1. Introduction
This privacy policy is to tell you what personal data we collect from you and why, and what we will do with this data. It also tells you about some of the key rights which you have under data protection laws. From 25 May 2018 onwards, 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 policy, we refer to this legislation as data protection laws.
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 “you” in this privacy policy, we mean every person who interacts with us in respect of a booking, booking request, enquiry or for any other reason and all persons for whom a booking or booking request is made.
For purposes of the policy, references to “we,” “our,” and “us” mean TripConsul Ltd. (operating as City Unscripted).
TripConsul Ltd. owns and operates the website at www.cityunscripted.com. Our site provides a wide range of information to our Site’s visitors. Like many web sites, if you make a booking, we also collect information from our visitors, including personally identifiable information, such as your full name, e-mail address, contact address, phone number, details of any group members you are travelling with that you tell us about, and other information that you may provide to us, and we also passively capture non-personally identifiable information (e.g., aggregate statistics about what parts of our Site are most popular).
We also deal with customers by email, over the phone, face to face, via social media, and via travel agents, which may contact us on your behalf. We will collect personally identifiable information from you such as your full name, email address, contact address, details of any group members you are travelling with that you tell us about, and other information that you may provide to us. We will also collect information about your travel arrangements such as booking numbers, flight and accommodation details, and any special requirements you may request.
Before using this site or communicating with us – and particularly before providing personally identifiable information to us – you should read this entire policy. Use of this site or communicating with us constitutes your agreement to the terms of this policy. If the terms of this policy are not acceptable to you, do not provide any personally identifiable information to us.
2. Scope of policy
Please be aware that this policy applies to information which we process about you. It does not apply to information which you provide via any other websites.
Within our site you may see links or references to other websites which are not covered by this policy and are likely to have different information practices. We therefore encourage you to read the privacy policy of each web site you visit. We provide these references and links for your convenience; they should not be construed as an endorsement of such sites, their content, or their information practices. You are solely responsible for any interactions you may have with such web sites.
If you make an enquiry or a booking with City Unscripted, we may share your information with third parties who will fulfil your booking requirements. We try to ensure that your information remains secure and is processed in accordance with relevant data protection requirements, but those third parties may have different information practices, which will be governed by their privacy policies.
If you have been referred to us from another site or by any other third party, your information that you provide to them will also be governed by their privacy policy, which we recommend you read.
3. What legal basis do we rely on to process your information?
We are required to explain the valid legal basis we rely on in order to process your personal information. As such, we may rely on the following legal basis to process your personal information:
a. Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specified purpose. You can withdraw your consent at any time.
b. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
c. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and fundamental rights and freedoms.
d. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
e. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
4. How we collect your information
a. How we collect your information via our website
I. Active information collection
Our website collects information from its visitors in two ways: actively and passively. Active information collection refers to instances in which we gather information from you when you fill it in and send it to us, such as by completing a questionnaire, feedback form, registration form, signing up for an electronic newsletter, sending an enquiry via our online webchat tool, signing up to receive a discount code, entering a competition, or sending us a message via an e-mail reply mechanism provided by this site. Active information collection can include both personally identifiable information (e.g. your full name or information that is unique to you) and non-personally identifiable information (e.g. if we were to ask for a list of the top three things you like about our site). Passive information collection refers to instances in which we collect information from you that you have not actively provided (please see the next section of this policy for a summary of our passive information collection practices).
i. Registration Information
If you are interested in receiving electronic updates, alerts, and other information from us regarding this site and our products and services, you must provide us with an e-mail address. In completing your registration, we may also ask for optional information, such as how you found us, to help us better serve you in the future.
ii. Feedback Information
We welcome your comments and feedback regarding this Site and our products, services and programs. This Site provides an e-mail address that permits you to send us your own e-mail address, comments, and any other information you choose to include. E-mail is not secure. As a result, you should carefully consider what information you wish to send to us via e-mail.
II. Passive information collection
We may use special technologies to passively collect information while you are visiting www.cityunscripted.com (that is, you do not actively provide this information). These technologies allow us to collect certain kinds of non-personally identifiable information, including your Internet domain name, the type of web browser you use, the operating system you use, the date and time of your visit www.cityunscripted.com, the specific pages you visit, and the address of the web site you visited prior to entering www.cityunscripted.com. We may link this passively collected non-personally identifiable information with personally identifiable information you have actively provided elsewhere on this site.
Below we have summarised the primary means of passive information collection at our Site.
i. Cookies
This site uses cookies, which are small text files that store non-personally identifiable information about you, either temporarily in connection with your Internet Protocol (IP) address (known as a temporary or session cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a permanent or persistent cookie). This Site uses session cookies so that you do not have to fill in the same information from page to page within www.cityunscripted.com. If you elect not to receive cookies, you may be able to view some, but not all, of the content on this Site.
ii. Internet Protocol (IP) Addresses
This site uses Internet protocol (IP) addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. IP addresses allow us to collect much of the same information we collect through cookies, including browser type, what pages you visit, and how long you stay on the site. In general, IP addresses allow us to identify problems with our servers, prepare aggregate demographic information and other information regarding this use of this site, and improve the functions of this site.
b. How we collect information through other channels including social media
We collect information from you when you call us, when you send emails or other messages to us, when you communicate with us via social media or via our online webchat tool, if you have asked a travel agent or an online travel agent to make an enquiry on your behalf.
