override or replace them.
By visiting or otherwise using our Websites, you are agreeing to thepractices set out in this Policy. If, for any reason, you do not agreeto the terms of this Policy, please stop using the Websites.
We reserve the right to revise or amend this Policy at any time toreflect changes to our business or changes in the law. Where thesechanges are significant we will endeavour to let registered users of theWebsites know. However, it is your responsibility to check this Policybefore each use of our Websites – for ease of reference the top of thisPolicy indicates the date on which it was last updated.
Please note that our Websites are not directed at children under theage of 13 (each a "
Child
together"
Children
") and we do not knowingly collect personalinformation about Children. If you believe we have collected personalinformation about your Child, you may contact us at
2. What is Personal Data and what do we collect?
What is personal data?
Where this Policy refers to ‘personal data’ it is referring to dataabout you from which you could be identified – such as your name, yourdate of birth, your contact details and even your IP address.
By law all organisations in the UK are obliged to process yourpersonal data in certain ways and to ensure that you are given anappropriate amount of information about how they use it. You also havevarious rights to seek information from those organisations about howthey are using your data, and to prevent them from processing itunlawfully. For more information about these rights, please see the‘Your Rights’ section of this Policy.
Data we collect from you when you use the Websites
Voluntary Provision of Data
When you voluntarily supply your personal data to us, for examplewhere you; use the Websites to upload or send personal data (by fillingout a form, subscribing to a publication or newsletter, taking part inan online survey, posting a comment, entering a competition, or engagingin similar activities in which you volunteer data about yourself);contact us by post, telephone, email or SMS; report a problem with aWebsite; we may collect, store and use the personal data that youdisclose to us.
The information we collect from you may include your title, name,address, e-mail address, company, job title, birthday, phone number,financial and credit card information – but will depend on preciselywhat details you volunteer to us and the precise nature of the reasonfor your submission of that data.
Automated Collection of Data
We may also collect information about you when you visit the Websitesthrough the use of technologies such as cookies. The following areexamples of information we may collect:
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information about your device, browser or operatingsystem;
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your IP address;
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information about links that you click and pages you view on ourWebsites;
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length of visits to certain pages;
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subjects you viewed or searched for;
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page response times;
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records of download errors and/or broken links;
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page interaction information (such as details of your scrolling,clicks, and mouse-overs);
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methods used to browse away from the page; and
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the full Uniform Resource Locators (URL) clickstream to, throughand from the Websites (including date and time).
We use the data described above for several different reasons.
Firstly, we use it to ensure that the Websites work properly (e.g. tomanage technical functionality, such as enabling you to log in tosections that you access with a username and password) and that you areable to receive the full benefit of them. Second, we use the data tomonitor online traffic and audience participation across theWebsites.
Cookies that relate to these functions will be deployed on yourcomputer automatically, either as you access the Websites or as youengage the relevant functionality. If you block these cookies thencertain aspects of the site may not operate properly (as they rely onthe cookies to work).
We undertake these activities because we have a legitimate interestin doing so and, for most of the cookies in question, because we need todo so in order to deliver the parts of the Websites that you are tryingto access to you.
Third Party Cookies and Resources
We also use the services of third parties to help us to collectvarious data about you and the way that you use the Websites in order toenable us to better understand your interests – both so that we canproduce and serve content to you that we think will be of interest toyou, and so that we can ensure that you are shown adverts delivered bythird parties which are more likely to be of interest to you.
Where we use cookies to deliver these kind of services, the deliveryof those cookies will be subject to your consent and you will be giventhe opportunity to refuse those cookies prior to them being deployed toyour computer. You are also able to remove cookies from your computer atany time.
For details of the cookies that we use on the Website, what thosecookies do, and the privacy policies of the third parties which providethem (where relevant) please see our Cookies Policy.
