PRIVACY POLICY
Last updated 22 May 2018.
The Travel Weekly Group (a company registered in the United
Kingdom with registered number 069277031) Travel Weekly Group are committed to
protecting and respecting your privacy.
This privacy policy (the “Policy”) sets out the types of
personal data we collect and use when you access and visit any of the websites
offered by the Travel Weekly group of companies (each a “Website” together the
“Websites”) or when you interact with our group companies directly. This policy
also explains how we may use that information and, in certain circumstances,
who we may share it with.
The Websites in the Travel Weekly Group are:
acornawards.co.uk
agentachievementawards.co.uk
aspiredigitalsummit.co.uk
aspireluxuryforum.co.uk
aspireluxuryforum.com
aspiretravelclub.co.uk
bestplacestoworkinhospitality.co.uk
bestplacestoworkinhospitality.com
britishtravelandhospitalityhalloffame.com
catererdigitalsummit.com
caterersubs.com
cateys.com
connectingtravel.com
foodservicecateys.com
gazetteers.com
globetravelawards.co.uk
hotelcateys.com
itcms.travel
jacobsmediagroup.com
northernball.co.uk
productexcellenceawards.co.uk
thecaterer.com
thecatererchristmas.com
travelanswerz.com
travelgbi.co.uk
travelgbi.com
travelweekly.co.uk
travelweeklyjobs.co.uk
travelweeklyjobs.com
travolution.com
travolutionsummit.co.uk
touringandadventure.com
weareconnections.com
1. Introduction
This Policy covers our collection, processing and use of
personal data when you use any of our Website.
When you supply any personal data to us we have legal
obligations towards you in the way we use that data. For ease of reading, we have divided this
Policy into several sections:
1. Introduction
2. What is
personal data and what do we collect
3. How and why
do we use/share your information
4. For how long
do we keep your information
5. Security
6. Your Rights
7. Contact
Details
It is important that you read this Policy together with any
other privacy notice or fair processing notices that we may provide on the
Website at or around the time that we collect or process personal data about
you (for example, fair processing notices that we may display to you at the
time that you sign up to receive e-mail updates from us) so that 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
intended to override or replace them (for this Website’s Cookies Policy please
click here).
By visiting or otherwise using our Websites, you are
agreeing to the practices set out in this Policy. If, for any reason, you do
not agree to the terms of this Policy, please stop using the Websites.
We reserve the right to revise or amend this Policy at any
time to reflect changes to our business or changes in the law. Where these changes are significant we will
endeavour to let registered users of the Websites know. However, it is your
responsibility to check this Policy before each use of our Websites – for ease
of reference the top of this Policy indicates the date on which it was last
updated.
Please note that our Website is not directed at children
under the age of 13 (each a "Child" together "Children")
and we do not knowingly collect personal information about Children. If you
believe we have collected personal information about your Child, you may
contact us at marketing@thecaterer.com and request that we cease processing
information about your Child.
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 data about you from which you could be identified – such as your name, your
date of birth, your contact details and even your IP address.
By law all organisations in the UK are obliged to process your
personal data in certain ways and to ensure that you are given an appropriate
amount of information about how they use it. You also have various rights to
seek information from those organisations about how they are using your data,
and to prevent them from processing it unlawfully. 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
example where you; use the Websites to upload or send personal data (by filling
out a form, subscribing to a publication or newsletter, taking part in an
online survey, posting a comment, entering a competition, or engaging in
similar activities in which you volunteer data about yourself); contact us by
post, telephone, email or SMS; report a problem with a Website; we may collect,
store and use the personal data that you disclose 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 precisely what
details you volunteer to us and the precise nature of the reason for your
submission of that data.
Automated Collection of Data
We may also collect information about you when you visit the
Websites through the use of technologies such as cookies. The following are
examples of information we may collect:
• information
about your device, browser or operating system;
• your IP
address;
• information
about links that you click and pages you view on our Website
• length of
visits to certain pages;
• subjects you
viewed or searched for;
• page
response times;
• records of
download errors and/or broken links;
• page
interaction information (such as details of your scrolling, clicks, and
mouse-overs);
• methods used
to browse away from the page; and
• the full
Uniform Resource Locators (URL) clickstream to, through and from this Website
(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. to
manage technical functionality, such as enabling you to log in to sections that
you access with a username and password) and that you are able to receive the
full benefit of them. Second, we use the data to monitor online traffic and
audience participation across the Website.
Cookies that relate to these functions will be deployed on
your computer automatically, either as you access the Website or as you engage
the relevant functionality. If you block these cookies then certain aspects of
the site may not operate properly (as they rely on the cookies to work).
We undertake these activities because we have a legitimate
interest in doing so and, for most of the cookies in question, because we need
to do so in order to deliver the parts of the Websites that you are trying to
access to you.