5. Information about other people
If you provide information to us about any person other than yourself, such as people you are enquiring or making a booking on behalf of, people you are travelling with, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our service providers, to use it.
6. Sensitive personal data
Unless we make it clear otherwise, our policy is not to ask for any sensitive personal data from you (that is information about you, or anyone you are enquiring or booking on behalf of) about, for example, racial or ethnic origin, political opinions, religious beliefs, physical or mental health, or sexual life. We, our service providers, and third parties which are providing a quote or fulfilling your experience arrangements may, however, require certain sensitive personal data to provide services which you have requested, or to deal with your enquiries. For example, if you ask us to book private transportation due to a disability, or if one of your party has special health requirements. If you choose to provide this sensitive personal data to us as part of a particular service (where such information has been requested and the reasons for that discussed with you) or for any other reason, this will mean that you have given (and we accept) your explicit consent for us, our outsourced service providers, and third parties which are providing a quote or fulfilling your travel arrangements to use that information for the reasons described in this policy, or as explained at the time you provide that information to us.
7. What do we do with your information
The personally identifiable information we process about you, and anyone that you are enquiring or booking on behalf of, will only be used and disclosed in accordance with this policy or as specifically disclosed to you at the time you provide the information. The personally identifiable information that we process may be used in the following ways:
a. To respond to your requests, it will be accessed by our staff, service providers which act on our behalf, and carefully selected third parties in the course of providing quotes that you request for our products and services, and fulfilling your experience with us (e.g. for quotes and for operational purposes such as bespoke food experiences).
b. It will be used to send you our emails and offers. We will send you these if you have opted in to receive them, or if you have previously asked us for a quote or made a booking with us. You can unsubscribe any time – see #9 Unsubscribing for more information.
c. It may also be used to personalise your experience by using your previous requests for quotes, previous purchases, communications with City Unscripted staff and providers which have fulfilled part of your City Unscripted experiences, your browsing activity, and other publicly available information (such as demographic data provided by an external provider), to make recommendations and special offers to you about products and services we think may be of interest to you based on your profile. If you do not want us to profile and process your information in this way, please contact our Data Protection Officer dataprotection@cityunscripted.com and see #16 Contact Information for further information.
d. We and/or our authorised service providers(such as our marketing agencies, and data analytics providers) may also use your personally identifiable information to review your dealings with us including your purchasing and preferences; to review, develop and improve our products and services, to improve our customers’ experience, and for internal market research, strategic development, and statistical analysis.
We reserve the right to sell, lease, transfer, or otherwise share without restriction aggregated, anonymised and other non-personally identifiable information regarding site usage, sales patterns, traffic patterns, demographics, and other statistics about our site and our products and services.
We reserve the right to use or disclose personal information which we process about you and other people which you provide information about, as necessary to comply with applicable laws, regulations, legal processes, and law enforcement inquiries, as required by litigation, to take precautions against liability, and protect the security and integrity of the site and the safety of our customers and site users.
e. We will store personal data for the shortest amount of time possible, and only for so long as is necessary to enable us to complete the tasks for which the data was collected in the first place. Once no longer needed, we shall remove all personal data from our systems permanently.
8. Subscribers to our newsletters and emails
Should you subscribe to the City Unscripted newsletter and emails, either directly through the City Unscripted website, blog or by filling in an enquiry form from our website or online webchat tool, you will receive our newsletter from hello@cityunscripted.com, as well as promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. If you make an enquiry or a booking, we will also send you our newsletter and offers to the email address you provide to us in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 (PECR).
9. Unsubscribing
We do not seek to collect personally identifiable information from you that you do not want collected. Toward that end, we indicate at all active information collection points whether requested information is required or optional. We also attempt to tell you at the point of collection and in this policy what the consequences will be (e.g., inability to access important functions of the site, less tailoring of information to match your interests, etc.) if you do not provide the required or optional information. When you submit personally identifiable information to us, whether such information is required or optional, that information will be subject to this privacy policy. Should you wish to unsubscribe from marketing communications via email, you may opt out by clicking on the clearly marked ‘unsubscribe’ button at the bottom of any City Unscripted newsletter or marketing email. Should you wish to unsubscribe from marketing communications via mail, you can contact us by e-mail at info@cityunscripted.com (please write “unsubscribe” in the subject line and provide each email address you would like us to remove), by post at City Unscripted, International House, 64 Nile Street, London, N1 7SR, United Kingdom.
10. Information access
We take reasonable steps to ensure that personally identifiable information that you send us is accurate, current, and complete. Toward that end, we provide you with reasonable access to your personal information to correct errors or delete the information you have provided. If you wish to access, rectify or erase your personally identifiable information, please contact our Data Protection Officer by e-mail at dataprotection@cityunscripted.com or by post at City Unscripted, International House, 64 Nile Street, London, N1 7SR, United Kingdom. To respond to your request or inquiry, we may require follow-up or contact information to allow us to verify that you are the person authorised to view the information you are requesting. We may, at our discretion, refuse to allow you access to certain information if, in our view, to provide such access would jeopardise another person’s privacy; would violate any applicable federal, state, or foreign law, regulation, or directive; or would unreasonably burden this site.
11. Data security
We are committed to safeguarding and protecting personally identifiable information and implement and maintain appropriate organisational and technical measures to ensure a level of security appropriate to protect any information provided to us. For instance:
• All personally identifiable data is kept securely in electronic format, no hard copies are available.
• Any card payment details given to us via email or over the phone are destroyed securely once payment has been accepted, they will never be stored on file.
Although we take reasonable steps to protect the personally identifiable information that you provide, no system is 100% secure or error-free. Therefore, we do not, and cannot, guarantee the security or accuracy of the information we gather. Electronic safety measures are only effective if you protect the secrecy of both your username and password. If you ever suspect your username or password may have been compromised or subject to unauthorized use, contact us immediately by email at: info@cityunscripted.com.
12. This site is not intended for use by children
This site is not directed to, and does not seek to collect personally identifiable information from, children under the age of 18. Nevertheless, if we are informed that we have collected information from someone in this age category, we will take reasonable steps to delete that information.
13. Who we share information with
The information that you provide to us may be disclosed with the suppliers of various elements that are required to fulfil your booking, such as our hosts and any other suppliers. This information is required to tailor your experience. We may need to disclose some information to third parties in relation to customer services, credit card processing or other services. From time to time, we may run contests, prize draws and competitions with carefully selected and relevant partners. These will usually be governed by an additional set of terms and conditions, which shall in that case be supplemental to this policy and not a replacement of it, unless otherwise stated. When you enter or participate in these we will collect the personal information you provide. If you win one of our competitions we may collect further information from you to enable us to administer the competition and fulfil the prize. We may disclose your personal information to:
• Entities who assist us in administering the competition and fulfilling the prize, and other prize
suppliers and deliverers;
• Our participating partners who will use and disclose it for similar purposes as us and subject to their
privacy policies;
• Other parties where required by law.
14. Where will we process your personal data?
Your personal data may be 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 process personal data outside the UK and the EEA. Data protection laws may not be as strong outside the UK or EEA as they are in the UK or EEA. Personal data will not be transferred to a country outside the UK or EEA unless (1) the country to which it is transferred is one which the British Government and/or 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 7 are satisfied they have or (3) we are obliged to provide the personal data to a government / public authority in order to provide your experience. All information you provide to us (except for credit or debit card details) is stored on our secure servers. We do not collect or process your credit or debit card details. These are however collected and processed by our payment processing service provider Stripe Payments Europe, Ltd (“Stripe”). The collection and processing by these providers of your credit or debit card details and other personal data are governed by their respective terms and conditions. See https://stripe.com/gb/privacy for more information. Stripe may from time to time provide us with information regarding the credits and debits made to your card in order to enable us to reconcile our accounts. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The transmission of information via the internet is not completely secure and we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
15. Changes to this policy
We reserve the right to change this Policy at any time and in our sole discretion, for example to take account of new data protection legislation, and to reflect our current business practices. If we do change the Policy, the new Policy will be posted here, along with its revision date. We encourage you to check this Policy periodically and – at a minimum – before each instance in which you provide personally identifiable information to us.
16. Contact Information
City Unscripted are at International House, 64 Nile Street, London, N1 7SR, United Kingdom. Please contact us by email at info@cityunscripted.com or by telephone on +44 (0)20 3776 1000, Monday – Friday 0900 – 1800 GMT. Our Data Protection Officer is Nick Whitfield.
17. Use of and with Google
We use Remarketing with Google Analytics to advertise online. Third-party vendors, including Google, may show you ads on sites across the Internet. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to inform, optimise and serve ads based on your past visits to this website. We and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies together to report how your ad impressions, other uses of ad services and interactions with these ad impressions and ad services are related to visits to our site. We will use data from Google’s Interest-based advertising or 3rd-party audience data (such as age, gender and interests) with Google Analytics to optimise how we show you ads across the internet. If you would like to opt out of receiving Google analytics cookies, visit the Google Analytics Optout Browser Add-on here to see the currently available opt outs for the web. Using the Google Ads Settings, you can opt out of Google Analytics for Display Advertising and customise Google Display Network ads.
18. Cookie notice
Our website uses cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. The cookies we use are "analytical" cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. This helps us to improve the way our website works, for example by ensuring that users are finding what they are looking for easily. Read more about the individual cookies we use and how to recognise them (see below).
19. Cookie policy
Information about our use of cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.
We use the following cookies:
• Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.