Privacy Policy

1.   INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of the website of Niche Travel Guides (www.nichetravelguides.com), including any information you may provide through this website when you make an enquiry, request information or purchase a product or service from us or any third party or take part in a prize draw or competition.

By providing us with your personal data, you represent and warrant to us that you are over 13 years of age. 

Benjamin Grundy (trading as Niche Travel Guides) (referred to as “we”, “us” or “our” in this privacy notice) is the data controller and is responsible for your personal data.

Contact Details

Full name: Benjamin Grundy (trading as Niche Travel Guides)

Email address: [email protected]

Postal address: 22 Homefield Road, London, W2 2LN, United Kingdom

If you have any concerns about our use of your personal information, you can make a complaint to us using these contact details.

You can also complain to the Information Commissioner’s Office (ICO) if you are unhappy with how we have used your data.

The ICO’s address:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Helpline Number: 0303 123 1113

ICO website: https://www.ico.org.uk

It is very important that the information we hold about you is accurate and up to date. 

Please let us know if at any time your personal information changes by emailing us at [email protected] 

2.  WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

• Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender and the same or similar information about other members of your family or travelling group.
• Contact Data may include your billing address, delivery address, email address and telephone numbers.
• Financial Data may include your bank account and payment card details.
• Transaction Data may include details about orders, purchases or payments made by you.
• Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
• Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
• Usage Data may include information about how you use our website, products and services.
• Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes 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 do not collect any information about criminal convictions and offences.

3.  HOW WE COLLECT YOUR PERSONAL DATA 

We collect data about you through a variety of different methods including:

• Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:
• [create an account on our site];

• request information, resources or marketing be sent to you;
• subscribe to our service; 
• purchase products or services from us or from a third party through us;
• give us feedback; or
• Automated technologies or interactions: As you use our site, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We may collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at https://www.nichetravelguides.com/cookie-policy for further details.
• Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:
• Identity, Contact, Financial, Transaction and Profile Data from suppliers of products and services from whom you request information through us or from whom you purchase products and services after visiting our website 
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4.  HOW WE PROCESS YOUR PERSONAL DATA  

We will only process your personal data when legally permitted under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018. 

We may process your personal data without your knowledge or consent where this is required or permitted by law.

The most common legal grounds upon which we rely to process your personal data are:

• Where it is necessary to perform a contract to which you are party or in order to take steps at your request prior to entering into a contract.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights and freedoms do not override those legitimate interests.
• Where it is necessary to comply with a legal obligation to which we are subject.

We do not rely on consent as a legal ground for processing your personal data except in relation to sending marketing communications to you via email or text message. You have the right to withdraw your consent to marketing at any time by following the opt-out links in any market message sent to you or by emailing us at [email protected] 

Purposes for processing your personal data  

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one legal ground, depending on the specific purpose for which we are using your data. Please email us at [email protected] 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 or to update the information that we hold about you as an existing customer	(a) Identity(b) Contact(c)  Profile	(a)  Performance of a contract with you or to take steps at your request prior to entering into a contract with you(b) Necessary for our legitimate interests to ensure that the information that we hold about you is accurate and up to date
To provide information and to make suggestions and recommendations to you about products or services that you have requested or which may be of interest to you. The suppliers of those products and services may be us or third parties selected by you or us.	(a) Identity(b) Contact(c) Technical(d) Usage(e) Transaction(f) Profile(g) Marketing and Communications	Performance of a contract with you or to take steps at your request prior to entering into a contract with you Necessary for our or third parties’ legitimate interests to develop our or third parties’ products or services and grow our business
To process and deliver your order including:(a) Manage payments, fees and charges(b) Collect and recover money owed to usThis may include sharing your personal data with third party suppliers of goods and services	(a) Identity(b) Contact(c) Financial(d) Transaction(e) Marketing and Communications	(a) Performance of a contract with you(b) Necessary for our or third parties’ legitimate interests to recover debts owed
To manage our relationship with you which will include:(a) Notifying you about changes to our terms or privacy policy(b) Asking you to leave a review or take a survey	(a) Identity(b) Contact(c) Profile(d) Usage (e) Transaction(f) Marketing and Communications	(a) Performance of a contract with you(b) Necessary to comply with a legal obligation(c) Necessary for our or third parties’ legitimate interests to study how customers use products or services supplied by us or third parties, and to inform our marketing strategy
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity(b) Contact(c) Technical(d) Profile(e) Usage	(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 content and advertisements to you and measure and understand the effectiveness of our advertising	(a) Identity(b) Contact(c) Profile(d) Usage(e) Transaction(f) Marketing and Communications	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, products/services, marketing, customer relationships and experiences	(a) Technical(b) Usage(c) Transaction	Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

Marketing communications 

You will only receive marketing communications from us if you have:

1. if you provided us with your contract details; 
2. given us your consent to send you marketing communications; and
3. you have not withdrawn your consent to receive marketing communications. 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us to stop sending you marketing communications at any time by following the opt-out links on any marketing message sent to you or by emailing us at [email protected]

Change of purpose  

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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us at [email protected] 

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground on which processing of your personal data for that new purpose is permitted.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

• Service providers who provide us with IT and system administration services.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities based in the United Kingdom and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

• Third parties to whom we sell, transfer, or merge parts of our business or our assets. 
• Third party suppliers of products and services from whom you have requested information or with whom you have placed orders or entered into contracts (although, as set out above, we will only share your personal data with any third parties for marketing purposes where you have given your express opt-in consent to such data sharing). 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS OF PERSONAL DATA

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Some of our third party service providers may be based outside the European Economic Area (EEA) so, if we share your personal data with them, this will involve a transfer of your personal data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
• Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
• Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY  

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. 

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 such data. 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 suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION  

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. 

At the end of the appropriate retention period for your personal data, we will permanently delete or securely destroy your personal data. To determine the appropriate retention period, 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. By law we are required to keep certain basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Section 9 below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR DATA PROTECTION RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. 

These include:

• Your right of access – You have the right to ask us for copies of your personal data
• Your right to rectification – You have the right to ask us to rectify personal data you think is inaccurate. You also have the right to ask us to complete personal data you think is incomplete.
• Your right to erasure – You have the right to ask us to erase your personal data in certain circumstances.
• Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
• Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal data in certain circumstances.
• Your right to data portability – You have the right to ask that we transfer the personal information toy have us to another organization, or to you, in certain circumstances.

You can see more about these rights at: 

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at [email protected].

You will not have to pay a fee to exercise your data protection rights. However, we may charge a reasonable fee for the administrative costs of complying with your request if it is manifestly unfounded or excessive or if you request further copies of your personal data following an access request. If we decide to charge a fee we will contact you promptly and inform you. 

We may also refuse to comply with requests that are manifestly unfounded or excessive.

We may need to request specific information from you to help us confirm your identity. 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.

We will usually comply a lawful request within one month of receipt. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. 

We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

11. COOKIES  You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.