Please note that, while you have to option to consent to specificindividual cookies that, unless specifically set out in our CookiesPolicy, we rely on our legitimate interests as our condition forprocessing your personal data on the basis set out in this section(specifically that, where you consent to receiving those cookies, thatwe have a legitimate interest in using the data that they provide to usto optimise the Websites’ content and to ensure that you are served withrelevant commercial communications as you use them). You can stopproviding us with that data at any time by removing the relevant cookiesfrom your computer.
3. How and why do we use/share your information
We will only use your personal data when the law allows us to. Mostcommonly we will use your personal data in the followingcircumstances:
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Where you have asked us to do so, or consented to us doingso;
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Where we need to do so in order to perform a contract we haveentered into with you;
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Where it is necessary for our legitimate interests (or those of athird party) and your fundamental rights do not override thoseinterests; and
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Where we need to comply with a legal or regulatoryobligation.
Core Services
We will use your personal data to provide various services that yourequest from us. Depending on which services you tell us that you wantto receive this may include sending you printed publications, sendingyou e-mail updates and newsletters, enabling you to receive news of andapply for job vacancies, and enabling you to attend and participate inevents.
Where an individual nominates you for an award which is to bepresented at one of our events, or where you are suggested as apotential judge at such events, then we will process your data on thebasis that we have a legitimate interest in doing so in order to ensurethat awards are fairly awarded to the most worthy winners. Where we wishto process your personal data for more than a brief period of time (if,for example we decide to add your details to a short list of potentialwinners or judges) then we will notify you that this processing istaking place and give you the opportunity to ask us to stop if you arenot happy for it to continue.
Where you provide us with your personal data in this way we will useit to the extent necessary to fulfil the terms of the contracts that weenter into with you.
Where you subscribe to receive e-mail updates from us which representmarketing communications we will use your personal data on the basisthat you have consented to use using your data for this purpose. You canwithdraw this kind of consent at any time – for more information see‘ Your Rights ’ below.
Where you register for or attend one of our events, we may use yourcontact details to send you marketing communications about future eventsthat we consider to be similar to those you have registered for orpreviously attended. You may opt out of receiving such communication atany time – for more information see ‘ Your Rights ’below.
Sharing your information
Depending on how and why you provide us with your personal data wemay share it in the following ways:
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we may share your personal information with any member of ourcompany group, which means our subsidiaries, our ultimate holdingcompany and its subsidiaries, as defined in section 1159 of the UKCompanies Act 2006;
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with selected third parties who we sub-contract to providevarious services and/or aspects of the Website’s functionality, such aswhere third party plugins provide functionality such as message boardsor image hosting services (see “ Service Providers ”below);
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with analytics and search engine providers that assist us in theimprovement and optimisation of this Website as described above;and
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with third parties who we contract with for the provision ofevent management services in connection with events we organise or host.Depending on the type of event that you come to this may include sharingyour name with individuals who are due to speak or present at an eventso that they can tailor their content to suit the anticipatedaudience.
We will not share your information with third parties in order forthat third party to provide direct marketing communications to you,unless it relates to a specific activity which we are undertaking with athird party (e.g. a competition where a third party is providing theprize) and you have provided your consent for that use. Such activitymay have its own terms and conditions relating to the way in which yourinformation may be used, which you will be notified of at the relevanttime.
Where you attend an event your details may be visible to otherattendees as part of the arrangements and logistics on the day, forexample at events with set seating arrangements your details may be setout on a publicly available seating plan.
We may also disclose your personal information to third parties inthe following events:
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if we were to sell or buy any business or assets, in which casewe might disclose your personal information to the prospective seller orbuyer of such business or assets as part of that sale;
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if Travolution UK Ltd or substantially all of its assets areacquired by a third party, in which case personal information held by usabout our customers will be one of the transferred assets;
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if we are under a duty to disclose or share your personalinformation in order to comply with any legal obligation, or if we areasked to provide your details to a lawful authority in order to aid inthe investigation of crime or disorder; and/or
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in order to enforce or apply our Website’s terms of use or termsand conditions; or to protect the rights, property, or safety of ourcompany, our customers, or others. This includes exchanging informationwith other companies and organisations for the purposes of fraudprotection and credit risk reduction.
Service Providers
Our service providers provide us with a variety of administrative,statistical, and technical services. We will only provide serviceproviders with the minimum amount of personal data they need to fulfilthe services we request, and we stipulate that they protect thisinformation and do not use it for any other purpose. We take theserelationships seriously and oblige all of our data processors to signcontracts with us that clearly set out their commitment to respectingindividual rights, and their commitments to assisting us to help youexercise your rights as a data subject. The following is a list of ourmajor service providers:
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Where you subscribe to one or more streams of e-mailcommunications from us (such as newsletters or other e-mails) we useMailJet system to store your details and to manage the sending of thosecommunications to you.
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Where you register to come to one of our events we are likely touse Version Two’s ‘Evessio’ platform to manage your registration andattendance details.
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Where you use any part of our Websites that involve jobvacancies, your details (including details of any listings orapplications that you make) will be stored on and processed via Madgex’s‘Job Board’ system. Your details will also be passed to a company orindividual to which you make any form of application.
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Our Websites are hosted on third party servers which are providedto us by a variety of hosting service providers, all of those serversare locate within the EEA (or where they are provided on a ‘cloud’ basisappropriate mechanisms are in place to ensure that your data is keptsecure) for more information on these mechanisms see ‘Security’below.
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Where you subscribe to receive a weekly digital or any printedpublication, we will share your details with various fulfilment partners(which will depend on which publication you subscribe to) who handletasks such as printing and distribution for us. We may also pass yourdetails to organisations which handle telephone contacts for us, suchorganisations may be used to contact you if/when your subscription isdue to lapse to remind you that you will need to renew that subscriptionif you wish to continue receiving the relevant publication.
Links to third party sites
Where we provide links to third party websites that are notaffiliated with the Travolution UK Ltd those sites will have their ownprivacy policies and will not be covered by this Policy. Such sites areout of our control and if you access them using the links provided, theoperators of these sites may collect information from you that could beused by them, in accordance with their own privacy policies. Pleasecheck these policies before you submit any personal data to thosewebsites.
4. For how long do we keep your information?
We will hold your personal information on our systems only for aslong as required to provide you with the services you have requested orto perform the purpose for which that data was collected.
For more specific descriptions of how long we will retain your datafor specific activities please see the details provided below in respectof certain key areas of processing:
Magazine Subscriptions
Where you subscribe to receive a weekly digital or any printpublication from Travolution UK Ltd we will hold your details for theduration of your subscription. We will also keep your details for aperiod of up to six years after your subscription has lapsed as part ofour books and records – which enable us to properly account for ourbusiness each year, and which we need to keep on file in order ensurethat we are able to properly respond to any disputes which may ariserelating to that subscription (or the fulfilment of it by our fulfilmentagents).
Newsletter Subscriptions and other e-mailcommunications
Where you subscribe to receive a newsletter or similar e-mailcommunication, we will hold your e-mail address for the full duration ofthat subscription in order to ensure that we are able to deliver thatsubscription to you. We may also hold other details about you which youprovide to us (such as your name and title) to personalise thosecommunications to you.
If you unsubscribe from a publication (by way of sending us an‘opt-out’ message telling us that you do not wish to receive it in thefuture) we will keep a record of your e-mail address indefinitely inorder to ensure that we know that we must not send similarcorrespondence to it going forwards (this practice is often referred toas ‘supressing’ an e-mail address) – for more information see ’YourRights’ below.
Use of Online Job Boards
Where you use online job boards featured on our Websites to advertiseyour availability for, or to apply directly to, job vacancies we willuse that data to advertise your ability and to send any applicationsthat you may make to the relevant recipients. That data will be held andmade available on the job board for so long as you maintain an activeprofile. You can deactivate your profile at any time, either by ‘hiding’your data or by deleting your profile entirely.
