By using the services of Maldivestop.uk (MALDIVES TOP RESORTS LTD), you have placed your trust in us and we appreciate it. We make every effort to keep your personal data secure. We act in the interests of our clients and do not hide information about the processing of your personal data.
1. POLICY OVERVIEW
1.1. Scope of this policy
1.2. Policy Update
2. ABOUT US
2.1. Who are we?
We are MALDIVES TOP RESORTS LTD, a company registered in England and Wales under company number 14425630. Registered office: 3rd Floor, 120 Baker Street, London, England, W1U 6TU
2.2. Who is the data controller?
2.3. How to contact us
3. WHAT INFORMATION DO WE COLLECT ABOUT YOU?
3.1. What types of information do we collect about you?
The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we collect any of the following:
- Details about you.
- Your name, email address, address, phone number, date of birth, your hotel room preferences, loyalty program membership details, frequent flyer membership details, payment details, reasons for your travel, meals and other travel preferences or dietary requirements and, if necessary, information about your health in so far as it relates to your fitness to fly, your holiday itinerary or the provision of special assistance to you.
- Identity documents/information.
- If you are travelling on a route that requires advance passenger information, your passport or identity card details, including your passport number, the country where your passport was issued and the expiry date.
- Details about the services you arrange with us.
- Details of your travel including details of your travel itinerary, where you are flying to, booking information, any details of onward travel if applicable, details of events or excursions booked through us, your baggage requirements, any information about class upgrades, your visits to waiting rooms, seat preferences, food preferences or requirements, details of any special assistance you may require from us and any other information relevant to enable us to provide you with travel or other services that you organized with us.
- Financial information.
- If you book services on our website, your payment details, which may include billing addresses, credit/debit card details and bank account details.
- Transaction data.
- We will collect information related to your transactions on the Website, including date and time, amounts charged and other related transaction details.
- Your interaction with us.
- Information about your interactions or conversations with us and our employees, including when you make inquiries, comments, complaints or send us feedback when you get to communicate via social media.
- Job applications.
- If you apply for a job with us, your resume, work history, information about education, qualifications, skills, projects, references, proof of right to work in the relevant country, national insurance number, details of your passport or another identity document, the role you are applying for and any other similar information you provide to us.
- Your use of our systems and services.
- Detailed information about how you use our site and/or social media pages (see OUR SITE AND COOKIES section below for more information).
4. HOW WE COLLECT INFORMATION ABOUT YOU
How we collect information about you will depend on how you interact with us and what services you provide with us. Depending on the circumstances, we collect information in one of the following ways:
4.1. Information you provide to us:
- When you browse our site;
- When you use «Manage My Booking» option on our site;
- When you book or search for a hotel through our site;
- When you complete part of the booking information on our site but do not complete the booking;
- When you apply for a job with us by email, through the Site or through a recruitment agency;
- When you attend a job interview;
- When you contact us through our social networks, email or instant messenger;
- When you sign up to receive email updates, participate in any of our competitions, promotions (for example, through any social media channels, email or on our website), surveys or market research;
- When you follow, post or interact with our social media accounts;
- When you provide us with information about an accident, illness or incident that occurred in connection with your holiday.
4.2. Information we receive from third parties, including:
- The person/company making the booking on your behalf.
- We will receive personal information in the form of booking details if, for example, a family member or friend, travel agent or employer, who may be in or outside the EU, makes a booking on your behalf;
- Employers, recruitment agencies and judges.
- If you are a job applicant, we may contact your recruiter, current and former employers and/or referees, who may be in or outside the EU, to provide information about you and your application.
- Service providers.
- We may collect personal information from ground handling agencies, our website developer, IT support provider and payment service provider (which may be located in or outside the EU).
- Site security.
- We will collect information from our website security partners, located inside or outside the EU, about any misuse of the website, such as the introduction of viruses, trojans, worms, logic bombs, website attacks or any other material or activity that is malicious or harmful.
- Plugins of social networks.