Third Party Cookies and Resources
We also use the services of third parties to help us to
collect various data about you and the way that you use the Website in order to
enable us to better understand your interests – both so that we can produce and
serve content to you that we think will be of interest to you, and so that we
can ensure that you are shown adverts delivered by third parties which are more
likely to be of interest to you.
Where we use cookies to deliver these kind of services, the
delivery of those cookies will be subject to your consent and you will be given
the opportunity to refuse those cookies prior to them being deployed to your
computer. You are also able to remove cookies from your computer at any time.
For details of the cookies that we use on the Website, what
those cookies do, and the privacy policies of the third parties which provide
them (where relevant) please see our Cookies Policy.
Please note that, while you have to option to consent to
specific individual cookies that, unless specifically set out in our Cookies
Policy, we rely on our legitimate interests as our condition for processing
your personal data on the basis set out in this section (specifically that,
where you consent to receiving those cookies, that we have a legitimate
interest in using the data that they provide to us to optimise the Websites’ content
and to ensure that you are served with relevant commercial communications as
you use them). You can stop providing us with that data at any time by removing
the relevant cookies from your computer.
3. How and why
do we use/share your information
Core Services
We will use your personal data to provide various services
that you request from us. Depending on which services you tell us that you want
to receive this may include sending you printed publications, sending you
e-mail updates and newsletters, enabling you to receive news of and apply for
job vacancies, and enabling you to attend and participate in events.
Where an individual nominates you for an award which is to
be presented at one of our events, or where you are suggested as a potential
judge at such events, then we will process your data on the basis that we have
a legitimate interest in doing so in order to ensure that awards are fairly
awarded to the most worthy winners. Where we wish to 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 potential winners or judges) then we will notify you
that this processing is taking place and give you the opportunity to ask us to
stop if you are not happy for it to continue.
Where you provide us with your personal data in this way we
will use it to the extent necessary to fulfil the terms of the contracts that
we enter into with you.
Where you subscribe to receive e-mail updates from us which
represent marketing communications we will use your personal data on the basis
that you have consented to use using your data for this purpose. You can
withdraw this kind of consent at any time – for more information see ‘Your
Rights’ below.
Sharing your information
Depending on how and why you provide us with your personal
data we may share it in the following ways:
• we may share
your personal information with any member of our company group, which means our
subsidiaries, our ultimate holding company and its subsidiaries, as defined in
section 1159 of the UK Companies Act 2006;
• with
selected third parties who we sub-contract to provide various services and/or
aspects of the Website’s functionality, such as where third party plugins
provide functionality such as message boards or image hosting services (see
“Service Providers” below); and
• with
analytics and search engine providers that assist us in the improvement and
optimisation of this Website as described above.
We will not share your information with third parties in
order for that third party to provide direct marketing communications to you,
unless it relates to a specific activity which we are undertaking with a third
party (e.g. a competition where a third party is providing the prize) and you
have provided your consent for that use. Such activity may have its own terms
and conditions relating to the way in which your information may be used, which
you will be notified of at the relevant time.
We may also disclose your personal information to third
parties in the following events:
• if we were
to sell or buy any business or assets, in which case we might disclose your
personal information to the prospective seller or buyer of such business or
assets as part of that sale;
• if Travel
Weekly or substantially all of its assets are acquired by a third party, in
which case personal information held by us about our customers will be one of
the transferred assets;
• if we are
under a duty to disclose or share your personal information in order to comply
with any legal obligation, or if we are asked to provide your details to a
lawful authority in order to aid in the investigation of crime or disorder;
and/or
• in order to
enforce or apply our Website’s terms of use or terms and conditions; or to
protect the rights, property, or safety of our company, our customers, or
others. This includes exchanging information with other companies and
organisations for the purposes of fraud protection and credit risk reduction.
Service Providers
Our service providers provide us with a variety of administrative,
statistical, and technical services. We will only provide service providers
with the minimum amount of personal data they need to fulfil the services we
request, and we stipulate that they protect this information and do not use it
for any other purpose. We take these relationships seriously and oblige all of
our data processors to sign contracts with us that clearly set out their
commitment to respecting individual rights, and their commitments to assisting
us to help you exercise your rights as a data subject. The following is a list of our major service
providers:
• Where you
subscribe to one or more streams of e-mail communications from us (such as
newsletters or other e-mails) we use Salesforce’s ‘Pardot’ system to store your
details and to manage the sending of those communications to you.
• Where you
register to come to one of our events we are likely to use Version Two’s
‘Evessio’ platform to manage your registration and attendance details.
• Where you
use any part of our Websites that involve job vacancies, your details
(including details of any listings or applications that you make) will be
stored on and processed via Madgex’s ‘Job Board’ system. Your details will also
be passed to an company or individual to which you make any form of
application.
• Our Websites
are hosted on third party servers which are provided to us by a variety of
hosting service providers, all of those servers are locate within the EEA (or
where they are provided on a ‘cloud’ basis appropriate mechanisms are in place
to ensure that your data is kept secure) for more information on these
mechanisms see ‘Security’ below.
• Where you
subscribe to receive a printed publication to you we will share your details
with various fulfilment partners (which will depend on which publication you
subscribe to) who handle tasks such as printing and distribution for us. We may
also pass your details to organisations which handle telephone contacts for us,
such organisations may be used to contact you if/when your subscription is due
to lapse to remind you that you will need to renew that subscription if you
wish to continue receiving the relevant publication.
Links to third party sites
Where we provide links to third party websites that are not
affiliated with the Travel Weekly Group those sites will have their own privacy
policies and will not be covered by this policy. Such sites are out of our
control and if you access them using the links provided, the operators of these
sites may collect information from you that could be used by them, in
accordance with their own privacy policies.
Please check these policies before you submit any personal data to those
websites.
4. For how long
do we keep your information?
We will hold your personal information on our systems only
for as long as required to provide you with the services you have requested or
to perform the purpose for which that data was collected.
For more specific descriptions of how long we will retain
your data for specific activities please see the details provided below in
respect of certain key areas of processing:
Magazine Subscriptions
Where you subscribe to receive a printed publication from a
member of the Travel Weekly group we will hold your details for the duration of
your subscription. We will also keep your details for a period of up to [six
years] after your subscription has lapsed as part of our books and records –
which enable us to properly account for our business each year, and which we
need to keep on file in order ensure that we are able to properly respond to
any disputes which may arise relating to that subscription (or the fulfilment
of it by our fulfilment agents).
Newsletter Subscriptions and other e-mail communications
Where you subscribe to receive a newsletter or similar
e-mail communication we will hold your e-mail address for the full duration of
that subscription in order to ensure that we are able to deliver that
subscription to you. We may also hold other details about you which you provide
to us (such as your name and title) to personalise those communications 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 the
future) we will keep a record of your e-mail address indefinitely in order to
ensure that we know that we must not send similar correspondence to it going forwards
(this practice is often referred to as ‘supressing’ an e-mail address) – for
more information see ‘Your Rights’ below.
Use of Online Job Boards
Where you use online job boards featured on our Websites to
advertise your availability for, or to apply directly to, job vacancies we will
use that data to advertise your ability and to send any applications that you
may make to the relevant recipients. That data will be held and made available
on the job board for so long as you maintain an active profile. 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 about
vacancies that may be relevant to you (which you may do we will use your
details in the same way as described in ‘Newsletter Subscriptions’ above. Where
we do this we will use the details that you have supplied to us in order to ensure
that we are supplying you with details of jobs that are relevant to the
interests/qualifications that you have described to us. You can unsubscribe
from these e-mails at any time – however, please note that this is a separate
service to hosting your profile, and that you will need to unsubscribe from
these e-mails separately if you wish to stop receiving them. You can do this by
using the ‘unsubscribe’ link contained in each e-mail – for more information
see ‘Your Rights’ below.
Applications to the Travel Weekly Group
Where you approach us to enquire about employment
opportunities or to apply for an advertised vacancy at the Travel Weekly Group
we will keep your details and your application on file irrespective of whether
you are successful or not. We do this on the basis that we have a legitimate
interest in ensuring that we are able to contact you should a suitable vacancy
arise in the future.
Usually we will keep your details in this fashion for a
period of twelve months or less. However, if you are a candidate who we
consider has particularly specialist skills that may be relevant to our
business in the future (or where you have gained additional experience or
qualifications) then we may keep your details on file for several years.
You are always entitled to ask us not to do this, or to have
us dispose of your data if you do not wish for us to retain it – for more
information, please see the section on your rights below
Events and Awards
Where you attend one of our events (as a guest or as a judge)
and/or are awarded an award at such an event then we will keep your details on
file for up to six years to ensure that we are able to accurately record who
attended.
If you are awarded an award at such an event then we will
keep your details in a similar fashion in order to ensure that we have an
accurate record of previous winners. We will keep such details on file for so
long as we continue to operate the same or similar events. We do this on the
basis that we have a legitimate interest in being able to withhold a list of
previous winners for reference purposes.
Please note that where you supply sensitive personal data to
us as part of your attendance at an event (such as disclosing dietary
preferences to us which indicate that you suffer from a particular health
condition) we will retain that data on file for future reference to ensure that
we respect those preferences in the event that you attend future events. You
may ask us to stop holding that data at any time and we 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 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.
5. Security
Please note that some of our service providers may be based
outside of the European Economic Area (the “EEA”). These service providers may work for us or
for one of our suppliers and may be engaged in, among other things, the
fulfilment of your order, the processing of your payment details, the hosting
of one or more of the Websites, and the provision of support services.
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 of the EEA we seek to ensure that appropriate safeguards are in place
to make sure that your personal data is held securely and that your rights as a
data subject are upheld. In most cases the safeguard which we rely on is the
‘Standard Contractual Clauses’ permitted by the GDPR, but where our Suppliers
are members of programs such as the USA’s ‘Privacy Shield’ or have other
appropriate mechanisms in place we may rely on those mechanisms instead. If you
would like more information about the mechanisms via which your personal data
is transferred, please contact marketing@thecaterer.com
If we ever give you (or where you have chosen) a password
which enables you to access certain parts of this Website, you are responsible
for keeping this password confidential. We ask you not to share a password with
anyone.
6. Your Rights
As a data subject you have a number of rights in relation to
your personal data. Below, we have described the various rights that you have,
as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data
that we hold which relates to you (you may have heard of this right being
described as a "subject access request").
Please note that this right entitles you to receive a copy
of the personal data that we hold about you in order to enable you to check
that it is correct and to ensure that we are processing that personal data
lawfully. It is not a right that allows you to request personal data about
other people, or a right to request specific documents from us that do not
relate to your personal data.
You can exercise this right at any time by writing to us
using the contact details set out here and telling us that you are making a
subject access request. You do not have to fill in a specific form to make this
kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data
that we hold about you which you believe is incorrect or inaccurate. You may
also ask us to erase personal data if you do not believe that we need to
continue 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
you provide to us and may take our own steps to check that the new data you
have supplied us with is right. Further, we are not always obliged to erase
personal data when asked to do so; if for any reason we believe that we have a
good legal reason to continue processing personal data that you ask us to erase
we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us
using the contact details set out here and telling us that you are making a
request to have your personal data rectified or erased and on what basis you
are making that request. If you want us to replace inaccurate 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 of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a
legitimate interest (see the sections of this Policy above which explain how
and why we use your information) you are entitled to ask us to stop processing
it in that way if you feel that our continuing to do so impacts on your
fundamental rights and freedoms or if you feel that those legitimate interests
are not valid.
You may also ask us to stop processing your personal data
(a) if you dispute the accuracy of that personal data and want us verify that
data's accuracy; (b) where it has been established that our use of the data is
unlawful but you do not want us to erase it; (c) where we no longer need to
process your personal data (and would otherwise dispose of it) but you wish for
us to continue storing it in order to enable you to establish, exercise or
defend legal claims.
Please note that if for any reason we believe that we have a
good legal reason to continue processing personal data that you ask us to stop
processing, we will tell you what that reason is, either at the time we first
respond to your request or after we have had the opportunity to consider and
investigate it.
You can exercise this right at any time by writing to us
using the contact details set out here and telling us that you are making a
request to have us stop processing the relevant aspect of your personal data
and describing which of the above conditions you believe is relevant to that
request. You do not have to fill in a specific form to make this kind of
request.
Your Right to Portability
Where you wish to transfer certain personal data that we
hold about you, which is processed by automated means, to a third party you may
write to us and ask us to provide it to you in a commonly used machine-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 the
majority of individuals with whom we interact. However, if you wish to transfer
your data from us to a third party we are happy to consider such requests.
Your Right to stop receiving communications
Where we send you e-mail marketing communications (or other
regulated electronic messages) you have the right to opt-out at any time. You
can do this by using the ‘unsubscribe’ link that appears in the footer of each
communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links,
or if you would prefer to contact us directly – you can unsubscribe by writing
to us at marketing@thecaterer.com and telling us which communications you would
like us to stop sending you.
Your Right to object to automated decision making and
profiling
You have the right to be informed about the existence of any
automated decision making and profiling of your personal data, and where
appropriate, be provided with meaningful information about the logic involved,
as well as the significance and the envisaged consequences of such processing
that affects you.
Exercising your rights
When you write to us making a request to exercise your
rights we are entitled to ask you to prove that you are who you say you are. We
may ask you to provide copies of relevant ID documents to help us to verify
your identity.
It will help us to process your request if you clearly state
which right you wish to exercise and, where relevant, why it is that you are
exercising it. The clearer and more specific you can be, the faster and more
efficiently we can deal with your request. If you do not provide us with
sufficient information then we may delay actioning your request until you have
provided us with additional information (and where this is the case we will
tell you).
7. Contact
Details
If you have any queries regarding this Policy, if you wish
to exercise any of your rights set out above or if you think that the Policy
has not been followed, please contact us at
The Head of Marketing
Travel Weekly Group LTD
52 Grosvenor Gardens
London
SW1W 0AE