If you give us your consent to send you future updates aboutvacancies that may be relevant to you (which you may do) we will useyour details in the same way as described in ‘Newsletter Subscriptions’above. Where we do this, we will use the details that you have suppliedto us in order to ensure that we are supplying you with details of jobsthat are relevant to the interests/qualifications that you havedescribed to us. You can unsubscribe from these e-mails at any time –however, please note that this is a separate service to hosting yourprofile, and that you will need to unsubscribe from these e-mailsseparately if you wish to stop receiving them. You can do this by usingthe ‘unsubscribe’ link contained in each e-mail – for more informationsee ’ Your Rights ’ below.
Applications to the Travolution UK Ltd
Where you approach us to enquire about employment opportunities or toapply for an advertised vacancy at Travolution UK Ltd we will keep yourdetails and your application on file irrespective of whether you aresuccessful or not. We do this on the basis that we have a legitimateinterest in ensuring that we are able to contact you should a suitablevacancy arise in the future.
Usually we will keep your details in this fashion for a period oftwelve months or less. However, if you are a candidate who we considerhas particularly specialist skills that may be relevant to our businessin the future (or where you have gained additional experience orqualifications) then we may keep your details on file for 6 months.
You are always entitled to ask us not to do this, or to have usdispose of your data if you do not wish for us to retain it – for moreinformation, please see the section on yourrights below
Events and Awards
Where you attend one of our events (as a guest or as a judge) and/orare awarded an award at such an event then we will keep your details onfile for up to six years to ensure that we are able to accurately recordwho attended.
If you are awarded an award at such an event then we will keep yourdetails in a similar fashion in order to ensure that we have an accuraterecord of previous winners. We will keep such details on file for solong as we continue to operate the same or similar events. We do this onthe basis that we have a legitimate interest in being able to withhold alist of previous winners for reference purposes.
Please note that where you supply sensitive personal data to us aspart of your attendance at an event (such as disclosing dietarypreferences to us which indicate that you suffer from a particularhealth condition) we will retain that data on file for future referenceto ensure that we respect those preferences in the event that you attendfuture events. You may ask us to stop holding that data at any time andwe will always honour and respect those requests.
In some circumstances you can ask us to delete your data: see’ Your Rights ’ below for further information.
In some circumstances we may anonymise your personal data (so that itcan no longer be associated with you) for research or statisticalpurposes, in which case we may use this information indefinitely withoutfurther notice to you.
5. Security
Please note that some of our service providers may be based outsideof the United Kingdom. These service providers may work for us or forone of our suppliers and may be engaged in, among other things, thefulfilment of your order, the processing of your payment details, thehosting of one or more of the Websites, and the provision of supportservices.
By submitting your personal information, you agree to this transfer,storing or processing.
Where we transfer your data to a service provider that is outside ofthe UK to a country that does not provide the same level of dataprotection as the UK law, we seek to ensure that appropriate safeguardsare in place to make sure that your personal data is held securely andthat your rights as a data subject are upheld. In most cases thesafeguard which we rely on is the ‘Standard Contractual Clauses’permitted by the GDPR. Specifically, we use the International DataTransfer Agreement which has been approved for use by the ICO and meansthe party to whom we are transferring the data are contractually obligedto protect your personal data to the same level of protection as itwould be afforded in the UK. If you would like more information aboutthe mechanisms via which your personal data is transferred, pleasecontact
If we ever give you (or where you have chosen) a password whichenables you to access certain parts of the Websites, you are responsiblefor keeping this password confidential. We ask you not to share apassword with anyone.
6. Your Rights
As a data subject you have a number of rights in relation to yourpersonal data. Below, we have described the various rights that youhave, as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that wehold which relates to you (you may have heard of this right beingdescribed as a " subject access request ").
