DATE OF POSTING: 22nd December 2016

SN-AP – PRIVACY AND COOKIE POLICY

This Privacy and Cookie Policy (together with the Terms and Conditions, and any other documents we refer to in this policy or those Terms) explains how we, Snap Travel Technology Limited (“we”, “our”, “us” as applicable), may collect, use and share your personal information and what cookies may be set when visiting sn-ap.com (“Website”).

We are committed to protecting and respecting your privacy.  Please read the following carefully.

By visiting and using the Website you are agreeing to and consenting to the use of your personal information in the way that is described in this Privacy and Cookie Policy. By continuing to use this Website, you are agreeing to our use of cookies in the manner described in this policy.

If you have any queries or concerns regarding this Privacy and Cookie Policy, please contact us at tripbuilders@sn-ap.com.

Any changes we may make to our Privacy and Cookie Policy in the future will be posted on this page and, where appropriate, notified to you by email.

For the purposes of the Data Protection Act 1998, the data controller is Snap Travel Technology Limited registered in England whose registered company address is 4th Floor Reading Bridge House, George Street, Reading, Berkshire, England, RG1 8LS.

Information we collect from you

We will collect and process the following data about you:

  • Information you give us. You may give us information about you by filling out forms on the Website, by correspondence with us by phone, e-mail or otherwise. This information includes information you provide when you register to use our Website or enter any promotion or make any booking or registrations which may include your name, address, e-mail address, phone number, personal description and photograph.

If you contact us, we may keep a record of that correspondence.

  • Information we collect about you and your mobile telephone or handheld device (“Device”). Each time you visit the Website we may automatically collect technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, details of your operating system and platform, details of the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system and the type of mobile browser you use.
  • Location information. We may also use GPS technology, WiFi, cell phone signals, iBeacons (which use Bluetooth) to determine your current location. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by amending the operating system settings on your Device.  We also collect location information that you share with us using the Website such as pick-up, drop-off or street addresses that you have searched using the Website.
  • Information we receive from other sources. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

We are aware that your information may be confidential and we will protect the confidentiality of your information in accordance with our normal procedures and legal requirements.

We also automatically collect information about how visitors use our Website (such as statistical data on click-through rates, sales on the Website and information about where traffic to our Website comes from) by using cookies and similar technology. To learn more about how we use cookies please see the “Cookies” section of this policy below.

PRIVACY

What we do with information we collect about you

Use of information

We use your information in the following ways:

  • to ensure that the Website’s content is presented as effectively as possible for you;
  • to improve the Website and the services accessible through Website (“Services”) for example by personalising the Services or making the booking process faster;
  • to contact you and to provide information that you request from us, including that coaches are available;
  • to display advertising or to send marketing directly to you in accordance with the law, including ensuring that content is presented as effectively as possible for you and creating reports to assist with future marketing;
  • for our internal purposes, such as quality control, site performance, system administration and to evaluate use of the Website and the Services, so that we can provide you with enhanced services;
  • to notify you about changes to our services; and
  • to enable you to participate in any interactive features of the Website when you choose to do so.

We may monitor your use of the Website and record your email address and/or IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers.  This is statistical information about our users’ browsing actions and patterns and does not identify any individual.

We collect non-personal aggregated statistics data about visitors to the Website and sales and traffic patterns. Just to be clear, this information does not identify users in any personal capacity and we do not use this information to build profiles on individual users: it just contains generalised information about the users of the Website.

We only keep your information for as long as is necessary.

Marketing

If you are an existing customer or you have made a booking enquiry or build up request, we may contact you by email / telephone / post with information about products and services which are similar to those we previously provided to you, unless you have indicated that you do not want to hear from us.

Otherwise, we may contact you by email / telephone / post only if you consent.

We may also pass your information to other organisations (only if you consent) who may contact you to provide marketing information about their products and services by email / telephone / post.

If you do not want us to use your information in this way, please tick the relevant boxes during the booking process when we collect your information.  You may ask us at any time not to use your information for marketing purposes by contacting us at customerservice@sn-ap.com.

