Privacy Statement

Newari Limited trading as Holiday Dragons respects your privacy and is 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 aims to give you information on how Newari Limited trading as Holiday Dragons collects and processes 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, when you take part in a competition and register to create an account online.

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.

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.

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:

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.

Contact Data

This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

Financial Data

This include data relating to your means and methods of payment, such as your bank account and payment card details.

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.

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.

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.

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, race or ethnicity. 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.

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 (or arrange for the provision of) 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 Terms and Conditions We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.

We use different methods to collect data from and about you including through:

  • Direct interactions
  • Make a booking of travel services
  • Subscribe to our newsletter or other publications
  • Request marketing to be sent to you
  • Enter a competition, promotion or survey
  • Give us some feedback

 

We may receive personal data about you from various technical third parties as set out below:

Analytics providers such as Google Contact, Financial and Transaction Data from providers of technical, payment and delivery based services.

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 we need to take steps to enter you into a contract with the supplier of your chosen travel services, where we are acting in an agency capacity.
  • 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 other than 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. Please see contact details above.

Purposes for which we will use your personal data:

  • Lawful basis for processing including basis of legitimate interest
  • To register you as a new customer
  • To process and deliver your booking 
  • Notifying you about changes to our terms or privacy policy
  • Asking you to leave a review or take a survey
  • Necessary to comply with a legal obligation
  • 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 a prize draw, competition or complete a survey
  • To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
  • To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
  • To make suggestions and recommendations to you about goods or services that may be of interest to you
  • For the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.

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 link to Cookie policy on the footer of our website.

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. Please see contact details above.

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.

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.

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.

If you make a booking with us we will keep your information for 6 years from your return date of travel (in the case of adults) or 6 years from the date of your 18th birthday (in the event of any children that travel on the booking) in order to enable us to defend any legal claims that you may pursue against us.

 

In addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

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