PRIVACY & COOKIES POLICY
This Website www.namarketing.com (“Website”) is owned and operated by NA Marketing Limited (“we”, “us” and “our”). We are registered in England and Wales under company number 4218990 and have our registered office at 2nd Floor, 12 Upper King Street, Norwich, Norfolk, England NR3 1HA.
Information Collection And Use
Types of Data Collected
While using our NA Marketing Limited, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:
• Details about you: Your first and last name, martial status, title, gender, e-mail address, telephone number, date of birth, your reasons for travel, meal and other travel preferences or dietary requirements.
• Payment details: Your bank details and payment card details when making a booking with us. Details about payments to and from you and other details of products and services you have purchased from us.
• Identification documents: If you are travelling on a route requiring advance passenger information, your passport or identity card details including your passport number, the country in which your passport was issued and the expiry date.
• Details about your booking with us: Details such as where you are flying from and to, your booking information (including anyone else on the booking), any onward travel details if relevant, details of experiences or excursions booked through us, baggage requirements, upgrade information, lounge visits, seat preferences, meal preferences or requirements, details of any special assistances required and any other relevant information so that we can provide you with the travel or other service you have arranged with us.
• Details from your interactions with us: Information about interactions or conversations with us and our staff, including when you make enquiries, comments, complaints or submit feedback to us. This could also include username and password and your interests, marketing preferences and survey responses.
• Your use of our systems and services: This includes how you use our site, app, retails stores, call centres and/or social media pages, IP addresses and information you may post on social media.
• Job applications: If you apply for a job with us, your CV, work history, educational details and the role you are applying for.
• Special types of data: In some circumstances we may need to collect information from you that is deemed sensitive. For example, we might collect:
• Data about your health. Knowing your dietary requirements and any medical conditions you have will ensure that the trip is suitable for you and any necessary adjustments are made.
• Information about your religion (for example if you specify a meal preference that indicates a particular religion, such as a kosher or halal meal).
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
• Session Cookies. We use Session Cookies to operate our Service.
• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
HOW DO WE COLLECT YOUR INFORMATION AND WHY?
Depending upon your interactions with us, we might collect information in the following ways:
You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone and email or otherwise, this includes personal data you provided when you:
- apply for a job with us by email or via the site;
- contact us via our call centres, press office, social media, post or email. Our interactions with you may be recorded and monitored for the purposes of improving customer service, quality assurance, training, security and general business purposes; or
- attend any of our events
Automated technologies or interactions
As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources
We may receive personal data about you from various third parties as set out below:
a) analytics providers such as Google based outside the EU;
b) search information providers such as Google based inside OR outside the EU.
WHAT DO WE USE YOUR INFORMATION FOR?
Under data protection laws we are allowed to use personal information only if we have a proper reason to do so such as:
• to fulfil a contract we have with you or;
• when it is our legal duty or;
• when it is in our legitimate interest (or those of a third party) and your interests and fundamental rights do not override those interested or
• when you consent to it
Generally, we do not rely upon consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via e-mail or text message. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
• To manage your booking with us. We will use your information to provide you with any travel or event services that you request or purchase. This entails providing you with any special assistance you require (where you give us your consent).
• To contact you with information about your bookings and support services: We will use your contact details to send you communications which relate to your booking or services you have requested. The types of information usually included would be: e-mails responding to enquiries, providing you with tickets, alerting you to changes in itineraries or responding to any complaints you have. We do these things in order to fulfil our contract with you and on the basis of our legitimate business interest of providing you with customer service.
• To provide assistance with online bookings. We may collect information when you enter it into forms on our websites but do not complete your booking. We do so in order to offer assistance in case you are experiencing difficulties using our website.
• To send you marketing communications. We will use your information to contact you in order to keep you up to date with the latest news, offers, events, sales, brochures, promotions and competitions that we consider may be of interest or relevant to you. We will usually only do this when we have your consent to do so or on the basis of our legitimate interest to provide you with customer service.
• To personalise your customer experience and improve our service. We use your information to provide you with a more personalised service. This might include personalising the communications we send to you with preferences, We may also record and/or monitor calls in order to improve our customer service.
• To ensure security and protect our business interests. In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development (on the basis of our legitimate interests to operate a safe and lawful business or where we have a legal obligation to do so);
• To process your job applications. We will use your information to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) (on the basis of our legitimate interest to recruit new employees or contractors);
• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
• To comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders or subpoenas (on the basis of our legitimate interests to comply with a legal obligation).
WHAT ABOUT OUR MARKETING PRACTICES?
When we will get in touch with you
One of the other reasons we sometimes collect your information is so that we can form a view on what we think you may want or need, or what may be of interest to you. With this information we decide which products, services and offers may be relevant for you and what marketing you may be interested in.
We keep you up to date with our latest offers, partnerships, sales, that we think might be of interest/relevance to you.
We will only contact you in this way if:
• You have signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.
• You have made a booking with us and have not told us that you do not want to hear from us.
What if I don’t want to receive marketing?
We never want to send our marketing to someone who isn’t interested in receiving this content. If you have decided that you no longer wish to hear from us, you can unsubscribe from marketing by contacting us
Third parties and marketing
We do not pass your information to other parties for marketing purposes unless you agree to us doing so. We will get your express opt-in consent before we share your personal data with any company outside of NA Marketing Ltd
The marketing material we send to you we may occasionally also include information about selected business partners who provide services closely related to our own products.
WHEN DO WE SHARE YOUR PERSONAL DATA?
In order to provide you with the services and on the lawful grounds described above, we may share your personal information with third parties such as:
• Third party suppliers we work with to provide your booking and our other services to you. We may share your information with parties such as airlines, hotels, tour operators, transport companies, excursion providers, airport authorities, insurance companies, car hire companies, ground handling agencies, and cruise companies.
• Airports, immigration / border control and/or other government authorities. Sometimes we have to provide ‘Advance Passenger Information’ about you to border or immigration authorities of the country of your travel destination. This would usually be the basic information contained in your passport but the laws of certain countries may require additional information. We will provide this information when we are required to do so.
• Credit references and fraud prevention agencies.
• Courts or advisors. We may have to share your information with other third parties (such as legal, accountants or other advisors, regulatory authorities, courts and government agencies) to enable us to enforce our legal rights, or to protect the rights, property or
safety of our employees or where such disclosure may be permitted or required by law; and We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
WHEN DO WE SEND YOUR DATA OUTSIDE THE EEA?
We will only send your data outside the European Economic Area (“EEA”) to:
• follow your instructions
• comply with a legal duty
• work with our suppliers and third parties who we use to help deliver our services
Some of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
If we do transfer information to parties outside of the EEA, we will make sure that it is given a similar degree of protection by ensuring that at least one of the following safeguards are implemented:
• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Learn more here.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
• Where we use providers based in the U.S, we may transfer data to them If they are part of the US-EU privacy shield, which sets out standards for data sent between the US and EU countries.
Please Contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
YOUR PERSONAL DATA RIGHTS
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. NA Marketing Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where NA Marketing Ltd relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
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.
HOW LONG DO WE KEEP YOUR DATA FOR?
We will only keep your personal data for as long as necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal accounting or reporting requirements.
We operate a data retention policy and look to find ways to reduce the amount of information we hold and the length of time we hold it for.
By law we have to keep basic information about booking and our customers for six years for legal clams and tax purposes.
HOW TO CONTACT US
We have appointed a Data Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Manager using the details set out below.
NA Marketing Ltd
12 Upper King street, Norwich
0207 372 0414
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
OTHER PRIVACY INFORMATION
Change of Purpose
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 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.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.