The Slow Cyclist Ltd Privacy Policy

Updated February 2024

The purpose of this privacy policy

This privacy policy sets out our approach to the personal data we collect from or obtain about you. We will only process your personal data as set out in our privacy policy or otherwise notified to or agreed by you or as we are otherwise permitted to do in accordance with data protection laws. 

When we refer to personal data, we mean any information which relates to an identified or identifiable individual. Where we refer to process or processing, we mean anything which we may do with your personal data including collecting, storing, using, disclosing to third parties and erasing it.

Please do not provide your personal data to us if you are not happy for us to process this information in accordance with this privacy policy.

If you have any queries in relation to this privacy policy, please contact travel@theslowcyclist.com

Applicable laws

You and your personal data will be protected by the EU General Data Protection Regulation (which is otherwise known as GDPR) and a new UK Data Protection Act 2018. In this privacy notice, we refer to this legislation as data protection laws.

What is our role in relation to your personal data?

We are usually a data controller in respect of the personal data you provide us with or which otherwise comes into our possession. 

For exceptional types of bookings, we may however be a data processor, for example where we contract with a third party such as a travel agent, travel planner or other travel business which is based outside the UK for the arrangement of travel services and which itself enters into a contract with you for the provision of your holiday. In this situation, that travel business is likely to be the data controller. Where we are a data processor, we will only process your personal data in accordance with the instructions of the data controller. Certain provisions of this privacy policy will be applicable where we are the data processor.

What personal data will we collect from you?

In order to respond to an enquiry, process and fulfill your booking or send you a brochure or other promotional material, we need to collect personal data from you. 

You may provide or we may otherwise obtain personal data to us in various ways. This may be as a result of our direct communications or through a third party such as a travel agent. We have provided examples of the personal data we process below. This may be provided over the telephone, on-line through our website or in emails to us. Additionally, in order to allow you to experience a more personalised service when you visit our website, we may find out about your interests. We may do so by asking you to provide this information, by reading your comments and/or by looking at the areas of our website you have visited as referred to below.

Examples of when and how we may collect your personal information include the following:

• If you want to make a booking with us, we will ask for the personal information of all persons travelling. This is required so that we can make and provide your holiday arrangements. Required information may include full name, date of birth, next of kin, postal address, telephone number, insurance details, passport information, details of any medical condition, names of additional travellers and credit or debit card information if paying online.
• When you sign up to our email newsletters on our website we may ask for personal information about you consisting of information such as your name and email address. By entering your details in the fields requested, you enable us to provide you with the services you select. You will be able to unsubscribe from our emails at any time using the unsubscribe link or by contacting our office. We will not share this data with any third parties.
• When you submit an enquiry online, we may ask for information such as your name and contact details. By entering your details in the fields requested, you enable us to provide you with the services you select. We will not subscribe you to our email newsletters unless you specifically opt-in. We will not share this data with any third parties.
• If you submit a CV to us, we will ask for your name and email address in order to effectively respond to your application. We will not share this data with any third parties.
• If you submit feedback to us, we will ask for your name and email address in order to effectively respond to your feedback. We will not share this data with any third parties.

We will use your personal information for a number of uses including, but not exclusively, for the following:

• Administrative purposes, which means that we may contact you for reasons related to the service you have requested e.g. extra information required for visas or pre-trip paperwork required
• To analyse and improve the services offered e.g. post trip feedback
• To keep you updated of special offers and general information via our newsletter, from which you may unsubscribe at any time

Special categories of personal data

Information concerning any disability, medical condition, restricted mobility or any other health issue (and related requirements) as well as dietary restrictions which may disclose your religious beliefs or any health issue are special categories of personal data. We only ask for special information when we deem it necessary and relevant to the enjoyment and comfort of your holiday. When you make your booking you are deemed to give your consent to use of this information but you are entitled to decline such consent by notifying us accordingly.

Is there any other personal information you may collect about me?

As well as asking you to submit personal data, we may collect information about you automatically when you visit our website. The collection of information may involve the use of cookies and web beacons. A web beacon is a small graphic image placed on a web page that is designed to allow us to monitor visitors to our website. A cookie is a small text file that is placed on your computer’s hard drive or mobile device by your web browser when you first visit our website. The cookie allows us to identify your computer and find out details about your last visit. Most internet browsers accept cookies automatically, but usually you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. If you choose not to receive our cookies, we cannot guarantee that your experience with our website will be as quick or responsive as if you do receive cookies.

The information collected by cookies and web beacons is not personally identifiable, it includes general information about your computer settings, your connection to the internet e.g. operating system and platforms, IP address, your browsing patterns and timings of browsing on our website and your geographical location.

Does this privacy policy apply to any other websites?

This policy applies only to our websites and our booking website but not to other websites to which we may provide links. You are advised to read the privacy policy of other websites.

Who will we provide your personal data to?

Where you make a booking or booking enquiry, appropriate personal data (but not email addresses) will be passed to the relevant suppliers (such as hotels, local bike supply partners, destination management partners, etc) and any other third party (such as banks and/or credit card companies) who need this information so that your chosen arrangements can be booked and provided or your booking enquiry answered. We request that these suppliers delete your personal data 30 days after your trip ends. Once your booking has been made, your personal data may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law. Certain information may also be passed on to security or credit checking companies. 