- We currently use social media plugins from the following service providers, both inside and outside the EU: Facebook, Instagram and YouTube. By providing your social media account information, you allow the third-party provider to share certain information about you with us.
- We may also receive information about you from third parties if you have indicated to such third party that you want to hear from us.
5. UNDER WHAT CIRCUMSTANCES DO WE NEED TO COLLECT YOUR CONFIDENTIAL INFORMATION?
5.1. In certain circumstances, we will collect information that is considered confidential or falls under special categories of personal data. This most likely includes information about:
- Your health (for example, if you ask us to provide you with special assistance during your holiday or to determine your fitness to fly, or if you indicate a food preference that indicates a medical condition such as celiac disease);
- Your religion (for example, if you indicate a food preference that indicates a particular religion, such as kosher or halal food);
- Your race, ethnicity, religious or philosophical beliefs and sexual orientation for the purposes of our diversity and equal opportunities records;
- Your health, if necessary to arrange an interview if you are an applicant or to support your needs and access to our workplace;
- Your criminal record for the purpose of passing the checks necessary for you to work with us.
5.2 We need additional justification for collecting, storing and using this type of personal information. We process special categories of personal information in the following circumstances:
- In limited circumstances with your express written consent;
- If we need to fulfil our legal obligations or exercise employment rights;
- If it is necessary in the public interest, for example, to monitor equal opportunities;
- If it is necessary in connection with legal claims or when it is necessary to protect your interests (or someone else’s interests) and you are unable to give your consent;
- Or where you have already made the information public.
6. HOW WE USE YOUR INFORMATION
6.1. For what purposes do we use your information?
We will use your information for a variety of purposes, some of which will depend on the services for which you engage us.
- To manage your booking with us.
- We will use your information to provide you with any services you request or purchase from us.
- To send you service messages and support services.
- We will use your information to send you any communications related to the services you have requested or purchased from us. This includes sending you an email notifying you of changes to your itinerary or providing you with a voucher, ticket or e-ticket. We will also provide customer service and support, and address your queries, complaints, comments or feedback that you have submitted.
- To manage our relationship with you.
- To send you marketing messages.
- We will use your information to keep you up to date with the latest news, events, offers, sales, promotions and competitions that we think may be of interest to you or will be relevant to you.
- To assist with online booking.
- We collect your information when you complete the required fields of our online booking forms but do not complete your booking or transaction in order to offer our assistance in the event that you experience difficulties with our website (if we have your consent to it).
- To personalize your customer experience.
- We use your information to provide you with more personalized service. For example, tailoring the messages we send to you with your favourite destinations, only showing you advertising we think you might like and/or improving your holiday experience (based on our legitimate interests in providing you with the right types of products and services ).
- To improve our customer service.
- We record calls to our call centre and/or monitor calls to improve our customer service, quality assurance, training, security and for general business purposes (based on our legitimate interest in improving our customer service).
- To process your job applications.
- We will use your information to process any job applications you submit to us, either directly or through an agent or recruiter (based on our legitimate interest in recruiting new employees or contractors).
- To optimize our site.
- If you use our site, we will use your information to ensure that the content of our website is presented in an effective way for you and your device, to give you access to our site in an efficient and convenient way, and to provide you with content that is relevant to you, using site analytics and research, and in certain circumstances combining this with other information we know about you (based on our legitimate interests to operate and present an effective and user-friendly website to our site users).
- To ensure the security and protection of our business interests.
- In certain circumstances, we use your information to ensure the security of our services, including for protection, investigation and prevention of fraud, unauthorized or illegal activity, system testing, maintenance and development (based on our legitimate interests to conduct a safe and lawful business or if we have a legal obligation to do so).
- To process and facilitate transactions with us.
- We will use your information to process transactions and payments for online bookings or purchases and to collect and recover money owed to us (based on the performance of our contract with you and based on our legitimate interest in debt collection).
- To assist with online booking.
- We collect your information when you complete the required fields of our online booking forms but do not complete your booking or transaction in order to offer our assistance in the event that you experience difficulties with our website.
- So that we can interact with you on social media platforms.