Sharing your information

With whom do we share your information? We may share your information with other organisations:

  • if we sell or buy any business or assets (as we may share your data with the prospective seller or buyer);
  • if we or substantially all of our company assets are acquired by another party, in which case your information will be one of the transferred assets;
  • with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006;
  • with business partners, suppliers, sub-contractors for the performance of any contract we enter with them or you; and
  • if we have to share your information to comply with legal or regulatory requirements, or if we have to enforce or apply our Terms or any other agreements or to protect our rights, property or our customers, etc.  This may involve exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

We may share the non-personal aggregated statistics data about visitors to the Website with third parties.

We may also share your information with selected third parties for the purposes of credit card clearance/credit reference/order fulfilment/delivery/data analysis/customer support/storage services.

We may pass your email address to selected third parties (as described above under the heading of ‘Marketing’) provided that you have explicitly consented to this when we take your order.

We do not send any personal information that we collect about you on the Website to any social media sites that you link to your account or if you share the Website for example on Facebook, nor do we share that information with such sites.  We do not collect any personal information about you from those sites.

If you pay for a booking over this Website, we use Stripe Payments Europe Ltd (“Stripe”) to process your payment. Stripe operates a secure server to process your payment details. They encrypt your credit or debit card information and authorise payment directly. This means that your credit card or debit card details are never revealed to us. Please read their privacy policy at https://stripe.com/gb/privacy to see what security measures they have in place and how they treat your information.

Where do we store our information about you

Security

All your information is stored on our secure servers. Any payment transactions will be stored on Stripe’s hosting services.  Your passwords are encrypted.  If you have a username, password or other login details which enable you to access certain parts of the Website, you must not allow any other person to use them and must treat them as confidential.  If you believe or suspect that someone else knows your login details you must contact us at customerservice@sn-ap.com as soon as possible. Please also see our Terms and Conditions.

Unfortunately, the transmission of information via the Internet is not completely secure.  Although we will apply our normal procedures and comply with legal requirements to protect your information, we cannot guarantee the security of your information transmitted to the Website and any transmission is at your own risk.  Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

The Website may from time to time contain links to and from other websites.  If you follow a link to any of those sites, please note that those sites ought to have their own privacy policies and that we do not accept any responsibility or liability for those sites or for their privacy policies.  Please check those privacy policies before you submit your information to those sites.  

Where do we transfer your information?

We may transfer your information to, or store it in, countries located outside the European Economic Area (‘EEA’) which do not have as developed data protection laws.  It may also be processed by staff at our affiliates, suppliers, agents or appointed representatives’ offices overseas.

Please do not send us your information if you do not want it to be transferred to or stored outside the EEA. By providing your information to us you agree and consent to us transferring to, and storing your information at, a destination outside the EEA.

Your rights

You can access and rectify certain parts of your personal information by logging into your account.

Under the Data Protection Act you have the right to see the personal information that we hold about you, whether collected through your use of the Website or through any communications that you have had with us. You have the right to access your information and should direct any request for your information to us at customerservice@sn-ap.com.

Please note that currently a fee of ten pounds sterling (£10.00) may be payable to meet our costs in providing you with details of the information we hold about you.

You have the right to rectify your information by sending a written request to us at customerservice@sn-ap.com.

You have the right to ask us not to process your information (or pass your information to other companies or organisations) for marketing purposes.  You can tick the appropriate box on the forms when we collect your information or later at any time by contacting us at customerservice@sn-ap.com

If you have a complaint about how we have used your information, you have the right to complain to the Information Commissioner’s Office https://ico.org.uk/.

COOKIES

What are cookies?

A cookie is a small data file that is placed on your computer or other device to allow a website to recognise you as a user when you return to the website using the same computer and web browser, either for the duration of your visit (using a ‘session cookie’) or for repeat visits (a ‘persistent cookie’).  Other similar files work in the same way and we use the word ‘cookie’ in this policy to refer to all files that collect information in this way.

