Toptour Europe Limited (the ‘Company’) Privacy Notice

We take your privacy very seriously. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, store, use and share your personal information.

We collect, use and are responsible for certain personal information about you. When we do so we are subject to applicable data protection law and we are responsible as ‘controller’ of that personal information for the purposes of those laws. Information about you is also used by our affiliated entities and group companies, including Tobu Top Tours Co. Ltd. in Japan (our ‘Group’).

Key terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	By post: Data Protection Manager, Toptour Europe Limited, Office No. 202, 1 Quality Court, off Chancery Lane, London WC2A 1HR By e-mail: dpo@tteuk.com By phone: 020 7430 2458
Personal information	Any information relating to an identified or identifiable individual

Personal information we collect about you

We may collect and use the following personal information about you:

• Your name and contact information, including email address and telephone number and company details
• Information contained in your passport
• Your gender information
• Your billing information, transaction and payment card information
• Your contact history and purchase history
• Information relating to health conditions
• Information about how you use our website, IT, communication and other systems

This personal information is required to provide services to you or to your employer. If you do not provide personal information we ask for, it may delay or prevent us from providing services to you or to your employer.

How your personal information is collected

We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website. However, we may also collect information:

• directly from a third party, e.g. your employer
• from cookies on our website—for more information on our use of cookies, please see below
• via our IT systems, e.g.:
  • computer networks and connections
  • communications systems
  • travel booking platforms
  • email and instant messaging systems
  • intranet and Internet facilities
  • telephones, voicemail, mobile phone records

How and why we use your personal information

Under data protection law, we can only use your personal information if we have a proper reason for doing so, e.g.:

• to comply with our legal and regulatory obligations;
• for the performance of our contract with you or to take steps at your request before entering into a contract;
• for our legitimate interests or those of a third party; or
• where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for	Our reasons
To provide services to you	For the performance of our contract with you or to take steps at your request before entering into a contract Legitimate interests i.e. so that we can provide services to your employer
To prevent and detect fraud against you or us	For our legitimate interests or those of a third party, i.e. to minimise fraud that could be damaging for us and for you
Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies	To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests or those of a third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information	For our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, or other efficiency measures	For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorised access and modifications to systems	For our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records	For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new services
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services and those of selected third parties to: —existing and former customers; —third parties who have previously expressed an interest in our services; —third parties with whom we have had no previous dealings.	For our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts	For our legitimate interests or a those of a third party, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards To comply with our legal and regulatory obligations

Promotional communications

We may use your personal information to send you updates (by email, text message, telephone or post) about our services, including exclusive offers, promotions or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

We will always treat your personal information with the utmost respect and never sell it to other organisations outside our Group for marketing purposes.

You have the right to opt out of receiving promotional communications at any time by contacting us using the details above. We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who we share your personal information with

We routinely share personal information with:

• companies within our Group;
• third parties we use to help deliver our services to you, e.g. hotels and airlines;
• other third parties we use to help us run our business, e.g. marketing agencies or website hosts;
• third parties approved by you, e.g. third party payment providers;
• our insurers and brokers; and
• our bank/s;

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers relating to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors, e.g. in relation to ISO accreditation and the audit of our accounts.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. Usually, information will be anonymised but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

Where your personal information is held

Information may be held at our offices and those of our Group, third party agencies, service providers, representatives and agents as described above (see above: ‘Who we share your personal information with’).

Some of these third parties may be based outside the UK. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the UK’.

How long your personal information will be kept

We will keep your personal information while we are providing services to you or to your employer. Thereafter, we will keep your personal information for as long as is necessary:

• to respond to any questions, complaints or claims made by you or on your behalf;
• to show that we treated you fairly;
• to keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

Transferring your personal information out of the UK and EEA

We share your personal data within our Group and where there is an international dimension to the services we provide. Many of our external third parties are based outside the UK or the EEA so their processing of your personal data will involve a transfer of data outside the UK or the EEA.

Whenever we transfer your personal data out of the UK or 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.
• Where we use certain service providers, we may use specific contracts approved for use in the UK or the EEA which give personal data the same protection it has in the UK or the EEA (as the case may be).

Further information

If you would like further information about data transferred outside the UK or EEA, please contact us.

Your rights

You have the following rights, which you can exercise free of charge:

Access	The right to be provided with a copy of your personal information (the right of access)
Rectification	The right to require us to correct any mistakes in your personal information
To be forgotten	The right to require us to delete your personal information—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal information—in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: —at any time to your personal information being processed for direct marketing (including profiling); —in certain other situations to our continued processing of your personal information, eg processing carried out for the purpose of our legitimate interests.
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, please contact us.

If you would like to exercise any of those rights, please:

• email, call or write to us;
• let us have enough information to identify you;
• let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
• let us know what right you want to exercise and the information to which your request relates.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you may raise about our use of your information.

Applicable data protection law also gives you right to lodge a complaint with a supervisory authority, in the country where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.

Changes to this privacy policy

This privacy notice was published on 21^st April 2021.

We may change this privacy notice from time to time—when we do we will inform you via email.