We will not pass your information on to third parties for marketing or sales purposes. 

Other information we may obtain

Our site also offers newsletter subscription services and cookies may be used to remember if you are already registered.

We use “cookies” to store and collect information regarding your usage of the website. Cookies are small files placed on your computer’s hard drive, or in your browser memory, when you visit our website. Your computer will only share the information in the cookie with the website that provided it, and no other website can request it. There are two types of cookies, session and persistent. Session cookies last only as long as your web browser is open. Once you close your browser, the cookie disappears. Persistent cookies store information on your computer for longer periods of time – typically up to 3 months. Our website may use both types of cookies.

In some special cases we also use cookies provided by trusted third parties. The following section details which third party cookies you might encounter through this site. Third party cookies may be created and/or used on this site by the following services – Facebook, Instagram, Google AdWords, Google Analytics

Our website uses Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the site and ways that we can improve your experience. These cookies may track things such as how long you spend on the site and the pages that you visit so we can continue to produce engaging content. For more information on Google Analytics cookies, see the official Google Analytics page.

We also use social media buttons and/or plugins on this site that allow you to connect with your social network in various ways. For these to work, social media sites including Facebook and Instagram will set cookies through our site which may be used to enhance your profile on their site or contribute to the data they hold for various purposes outlined in their respective privacy policies.

Our website and certain literature contains hyperlinks to websites owned and operated by third parties. These third party websites have their own privacy policies, including cookies, and we suggest that you review them. They will govern the use of personal information you submit or are collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third-party websites and your use of such websites is at your own risk.

Where will we process your personal data?

Your personal data may be stored, used and otherwise processed within the UK and/or any other country(ies) of the European Economic Area (EEA). EEA countries are all member states of the European Union together with Norway, Iceland and Liechtenstein. We may also store, use or otherwise process personal data outside the EEA. Data protection laws may not be as strong outside the EEA as they are in the EEA. Personal data will not be transferred to a country outside the EEA unless (1) the country to which it is transferred is one which the European Commission considers to provide an adequate level of data protection or (2) the personal data is transferred to a company which is required by our contract with them only to deal with the data in accordance with our instructions and to maintain appropriate security to protect the personal data which we are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your holiday.

How do we protect your personal data?

We take appropriate technical and organisational measures to protect against unauthorised or unlawful processing of personal data and against accidental loss or destruction of, or damage to, personal data, which is appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures.

Can we use your personal data to send you information in the future?

We will only retain and use your personal data for marketing purposes where you have specifically consented to our doing so or we are permitted to do so in accordance with data protection laws (including as set out below).

We may send you e-mail marketing where we comply with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR). PECR permits us to e-mail you information about the travel services we offer where you have previously provided us with your e-mail address in the course of entering into a contract with us for holiday / travel arrangements or negotiations for such arrangements and we wish to e-mail you marketing material about our similar services or products. You will be given the opportunity to opt out of receiving such e-mail marketing communications when you first provide us with your e-mail address and whenever we send you any e-mail marketing.

Where you have previously requested or agreed to receive information about our travel services from us by post, we may continue to send you such information in the same way until you ask us not to (which you can do by telephone, e-mail or post). 

How can you find out what information we are holding about you?

You may ask us (by letter or e-mail) what personal data of yours is being held or processed, for what purpose and to whom it may be or has been disclosed. No fee will be charged for responding to this request unless it is obviously unfounded or excessive or we have previously provided the same information. We will respond to your request without undue delay and in any event within one month.

What should you do if the personal data we are holding is inaccurate or incomplete?

If you believe this is the case, please tell us by e-mail and we will rectify the problem as soon as reasonably possible.

How long can we retain and process your personal data?

We will not process your personal data in a form which enables you to be personally identified for any longer than is necessary in order to fulfil the purpose for which it was originally collected or for any other legitimate business purpose.

If you have consented to receiving marketing communications from us, we may continue to use your personal data for this purpose until you withdraw your consent.

Where you have provided your personal data to enable us to provide the holiday arrangements or other services you have contracted, we are entitled to retain this information for a period of ten years after the end of those arrangements. 

Deletion of your personal data

You can ask us to erase or remove your personal data in certain circumstances, for example where you have withdrawn your consent to further marketing where the data in question has only been processed for this purpose. However, this is not always the case. Please see the previous paragraph for further information on the period of time we may retain personal data.

Changing this privacy policy 

Occasionally we may need to make changes to this privacy policy. These may be required as a result of changes in data protection laws or in the guidance issued by regulators such as the Information Commissioner’s Office (which is usually referred to as the ICO) or where we make changes to our procedures. The latest version of this privacy policy will be on our website.

Complaints 

If you have a complaint about the way in which your personal data has been dealt with, please let us know by e-mail to travel@theslowcyclist.com. We will investigate and respond to you as soon as we reasonably can. If you remain dissatisfied, you may complain to the Information Commissioner’s Office.