Privacy Policy

Just Go Vacations, Llc: Privacy Notice

Introduction
When you interact with us we collect your personal data. Just Go Vacations, Llc (Just Go Vacations) is committed to protecting your privacy. Please read the following policy that explains how we use and protect your information. We are the data controller of the information you provide to us and one of our group companies may be the data processor.

1. The JG Travel Group of companies
Just Go Vacations is part of the JG Travel Group (JGTG) which is made up of a number of related businesses all of which provide travel products and services to members of the public. These include UK registered companies Just Go Holidays Ltd and Cruise Connections Ltd and the US registered companies Just Go Vacations, Llc and Albion Journeys, Llc.

JGTG abides by the European regulations about how your personal data is used and stored. The European regulations are often referred to as GDPR (General Data Protection Regulation).

2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:

• Consent: in specific situations, we can collect and process your data with your consent, for example, when you tick a box to receive email newsletters. When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
• Contractual obligations: in certain circumstances, we need your personal data to comply with our contractual obligations, for example, when we are booking a hotel, flight or event ticket on your behalf we may need to pass on your information.
• Legal compliance: if the law requires us to, we may need to collect and process your data, for example, we can pass on details of people involved in fraud or other criminal activity to law enforcement.
• Legitimate interest: in specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests. For example, we will use your purchase history to send you or make available personalized offers. We also combine the booking history of many customers to identify trends and ensure we can keep up with demand, or develop new products/services. We will also use your address details to send you direct marketing information by post, telling you about products and services that we think might interest you.

3. When do we collect personal information about you?

• When you request information about our products and services e.g. brochure request.
• When you make a booking both through our website and over the phone.
• When you sign up for the newsletter on our website.
• When you create an online account.
• When you engage with us on social media.
• When you contact us by or for any means.
• When you choose to complete any surveys we send you.

4. What personal information do we collect about you?

• In the natural course of requesting product information for example a brochure we will ask for your name, address and telephone number.
• In the natural course of making a reservation we will ask for your name, address, gender, date of birth, email address and phone numbers, both home and mobile if different.
• Any special requirements you may have such as dietary and any disabilities which we should know about in order to ensure you have a safe and enjoyable trip. We will collect and process payment card details for the purposes of the transaction at that time but this data is not retained for future transactions or reference.
• Passport details where advance passenger details are required.
• If you create an online account we will store an encrypted version of your login password.
• Calls to the JGTG offices are recorded for training purposes. These will contain any personal data you have provided to us during that call.
• If you engage with us via social media, your social media username.
• We log your preferences as to how your data can be used e.g. for direct marketing.
  IP addresses and cookies:
• We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.
• For the same reason, we may obtain information about your general internet usage by using a cookie which is stored on the hard drive of your computer. Cookies are used to assist the operation of our website and are designed to deliver a better and more personalized service. They enable us: to estimate our audience size and usage pattern, to store information about your preferences, to customize our website according to your individual interests, to speed up your searches and to recognize you when you return to our website.

5. How we use the information we collect about you and why we would do this?

• JGTG will only process (collect, store and use) the information you provide if there is a reason for doing so in a manner compatible with the EU’s GDPR.

We will endeavor to keep your information accurate and up to date, and not keep it for longer than is necessary. JGTG is required to retain information in accordance with the law, such as information needed for income tax and audit purposes. How long certain kinds of personal data should be kept may also be governed by specific business-sector requirements and agreed practices.

Personal data may be held in addition to these periods depending on individual business needs. The JGTG Document Retention Policy will define how long we securely retain each set of personal data.

Generally we collect information at the time of booking or making a request for information in order to provide you with a service, a service which you have requested and to fulfill our legal obligations as far as providing a holiday are concerned.

• The data privacy law allows this as part of our sole interest in striving to understand our customers and answering their needs and wants as far as service and product design are concerned
• We will contact you via telephone, SMS text, letter and/or email when appropriate to keep you informed about travel updates that might affect your upcoming trip e.g. coach pickup times.
• We ask for your consent to use your personal data and preferences to keep you informed by email, post and telephone about our products and services including special offers and promotions. We’ll do this on the basis of our legitimate business interest. You are free to change your preferences at any time and to opt in or out of any or all of these channels.

6. Do we share your information with anyone else?

• Yes, but only as necessary and when legally required to do so in the fulfillment of our obligation to provide you with a product or service you have requested or booked.
• All of our partners e.g. coach operators, airlines, hotels also have to conform to the GDPR standard and when they no longer need your data to fulfill this service, they will securely dispose of your personal data in line with JGTG procedures.
• Hotels may need to retain your reservation data in order to comply with their own income tax and audit purposes.
• If we wish to pass your sensitive personal data onto a third party we will only do so once we have obtained your consent, unless we are legally required to do otherwise.
• We do not sell, transfer or otherwise disclose this personally identifiable information outside this company, except where disclosure is required by law.

7. Under what circumstances will JGTG contact me?

Our aim is not to be intrusive, and we undertake not to ask irrelevant or unnecessary questions. Moreover, the information you provide will be subject to rigorous data security measures and procedures to minimize the risk of unauthorized access or disclosure.

8. How we will protect your personal data

• We will treat your data with the utmost care and take appropriate measures to protect it.
• Our business systems are protected by robust technologies and policies to ensure the personal information stored is suitably protected.
• We take steps to protect your information from unauthorized access and against unlawful processing, accidental loss, destruction and damage.
• We secure all transactional areas of our website using https technology.
• Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.
• We regularly monitor our systems for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
• Any personal data shared with hotels, coach operators and airlines is password protected.

9. How long will we keep your personal data?

We will only keep your personal data for as long as necessary for the purpose for which it was collected. At the end of that retention period, your data will be deleted or anonymised so that it can be used in a non-identifiable way for analysis and business planning.

10. An overview of your different rights

You have the right to request:

• Access to the personal data we hold about you, free of charge in most cases.
• The correction of your personal data when incorrect, out of date or incomplete.
• That we stop using your personal data for direct marketing (either through specific channels, or all channels).
• That we stop any consent-based processing of your personal data after you withdraw that consent.

11. Where we store your personal data

The data that we collect from you will be transferred to, and stored at, a destination outside the USA. It will also be processed by staff operating outside of the USA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfillment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

You can contact us to request to exercise these rights at any time as follows:

To ask about the information we hold about you or to ask for your information or preference to be amended you can either
• email dpo@justgoholidays.com,
• write to The Data Protection Officer, Just Go Vacations, Llc, 27 North Chestnut Street New Paltz, NY 12561

We will provide you with a request form to complete and, following proof of your identification, we will be able to answer your questions.

Last Updated 6^th November 2019