This policy explains the what, how, and why of the information we collect when you visit one of our websites, or when you use our Services. It also explains the specific ways we use and disclose that information. We take your privacy extremely seriously, and we never sell any client data to third parties.
These definitions should help you understand this policy. When we say “we,” “us,” “our,” and “Spear Travels,” we are referring to Jetclub Ltd trading as Spear Travels and Broads Travel. We provide travel agency services for leisure and business travellers to plan and book trips worldwide (the “Services”). When we say “Client,” we are referring to the person or entity that is registered with us to use the Services. When we say “you,” we are referring either to a Client or to some other person who uses our Services. An “Operator” is a carefully selected third party travel provider that we work closely with as an agent on behalf of our Clients to book and supply their travel requirements. “Personal Information” means any information that identifies or can be used to identify you directly or indirectly, including, but not limited to, first and last name, date of birth, email address, gender, occupation or other demographic information. A “Distribution List” is a list of Clients and all associated information related to them (for example, email addresses).
- Questions & Concerns
If you have any questions or comments, or if you want to update, delete, or change any Personal Information we hold, or you have a concern about the way in which we have handled any privacy matter, please contact us by postal mail or email at:
The Spear Travels Group
Attn. Marketing Department
50 Mere Green Road,
- What information will we collect and use?
By using our Services, we will collect and use information about you and any other persons considered to be part of your travel party. This information includes your enquiry and booking details and information about the use of our Services. Listed below are the types of information we collect and how we collect them.
(c) Information from your use of our Services: We may receive information about how and when you use our Services, store it in log files or other types of files associated with your enquiries and bookings, and link it to other information we collect about you. This type of information helps us to improve our Services for both you and for all of our Clients.
(e) Web beacons: We use web beacons on our websites and in our emails. When we send marketing emails to Clients, we may track behaviour such as who opened the emails and who clicked the links. This allows us to measure the performance of our email campaigns and to improve what content we feature for specific segments of Clients. Web beacons allow us to collect information about when you open the email, your IP address, your browser or email client type, and other similar details.
(f) Information from other sources: From time to time we may obtain information about you from third party sources, such as public databases, social media platforms, third party data providers and our joint marketing partners. We take steps to ensure that such third parties are legally permitted or required to disclose such information to us. Examples of the information we may receive from other sources include: demographic information, device information (such as IP addresses), location, and online behavioural data (such as information about your use of social media websites, page view information and search results and links). We use this information, alone or in combination with other information (including Personal Information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products and services.
- How will your information be used?
We, partner Operators and other service providers that we work with (as described in more detail in the ‘Who will we share your information with?’ section below), may use your information to:
(a) Provide quotes for our Services and those of our partner Operators, as well as subsequently providing these Services to you once booked.
(b) To communicate with you about your enquiries/bookings and provide customer support.
(c) Analyse how you use our Services.
(d) Assess the effectiveness of our marketing activities and the marketing activities we carry out on behalf of partner Operators.
(e) Understand your behaviour based on the information available to us and to send or show you information, offers and promotions for the products or Services which we believe are most likely to interest you.
(f) To promote use of our Services to you and others. In addition, we may use information we collect in order to suggest additional features of our Services that you might consider using.
(g) To send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email we send.
(h) To bill and collect money owed to us. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different payment method. We use third parties for secure card payment processing, and we send billing information to those third parties to process your card payments.
(i) To protect the rights and safety of our Clients and third parties, as well as our own.
(j) To meet legal requirements, including complying with court orders and other appropriate legal mechanisms.
(k) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
(l) To prosecute and defend a court, arbitration, or similar legal proceeding.
(m) To respond to lawful requests by public authorities, including to meet national security or law enforcement requirements.
- When can we use your information?
We collect and use your information in the following situations:
(a) Where our use of your information is necessary for us to perform the contract that we have with you.
(b) Where our use of your information is for the purposes of our legitimate interests and we have made sure that your information, and your rights in relation to that information, are protected.
(c) Where we believe it is necessary to use your information to comply with a legal obligation to which we are subject.
(d) Where we have your consent.
We will rely on your consent to:
- Use your information for marketing to you by email and other methods of electronic communication from time to time in accordance with your data choices.
Where we rely on consent to use your information, you have the right to withdraw that consent at any time. Please see the ‘Your choices and rights’ section of this policy for more details.
- The period for which we will keep your information
We will keep your information for as long as is necessary for us to fulfil the purposes that we describe in this policy. As a general rule, however, we will keep:
(a) The information you provide when you make a booking with us, together with any updates you make to that information, for a period of 3 years from the date of return travel;
- Who will we share your information with?
We may share your information within the Spear Travels Group. We may also share your information for the purposes described in this policy with:
(a) Service Providers. Sometimes, due to the nature of the business sector we operate in, we have to share your information with our third party Service Providers, who help us provide and support our Services. For example: partner Operators, third party websites, analytics providers, payment processors, hosting services, content delivery services and advertising and media companies to enable them to show you adverts or offers which may interest you, including online, and mailing houses so that we can send you information or offers in the post. These third party Service Providers enter into a contract that requires them to use your Personal Information only for the provision of services to us and in a manner that is consistent with this policy.
(b) Our professional advisors.
(c) Any law enforcement agency, court, regulator, government authority or other third party where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
(d) Any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your information uses it in a manner that is consistent with this policy.
We promise we’ll never share your details with anyone else.