Cookies are an extremely common technology for remembering certain information about a visitor to a website.  The vast majority of websites currently make use of cookies and they are commonly used for a wide range of tasks.  We use cookies for the following purposes:

      • Strictly necessary cookies. These are cookies that are required for the operation of our Website. They include, for example, cookies that enable you to log into secure areas of our Website or make use of online payment services.
      • Analytical cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily.
      • Functionality cookies. These are used to recognise you when you return to our Website and to embed functionality from third party services. This enables us to personalise our content for you, greet you by name, remember your preferences (for example, your choice of language or region) and to integrate useful services provided by third party providers into our Website e.g. maps and social media features.
      • Advertising cookies. These cookies record your visit to our Website, the pages you have visited and the links you have followed. We will use this information to make the advertising displayed to you more relevant to your interests. We may also share this information with third parties for this purpose.

This policy gives you information on the specific cookies used on this Website.

How to control and delete cookies

If you continue to use this Website, cookies and other tracking technologies will be placed on your computer as described in this policy in order to enhance your user experience whilst on the Website.  By continuing to use the Website and/or by accepting our Terms and Conditions or Conditions of Sale, you are agreeing to the use of such cookies and tracking technology.

We will not use cookies to collect personally identifiable information about you.  However, if you wish to restrict or block the cookies which are set by this Website (or, indeed, on any other site) you can do this through your browser settings.  The ‘Help’ function within your browser should tell you how.    If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to the Your Online Choices site at http://www.youronlinechoices.com/uk/your-ad-choices.

Alternatively, you may wish to visit http://www.allaboutcookies.org/ which contains comprehensive information on how to do this on a wide variety of browsers.  You will also find details on how to delete cookies from your computer, as well as more general information about cookies.  Please note that, as these websites are not owned or operated by us, we are not responsible for any of the content on them.

Please be aware that restricting cookies may mean that you will not be able to take full advantage of all the features or services available on this Website.

Cookies used by us on our Website

The cookies we use are analytical cookies, strictly necessary cookies, functionality cookies and advertising cookies.

Third party cookies-

We also use and work with a number of third party suppliers and partners who set or read cookies on this Website.  We do not have any control over these cookies. Whilst we provide a summary of the third party cookies used below, you should also check the relevant third party’s privacy policy using the links in that table for more information about how these cookies are used.

The third party cookies used in connection with this Website include:

  • Analytics cookies.   We use cookies to help us collect information that allows us to analyse web traffic to our Website. The information collected via the cookies, which is anonymous, is sent to a third party that operates analytics tools which we use to analyse the information collected and improve the Website’s performance.
  • Embedded third party content.  Some of the content on our Website is provided by online services operated by third parties.  When you visit a page containing content from one of these services, a cookie may be set by the relevant third party.
  • Advertising cookies.  We also use and work with a number of third party suppliers and partners who set cookies on this Website in order to deliver [targeted and non-targeted] advertising to you.  Please see a summary of the third party advertising cookies used in the table below.  If you would like more information about the cookies used by these organisations or would like to access a tool which you can use to disable them, please visit the Your Online Choices site at http://www.youronlinechoices.com/uk/your-ad-choices or click on the AdChoices logo that you will see in the corner of advertisements that carry behavioural targeting cookies.

Email tracking

Some of the emails we send to you may contain a ‘web beacon pixel’ or tracked links which allows us to identify when you have opened the email and to verify which links contained in the email you have accessed.  We use this information to determine which parts of our emails are of most interest to you.

You can delete the pixel by deleting the email.  If you do not wish to download the pixel to your computer or other device, you can ensure this by selecting to receive emails from us in plain text rather than HTML.

Alternatively you can unsubscribe from our mailing list by contacting us at tripbuilders@sn-ap.com.

Except for essential cookies, all cookies will expire after 24 hours.

Changes

We may make changes to this Privacy and Cookie Policy at any time by sending you an email with the modified terms or by posting a copy of them on the Website.  Any changes will take effect 7 days after the date of our email or the date on which we post the modified terms on the Website, whichever is the earlier. Your continued use of the Website after that period expires means that you agree to be bound by the modified policy.

How to contact us

If you wish to contact us with any queries or concerns, please see our Contact Us page or email us at customerservice@sn-ap.com or write to us via post at:

Snap Travel Technology Limited

Central Parade

Hoe Street

London

E17 4RT