- These include Facebook, Instagram and YouTube, for example posting status updates, replying to comments and messages, posting, ‘retweeting’ and ‘liking’ posts (based on our legitimate interest in promoting our brand and communicating with interested parties).
- To detect fraud, terrorism and illegal activity.
- To protect, investigate and prevent fraudulent, unauthorized or illegal activity, including identity fraud, terrorism and other illegal conduct (based on our legitimate interests to conduct a safe and lawful business or if we have a legal obligation to do so).
- Conduct research.
- We use your information to conduct aggregated and anonymous research about your overall interaction with our services and systems, or if you choose to participate in customer surveys, consumer focus groups and research (based on our legitimate interests in improving our products, services and customer service ).
- To comply with our legal obligations, policies and procedures.
- In certain circumstances, we will need to use your information to comply with our policies, procedures and legal obligations (for example, to comply with any court orders or subpoenas), to enforce our legal rights and to protect the rights, property safety of staff, customers and others. This includes sharing your information with our lawyers, technical consultants, law enforcement and other regulatory authorities if necessary (based on our legitimate interests or to comply with a legal obligation).
6.2. On what basis will we process your information?
We will use your information for the purposes stated above:
- To fulfil your contract with us and provide you with our services;
- To comply with a legal obligation we have;
- For our legitimate interests (we explain what we mean below);
- Protect your vital interests;
- With your consent;
- To establish, exercise or defend legal claims;
- For reasons of significant public interest.
6.3. What do we mean by “legitimate interests”?
As stated above, in certain circumstances we may use your personal information to achieve our own or third parties legitimate interests, provided that your interests and fundamental rights do not override these interests. By “legitimate interests” we mean our interests in running and managing our business and in ensuring the best service and experience for you and our customers.
- Providing service to you;
- Determining the effectiveness of our site/tools/services and improving security;
- Confirming information you provide to us in your resume or application by referencing past employers and/or publicly available job or business profiles;
- Personalize, enhance, modify or otherwise enhance the services and/or communications we provide to you, such as sending you marketing and providing you with advertising that is relevant and may be of interest to you;
- Detecting, monitoring and preventing fraud or other illegal activities and conducting safe and legal business.
If we use your information for our legitimate interests, we take into account any potential impact that such use may have on you. Our legitimate interests do not automatically override yours, and we will not use your information if we believe that your interests should override ours, unless we have other reasons to do so (for example, where we have your consent or we are under a legal obligation use your information in this way).
As set out in the “YOUR RIGHTS” section below, from 25 May 2018 you will have the right to object to the use of your information for our legitimate interests. However, please be aware that your objection to this type of processing may affect our ability to perform the tasks we have outlined above.
7. WHO DO WE SHARE YOUR INFORMATION WITH
7.1 In connection with the purposes and legal grounds described above, we provide your personal information to the following third parties:
- Third-party suppliers, we work with to provide you with your booking and our other services.
- We may share your information with third-party vendors who provide us with services related to providing you with our services. This includes, for example hotels, tour operators, transport companies, tour providers and ground-handling agencies.
- Other third-party providers with whom we work in connection with our business.
- We share your information with third-party vendors who provide us with services related to our business and the provision of our services to you. This includes, for example, marketing agencies and/or companies that carry out our marketing campaigns, IT developers, service providers and hosting providers, third parties that run promotions or competitions that we may run, third-party software companies, suppliers and advertising networks, ground agents, site analytics providers, healthcare providers and credit card verification companies.
- Airports, immigration/border control and/or other government agencies. Most destinations require airlines, cruise lines and tour operators to provide “Prior Passenger Information” about you to the destination country’s border/immigration authorities. Advance Passenger Information contains the basic information contained in your passport that you must present on arrival. In addition, laws in certain destinations on your itinerary, such as the United States and countries over which you may fly, require airlines to provide certain additional advance information about you and your travel arrangements. We will provide this information if required.
- Third parties for marketing.
- We share your information with any third party to whom you consent to share your information for marketing purposes.
- Regulators and government bodies.
