EFR Leisure Travel respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.
Please also use refer to the Glossary that we have set out at the end of the Policy if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
This privacy notice aims to give you information on how EFR Leisure Travel collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you purchase travel services, when you sign up to our newsletter, when you take part in a competition.
This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
E.F.R. Travel Limited, a company registered in England & Wales with company registration number 04440987 with registered office 2nd Floor Nucleus House, 2 Lower Mortlake Road, Richmond, United Kingdom, WHI067Z trading as “LWC Holidays”, “Elegant Golf Resorts” and “Camberley Travel” is the data controller and responsible for your personal data (collectively referred to as “EFR Leisure Travel”, “we”, “us” or “our” in this privacy notice). Note that we have separate privacy policies in place for our other brands carried out under other trading names by E.F.R. Travel Limited.
We have appointed Craig Murray as data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: E.F.R. Travel Limited
Name or title of Data Privacy Manager: Craig Murray
Email address: firstname.lastname@example.org />Postal address: 43-45 High Road, Bushey Heath, Hertfordshire, WD23 1EE
Telephone number: 02084217090
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
This version was last updated on 25th June 2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
We collect the following special categories of personal data about you.
Details about your:
We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us from arranging the provision of the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and inform the supplier, in which case the cancellation terms of the relevant supplier will become applicable.
Where we need to collect personal data by law, or where we are acting as an agent and we need to collect personal data to enter you into a contract with the supplier of your chosen travel arrangements, 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.
In other words, where we require details from you in order to arrange for the provision of your chosen travel services, if you do not provide us with the necessary details then we will not be able to arrange for the provision of the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary data, we may not be able to arrange for the provision of your booking or we may have inform the supplier, who will be required to cancel your booking. We will notify you accordingly.
We use different methods to collect data from and about you including through:
A. Direct interactions – You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
C. Third parties – We may receive personal data about you from various third parties as set out below:
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:
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to explicit consent for the use of dietary information and sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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 ground 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 including basis of legitimate interest|
|To register you as a new customer.||
|Performance of a contract with you.|
|To process and deliver your booking including:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
|(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
(c) Explicit consent (for (f) only)
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey.
|(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|To enable you to partake in a prize draw, competition or complete a survey.||
|(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, reporting and hosting of data).||
|(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 content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
|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||
|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||
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|To monitor our communications with you in order to check any instructions given to us, for training purposes, for crime prevention, to improve the quality of our customer service and to defend legal claims.||
|(a) Necessary for our legitimate interests (to assist us in training our employees and defend our business in the event of a claim.
(b) Necessary to comply with a legal obligation
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
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).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can unsubscribe from our email marketing by clicking on the unsubscribe link found in all marketing emails or by contacting us at any time.
Where you opt out of receiving these marketing emails , this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.
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.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
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.
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.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.
For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
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. 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.
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.
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 requirements.
In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Request erasure 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.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact us
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 may 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.
We try to respond to all legitimate requests within one month. 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.
You have the right to: