Introduction
Welcome to MagicBreaks privacy notice.
We respect your privacy and are 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.
This privacy notice is provided in a layered format so that you can easily click through to the
specific areas set out below.
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.
▲ Important information and who we are:
Purpose of this privacy notice
This privacy notice aims to give you information on how we collect and process 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,
or 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.
Controller
World Travellers UK Limited trading as MagicBreaks is the controller and responsible for your
personal data (collectively referred to as "World Travellers", “MagicBreaks”, "we", "us" or "our"
in this privacy notice).
We have appointed a data privacy supervisor who is responsible for overseeing questions in
relation to this privacy notice. If you have any questions relating to this privacy notice, including any requests to
exercise your legal rights, please contact our data privacy supervisor using the details set out
below.
Our full details are:Full name of legal entity: | World Travellers UK Limited |
Name or title of data privacy supervisor: | Anna Gilmour |
Email address: | privacy@magicbreaks.co.uk |
Postal address: | The Spice Building, 8 Devonshire Square, London EC2N 4PN |
Telephone number: | +44 (0) 330 880 5006 |
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.
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 25th May 2018 and historic versions can be obtained by
contacting us.
The data protection law in the UK will change on 25 May 2018. Although this privacy notice
sets out most of your rights under the new laws, we may not yet be able to respond to some
of your requests (for example, a request for the transfer of your personal data) as we are still
working towards getting our systems ready for some of these changes.
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.
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.
▲ The data we collect about you:
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 follows:
(A) | Identity Data |
This includes data relating specifically to your identity, such as your first name, maiden
name, last name, username or similar identifier, marital status, title, date of birth and
gender.
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(B) | Contact Data |
This includes data relating to how you may be contacted, such as your billing address,
delivery address, email address and telephone numbers.
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(C) | Financial Data |
This include data relating to your means and methods of payment, such as your bank
account and payment card details.
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(D) | Transaction Data |
This includes data relating to the transactions you have carried out with us, such as
details about payments to and from you and other details of products and services you
have purchased from us.
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(E) | Technical Data |
This includes more technical data that we may obtain when you make use of our
website, such as your internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you use to access this
website.
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(F) | Profile Data |
This includes the data that we receive when you create a profile on our website and
make use of that policy, purchases or orders made by you, your interests, preferences,
feedback and survey responses.
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(G) | Usage Data |
This includes information about how you use our website, products and services.
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(H) | Marketing and Communications Data |
This includes your preferences in relation to whether or not you want to receive
marketing from us and our third parties and also your communication preferences.
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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.
Special Categories of Personal Data
We collect the following special categories of personal data about you.
Details about your:
- dietary requirements which may disclose your religious or philosophical beliefs;
- health.
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 providing the travel
service you have booked, we will be required to treat any withdrawal of consent as a
cancellation of your booking and any applicable cancellation fees or charges in our Booking Terms and Conditions will become payable.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with
you 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 provide you with your chosen
travel services, if you do not provide us with the necessary details then we will not be able to
provide the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary date, we may either not
be able to process your booking or we may have to cancel your booking, in which case we will
treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions
and any applicable cancellation fees or charges will become payable. We will notify
you if we are unable to process a booking or are required to cancel a booking for this reason.
▲ How your personal data is collected?
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:
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(B) | Automated technologies or interactions |
As you interact with our website, we may automatically collect Technical Data about
your equipment, browsing actions and patterns.
We collect this personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you visit other websites
employing our cookies. Please see our COOKIE POLICY for further details].
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(C) | Third parties |
We may receive personal data about you from various third parties as set out below:
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(D) | Transaction Data |
This includes data relating to the transactions you have carried out with us, such as
details about payments to and from you and other details of products and services you
have purchased from us.
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(E) | Technical Data |
This includes more technical data that we may obtain when you make use of our
website, such as your internet protocol (IP) address, your login data, browser type and
version, time zone setting and location, browser plug-in types and versions, operating
system and platform and other technology on the devices you use to access this
website.
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(F) | Profile Data |
This includes the data that we receive when you create a profile on our website and
make use of that policy, purchases or orders made by you, your interests, preferences,
feedback and survey responses.
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(G) | Usage Data |
This includes information about how you use our website, products and services.
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(H) | Marketing and Communications Data |
This includes your preferences in relation to whether or not you want to receive
marketing from us and our third parties and also your communication preferences.
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▲ How we use your personal data:
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:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation
Generally we do not rely on consent as a legal basis for processing your personal data
although we may do so in relation to 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.
Purposes for which we will use your personal data
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. | (a) Identity; (b) Contact. |
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) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications. |
(a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us). |
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) Marketing and Communications. |
(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 aprize draw, or competition | (a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications. |
(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 our website (including troubleshooting, data ,analysis, testing, system maintenance, support, reporting and hosting of data). | (a) Identity; (b) Contact; (c) Technical. |
(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. | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
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 |
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 travel services , products or offers that may be of interest to you | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
We strive to provide you with choices regarding certain personal data uses, particularly around
marketing and advertising.
If at any time you want to change your preferences about how you receive marketing material
from us or if you want to stop receiving it altogether then you can contact our
data privacy
supervisor
at any time with your request and we will make the changes you require.
Promotional offers from us
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 or products from us, or shown in interest in our products and services
and, in each case, you have not opted out of receiving that marketing.
Third-party marketing
It is not our usual policy to share your personal data with any third party for marketing purposes
but should we want to do so we will ask you for your express opt-in consent.
Opting out
You can ask us to stop sending you marketing messages at any time by emailing our data
privacy supervisor at privacy@magicbreaks.co.uk or by opting out using the link on any
marketing message we send to you by email.
Where you opt out of receiving these marketing messages, 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.
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 COOKIE POLICY.
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 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.
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.
▲ International transfers:
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.
(A) | External Third Parties as set out in the Glossary. |
(B) | Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice. |
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.
▲ Disclosures of your personal data:
Some 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 made a booking of travel services which are located or otherwise due to be
fulfilled outside the EEA, we are required and are permitted to transfer your personal data to
the supplier of the services that you have purchased, outside the EEA in order to:
- Fulfil the contract we have with you; or
- Where we act as agent, to place you into a contract with the supplier and so that the supplier can fulfil the contract they have with you.
For all other transfers of data that are unrelated to the provision of travel services to you,
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:
- 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. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries .
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
▲ 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. 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.
▲ Data retention:
How long will you use my personal data for?
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.
For tax purposes, we have to keep basic information about our customers (including Contact,
Identity, Financial and Transaction Data) for 6 years after they cease being our customers.
Unless otherwise required by law, a competent authority or professional guidelines we will not
(without obtaining your consent) retain your personal data any longer than 3 years after you
have ceased to be our customer or to interact with our products and services.
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.
▲ Your legal rights:
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 our data privacy supervisor
No fee usually required
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.
What we may need from you
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.
Time limit to respond
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.
▲ Glossary:
LAWFUL BASIS
THIRD PARTIES
YOUR LEGAL RIGHTS
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Legitimate Interest
means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us -
Performance of Contract
means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. -
Comply with a legal or regulatory obligation
means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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External Third Parties
- Suppliers of travel services acting as processors or joint controllers based in Europe, North America, Antigua and other countries who provide the travel services that comprise any booking of travel services that you make with us.
- Service providers acting as processors based in the United Kingdom, Romania, North America and India who provide IT and system administration services.
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based the United Kingdom and Spain who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances.
- Other third parties, such as Feefo, Front Page and Constant Contact based in the United Kingdom and Canada and who provide market research, review and digital marketing services
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Request access
to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. -
Request correction
of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. -
Request erasure
of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. -
Object to processing
of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. -
Request restriction of processing
of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:- if you want us to establish the data's accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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Request the transfer
of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machinereadable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. -
Withdraw consent at any time
where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.