Please note that this right entitles you to receive a copy of thepersonal data that we hold about you in order to enable you to checkthat it is correct and to ensure that we are processing that personaldata lawfully. It is not a right that allows you to request personaldata about other people, or a right to request specific documents fromus that do not relate to your personal data.
You can exercise this right at any time by writing to us using thecontact details set out here and telling us that you are making asubject access request. You do not have to fill in a specific form tomake this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that wehold about you which you believe is incorrect or inaccurate. You mayalso ask us to erase personal data if you do not believe that we need tocontinue retaining it (you may have heard of this right described as the“right to be forgotten”).
Please note that we may ask you to verify any new data that youprovide to us and may take our own steps to check that the new data youhave supplied us with is right. Further, we are not always obliged toerase personal data when asked to do so; if for any reason we believethat we have a good legal reason to continue processing personal datathat you ask us to erase we will tell you what that reason is at thetime we respond to your request.
You can exercise this right at any time by writing to ususing the contact details set out here and telling us that you aremaking a request to have your personal data rectified or erased and onwhat basis you are making that request. If you want us to replaceinaccurate data with new data, you should tell us what that new data is.You do not have to fill in a specific form to make this kind ofrequest.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimateinterest (see the sections of this Policy above which explain how andwhy we use your information ) you are entitled to ask usto stop processing it in that way if you feel that our continuing to doso impacts on your fundamental rights and freedoms or if you feel thatthose legitimate interests are not valid.
You may also ask us to stop processing your personal data (a) if youdispute the accuracy of that personal data and want us verify thatdata’s accuracy; (b) where it has been established that our use of thedata is unlawful but you do not want us to erase it; (c) where we nolonger need to process your personal data (and would otherwise disposeof it) but you wish for us to continue storing it in order to enable youto establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a goodlegal reason to continue processing personal data that you ask us tostop processing, we will tell you what that reason is, either at thetime we first respond to your request or after we have had theopportunity to consider and investigate it.
You can exercise this right at any time by writing to ususing the contact details set out here and telling us that you aremaking a request to have us stop processing the relevant aspect of yourpersonal data and describing which of the above conditions you believeis relevant to that request. You do not have to fill in aspecific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold aboutyou, which is processed by automated means, to a third party you maywrite to us and ask us to provide it to you in a commonly usedmachine-readable format.
Because of the kind of work that we do and the systems that we use,we do not envisage this right being particularly relevant to themajority of individuals with whom we interact. However, if you wish totransfer your data from us to a third party we are happy to considersuch requests.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other regulatedelectronic messages) you have the right to opt-out at any time. You cando this by using the ‘unsubscribe’ link that appears in the footer ofeach communication (or the equivalent mechanism in thosecommunications).
Alternatively, if for any reason you cannot use those links, or ifyou would prefer to contact us directly – you can unsubscribe by writingto us at
You have the right to be informed about the existence of anyautomated decision making and profiling of your personal data, and whereappropriate, be provided with meaningful information about the logicinvolved, as well as the significance and the envisaged consequences ofsuch processing that affects you.
Exercising your rights
When you write to us making a request to exercise your rights we areentitled to ask you to prove that you are who you say you are. We mayask you to provide copies of relevant ID documents to help us to verifyyour identity.
It will help us to process your request if you clearly state whichright you wish to exercise and, where relevant, why it is that you areexercising it. The clearer and more specific you can be, the faster andmore efficiently we can deal with your request. If you do not provide uswith sufficient information then we may delay actioning your requestuntil you have provided us with additional information (and where thisis the case we will tell you).
7. Contact Details
If you have any queries regarding this Policy, if you wish toexercise any of your rights set out above or if you think that thePolicy has not been followed, please contact us at
The Marketing Manager
Travolution UK Ltd
353 Buckingham Avenue,
Slough,
England,
SL1 4PF
You may also wish to lodge a complaint to the InformationCommissioner’s Office (the ICO), who are the UK regulator for dataprotection issues (
www.ico.org.uk