Upton Coaches Privacy Statement
Who are ‘we’?
In this policy, whenever you see the words ‘we’, ‘us’, or ‘our’, we are referring to Upton Coaches which is the trading name of Upton Coaches Limited.
Upton Coaches Limited (Registered Company number 06763809) carries out a range of commercial trading activities including private coach hire, service transportation, trips, and tours.
Our promise to you
We respect your right to privacy and will never sell your personal data. We will only share it with organisations we work with when it is necessary (for example when we are processing a booking for you or if you come to work for us). No privacy and security system can be guaranteed to be perfectly secure at all times, but we have put in place procedures and systems designed to keep your personal data secure.
- Who does this policy apply to?
This policy applies to you if we obtain your personal data. This policy covers:
Individuals who make a booking or enquire about our travel services through us;
Individuals in respect of whom an enquiry or booking is made on their behalf (such as friends, family, children, special interest group members, sports or tour group members, employees and officers of businesses and organisations);
Individuals or employees who are acting as representatives of our customers that are organisations or businesses and, where necessary, individuals who are connected to that business in processing the booking, (for example key account managers or accounts or administrative personnel);
Individuals or employees who provide business function outsourcing services and, where necessary, individuals who are connected to those businesses;
Our employees (if you work, or have worked, with us or for us) including prospective employees and those who make contact with us in order to offer us their services;
Those who visit us at our premises or who travel on our vehicles; and events
Other road users or pedestrians who are captured by our onboard CCTV systems
- What types of personal data do we collect and process
This section covers the types of personal data about you that we collect and process in connection with specific activities such as when you make an enquiry or book with us, contact us (by phone, email or fax), visit our website, visit our premises, order a brochure, buy a voucher, or when you submit a response to an online questionnaire, or take part in research or other social media functions on our website, or by entering a competition, promotion or survey, or if you use any of our services, or when you travel with us or when you work with us or for us or are captured by our CCTV systems.
Your personal data (by which we mean any information relating to you, for example, your full name, postal address, email address, telephone numbers, date of birth, photograph, gender, dietary requirements, disability information, special request / room requirements, next of kin details, preferences, payment information and passport details may be collected and used by us.
Information may be recorded with your personal details concerning information arising during a trip and information relating to payments made.
If you are an individual associated with a business or other company with which we do business, then your personal data may include information such as the business or organisation’s details, contact and payment arrangements and financial information etc., your relationship with that business, such as owner, employee, agent etc., and your contact details within that business such as your work address and contact details etc. and the results of searches carried out to verify the business such as its address and credit status before we confirm a contract with you and the organisation that you work with or for.
Sensitive personal Data:
At times we collect special categories of personal information such as health information relevant to your proposed travel plans and this information requires higher levels of protection. We may use this information so that, for example, we can pass on relevant details to a hotel where you may be staying or next of kin contact details for a tour in case you become unwell. We may also be given information regarding children in order to process school bus passes or be given passenger manifest information about you by a tour operator. This information could include your name, age, gender, and passport details.
If you work for us we will require your national insurance number and we may also obtain, personal financial and medical information relevant to your employment with us.
We ask that you let us know if ever any of the personal data that you provide to us changes or if you become aware that data that we may hold for you is inaccurate for any reason.
Personal data provided by you
This includes information you give when interacting with us, including when you place an order or communicating with us, for example:
Personal details (name, date of birth, email and/or postal address, telephone number, and so on) when you join us as a member of staff or make a booking or buy a voucher;
Payment information (such as bank account, credit card or debit card details) if you make a booking or we need to pay you;
Your opinions, attitudes and experiences of working with us or travelling on our vehicles; and
The personal data that you provide to us may include identification information, and if you visit us or travel on our vehicles or are in the immediate surroundings of one of our coaches you may be recorded on our CCTV systems.
Personal data automatically collected by us:
There is certain information that our systems may record and store automatically such as CCTV images and sound when you visit our premises or travel on our vehicles or if you are filmed by our vehicle dash-cams or peripheral cameras used on our vehicles.
Some information will be collected and used anonymously, and aggregated for analysis, such as when you visit our website (e.g. IP address, web browser, operating system, time-zone, and any web pages that you came from, page response times etc.) or when you make contact with us by phone such as the number of the telephone that you are calling from and the time and length of your call.
Information from third parties
We do not buy anonymous external data from third parties (for example census data, or data held by credit reference agencies).
- How we use your personal data and why we are allowed to do so
Your personal data may be collected and used to help us work with you or deliver our service or complete your order or request, or if you work with us or for us. To help make clear what we mean, we have set out below examples of situations where we may obtain and/or make use of your personal data:
Facilitate search, booking, review, accounts and other functions of our website
Provide information and respond to your enquiries
Make payments and facilitate refunds
Communicate with customers, suppliers and employees
Keeping records and archives including bookings, contracts and complaints
Improve and manage our business e.g. such as carry out surveys, improve sales and provide staff training
Direct marketing of the travel services you have selected
Advertising: normally this is anonymous statistical data and does not identify an individual
Contact you in relation to services when you have specifically consented to us doing so
Record images and sound using CCTV or phone services in relation for security, legal and training purposes
When you make contact with us and/or when you travel on one of our vehicles we may have a legitimate interest in holding your details, and sometimes it may be legally necessary to obtain, use or store your personal data (for example If we are asked by the police, or any other regulatory or government authority investigating suspected illegal activities, we may be required to provide your personal data).
Sometimes your data may be used and communicated to third parties, for example if you work for us and our accountants require access to our financial records, or because we are the subject of an audit, or we require assistance to host and operate our data systems (including our computer systems, website and email facilities). Wherever we can we will limit our use of your data and the access that any third party has to it.
If you are happy for us to get in touch with you to provide you with details such as the services we offer and new products or special offers which may be of interest to you, then, with your consent we may get in touch with you from time to time.
If you have contacted us for an estimate, made a booking, been on trip or a tour, hired a coach or interacted with our website, we may request your feedback by email, phone or mail so that we can improve and customise the service and products we offer.
If you agree to receive marketing information from us you can change your mind at any time thereafter. However, if you tell us you do not want to receive marketing communications, then you may not hear about events or trips that may be of interest to you. The choice is yours and we will respect your preferences.
We may sometimes use third parties to capture some of your data on our behalf, but only where we believe that the third party will treat your data securely.
We will not send marketing emails, letters or make calls to people under the age of 17.
Cookies and Tracking
- How we protect and store your information
To protect your information, Upton Coaches has internal procedures that cover the storage, access and disclosure of your information. In addition, although the internet is not a secure medium, we have various security procedures in place to help ensure that your personal information is kept secure and confidential. We will only hold or use your personal data as permitted by law with reference to the obligations that may apply if we act as a data controller or data processor.
We will only store your information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, reporting or accounting processes.
- Sharing your information
Where necessary to fulfil our obligations to you or for business functions or for marketing purposes or for evidential purposes; Upton Coaches may pass your details to third parties such as:
Our travel partners such as hotels and restaurants, suppliers or sub-contractors;
Mailing & Distribution services to help fulfil our direct mailing requirements (who have limited access to your information such as the name and address that we use to send out brochures and product updates);
Selected card payment facilitators who help us process customer payments and protect us against fraud;
Credit reference agencies and other companies for e.g. prospective business or organisations or clients with a limited credit history in credit decisions, fraud prevention and to pursue debtors;
Google analytics to automatically and anonymously collect aggregated data for analysis so that we may improve your experience and our service to you. For more information go to https://www.google.com/analytics/terms/gb.html;
Business Function Outsourcing to operate or supply database systems, business functions or actions (such as email and email archiving systems, processing payments and feedback platforms);
Prospective buyers of our business or assets;
For booking platform purposes to process and store private hire and leisure bookings; and
Evidential purposes where access to and storage of CCTV images are restricted and carefully controlled to protect the rights of the individual. The reasons for the disclosure of the images will be compatible with the purpose for which they were collected or as required by law.
If there is anything that you would like to know about the information that we hold about you please let us know and we will try to help. If you ask us to provide you with details of the personal data that we hold for you then we will do so in a structured and commonly used format and we will need to verify your identity for security. When we hold your personal information, you have the right to:
Access the information we hold about you and know why we hold it in the first place: you can contact us to request the information we hold about you and why we have that information, who has access to that information and where it is stored. Once we have received your request and verified who you are we will use our best endeavours to respond within 30 days.
To correct and update the information we hold about you: If you believe that the personal data that we hold for you is inaccurate then please let us know. If we have got something wrong we will try to correct it quickly for you.
To be forgotten: If we have held your data because we have worked with you or for you, we will only hold on to your data after the work is completed for as long as is necessary. If you are concerned that we may be holding your personal data when there is no longer any need or proper reason for us to do so and you wish us to delete your data, please let us know. Equally, if you feel that we should no longer be using your data or that we are illegally using your data, you can request that we erase the data we hold. If we are holding your personal data because you have consented to us doing so and, if you withdraw your consent, you are entitled to ask that we delete your data and we promise to do so (provided we do not need to retain the data for some other reason, in which case we will explain our reasons for retaining your data so that you know what we are doing and why). When we receive your request, we will confirm whether the data has been deleted or tell you the reason why it cannot be deleted.
To object to the processing of your data: upon receiving this request we will contact you to tell you if we are able to comply or if we have legitimate grounds to continue processing your data. If data is no longer processed, we may continue to hold your data to comply with your other rights or our other legal obligations; and
In relation to data portability: upon receiving this request we will comply where it is feasible to do so.
Who to contact about this policy or your personal data
The Information Commissioner
For more information about your rights in relation to your personal data you can contact the Information Commissioner via the Information Commissioner’s Office website at www.ico.org.uk.
We may need to change this policy
If we need to update this policy (for example because a change in the law requires us to do so) we will publish the new version on our website, so we recommend that you check our website periodically to see if we have needed to make any changes that might affect you.