- Transferring your information internationally
Your personal information may be transferred internationally. Sometimes we will need to transfer your information out of the United Kingdom, for example, we outsource some of our IT services to the USA. Countries to which we transfer information may have different standards to control how your information is used and protected and these standards may not be as strict as those in place in the United Kingdom. If we transfer your information to a country which does not have data protection laws which offer an adequate level of protection for your information, we will make sure that the organisation which receives your information is a participant in the Privacy Shield Framework, put in place appropriate safeguards to protect your information, or otherwise ensure that we can transfer your information in a way that complies with data protection law.
- Public Information and Third Party Websites
(a) Our Blog. We have public blogs on our websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, please contact us. If we are unable to remove your information, we will tell you why.
(b) Social media platforms. Our websites include social media features. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features are either hosted by a third party or hosted directly on our website. We also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them.
We may, from time to time, offer competitions or other promotions on our websites or through social media. Participation in our promotions is completely voluntary. Information requested for entry may include personal contact information such as your name, address, date of birth, phone number, email address, and similar details. We use the information you provide to administer our promotions. We may also, unless prohibited by the promotion’s rules or law, use the information provided to communicate with you about our Services.
- Your choices and rights
You have a number of rights in relation to your information, and can make a number of choices about how we collect and use it. For example, you can decide not to receive marketing material from us, tell us how you want to receive marketing communications from us, and object to some of the ways in which we use your information.
You have the right to contact us to:
(a) Access and update the contact and personal details we hold about you.
(b) View your transaction history.
(c) Opt-out of receiving marketing communications from us.
(d) Ask that we erase or restrict our use of your information.
(e) Request that we provide your information to you in a commonly used electronic format and to have that information transmitted directly to another organisation (this is known as the right to ‘data portability’).
- Notice of Breach of Security
If a security breach causes an unauthorized intrusion into our systems that materially affects you, then Spear Travels will notify you as soon as possible and later report the action we took in response.
- Safeguarding Your Information
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Our credit card processing vendor uses security measures to protect your information both during the transaction and after it is complete. Our vendor is certified as compliant with card association security initiatives.
- We Operate in the United Kingdom
By using our Services, you understand and consent to the collection, storage, processing, and transfer of your information to us in the United Kingdom and those third parties with whom we share it as described in this policy.
- Accuracy and Retention of Data
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your Personal Information. We will retain your information for as long as needed to provide you with our Services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Agreements.
We will give an individual access to any Personal Information we hold about them within 30 days of any request for that information. Individuals may request to access, correct, amend or delete information we hold about them by contacting us. Unless it is prohibited by law, we will remove any Personal Information about an individual at their request. There is no charge for an individual to access or update their Personal Information.
- Who we are
We are Jetclub Limited trading as Spear Travels and Broads Travel, a company registered in England under number 1711255. Our registered office is at 75 Corbets Tey Road, Upminster, Essex RM14 2AJ. We are the Data Controller.
What are cookies?
Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by online service providers in order to (for example) make their websites or services work, or to work more efficiently, as well as to provide reporting information.
Cookies set by the website owner or service provider (in this case, Spear Travels Group) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website or service you are using (such as advertising, interactive content and analytics). The third parties that set these third party cookies can recognise your computer both when it visits the website or service in question and also when it visits certain other websites or services.
Cookies served through our Websites
The specific types of first and third party cookies served through our Websites and the purposes they perform are described in further detail below:
Essential Website Cookies
These cookies are strictly necessary to provide you with services available through our websites and to use some of its features, such as access to secure areas. Because these cookies are strictly necessary to deliver the websites, you cannot refuse them without impacting how our websites function. You can block or delete them by changing your browser settings, as described under the heading “How can I control cookies?” in the Cookie Statement.
Performance and Functionality Cookies
These cookies are used to enhance the performance and functionality of our websites but are non-essential to their use. However, without these cookies, certain functionality may become unavailable.
Analytics and Customization Cookies
These cookies collect information that is used either in aggregate form to help us understand how our websites are being used or how effective our marketing campaigns are, or to help us customize our websites and applications for you in order to enhance your experience.
Advertising (Targeting) Cookies
These cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed, and in some cases selecting advertisements that are based on your interests. For further information, see the section of the Cookie Statement entitled “Targeted online advertising”.
Other tracking technologies
We and our third party partners may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”) and other tracking technologies. These are tiny graphics files that contain a unique identifier that enable us to recognise when someone has visited our Websites or, in the case of web beacons, opened an e-mail that we have sent them. This allows us, for example, to monitor the traffic patterns of users from one page within our Websites to another, to deliver or communicate with cookies, to understand whether you have come to our Websites from an online advertisement displayed on a third-party website, to serve targeted advertisements to you and others like you, to improve site performance, and to measure the success of marketing campaigns. While you may not have the ability to specifically reject or disable these tracking technologies, in many instances, these technologies are reliant on cookies to function properly; accordingly, in those instances, declining cookies will impair functioning of these technologies.
Targeted online advertising
We have engaged one or more third party service providers to track and analyse statistical information from interactions with our Websites. We also partner with one or more third parties (such as advertisers and ad networks) to manage and serve advertising on other sites.
How can I control cookies?
You have the right to decide whether to accept or reject cookies.
Website Cookie Preference Tool: You can exercise your Website cookie preferences by visiting the TRUSTe preference centre by clicking this link: http://preferences-mgr.truste.com/
Disabling Most Interest Based Advertising: Most advertising networks offer you a way to opt out of Interest Based Advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com
Do Not Track: Some Internet browsers – like Internet Explorer, Firefox, and Safari – include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT” signals have not been adopted, our Websites do not currently process or respond to “DNT” signals. Spear Travels takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard. To learn more about “DNT”, please visit https://allaboutdnt.com/
How often will you update this Cookie Statement?
The date at the bottom of this Cookie Statement indicates when it was last updated.
Where can I get further information?
Updated 02 May 2018