- We provide your information to HM Revenue and Customs, regulatory authorities, government bodies and other bodies acting as processors or joint controllers located in the United Kingdom who require reporting of processing activities in certain circumstances.
- Courts or advisers.
- We share your information with other third parties (including lawyers, accountants or other consultants, regulators, courts and government agencies) if necessary 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.
- Third parties who are business successors.
- If we share your information with third parties, we will require them to take appropriate security measures to protect your information from unauthorized access or processing, unless we are able to do so (for example, if we share information with border or law enforcement authorities). authorities).
8.1. We will keep you informed of our latest offers, partnerships, sales, promotions, and competitions if we think it may be of interest/relevance to you and if you have indicated that you are happy to receive marketing communications from us, i.e.:
- You have purchased services from us, such as holidays, and have not told us that you do not wish to receive such information from us.
- Or you signed up to receive marketing communications from us and did not later tell us that you did not want to receive communications from us.
8.2. Withdraw your consent to marketing
If you no longer wish to receive communications from us, you may opt-out or unsubscribe:
- Follow the “unsubscribe” link contained in any marketing communications you receive from us;
- Or email us at [email protected]
8.3. Third parties and marketing
We may rely on third parties to help us manage our marketing communications, but we will not share your information with any third parties for their marketing purposes unless you agree with us.
9. OUR SITE AND COOKIES
9.1. What we collect when you interact with our site
As you may already know, most sites and applications automatically collect some information about how you interact with them in log files. This may include your IP address, geographic location, device information (such as hardware model, mobile network information, unique device identifiers), browser type, referral source, duration of site or application visit, number of page views, search requests you make and similar information.
This information will be collected by us or a third-party site analytics service provider and will be collected using cookies.
As we described above, we use this information to save your preferences, such as the last hotel you searched for, so you can easily find it a second time, to give you access to more great features on our website, to help improve our features and services, perform diagnostics, analyze trends, track visitor traffic, gather broad demographic information, and personalize our services.
9.2. What do we mean by “cookies”?
Cookies are small amounts of information in the form of text files that we store on the device you use to access our site or our marketing communications. Cookies allow us to monitor your use of our services and improve them. For example, a temporary cookie is also used to track your “session”. Without this temporary cookie, you will not be able to purchase a vacation or other services on our website.
If you do not want cookies to be placed on your device, you can change your browser or device settings to reject cookies. For more information on how to reject cookies using your web browser settings, please refer to the Help section of your web browser or visit http://www.aboutcookies.org. Please note that if you set your Internet browser to reject cookies, you may not be able to access all of the site’s features.
For details of all the cookies we use and what we use them for, please visit https://www.maldivestop.uk/cookies
10. YOUR RIGHTS
10.1. Overview of your rights
You have certain rights regarding the personal information we hold about you, including:
- The right to ask us not to process your information for marketing purposes;
- The right to request access to the information we hold about you;
- The right to require us to correct any outdated or incorrect information we hold about you;
- In certain circumstances, the right to ask us to stop using information about you;
- The right to withdraw the consent you have given to us using your personal information (see clause 6.1 for when we rely on your consent);
- The right to object to us using your information on the basis of our legitimate interests (see point 6 above to find out when we rely on our legitimate interests) (or the interests of a third party) and there is something about your particular situation that makes you want to object against processing on this basis;
- The right to receive a copy of any information we hold about you (or request that we transfer that information to another service provider) in a structured, commonly used, machine-readable format in certain circumstances;
- The right to complain about us to the UK Information Commissioner’s Office (https://ico.org.uk/) or the relevant authority in your country of work or residence.
Please note that we reserve the right to retain certain information for our own records (for example, to ensure that you do not receive marketing communications that you have opted out of) and to defend against any claims. We may also need to send you communications related to the services we provide to you, even if you have requested not to receive marketing communications.
10.2. The right to ask us to limit or stop processing or delete information we hold about you in certain circumstances.
10.3. How to exercise your rights
Contact us. You can exercise your rights by contacting us using the information in the “ABOUT US” section above, or by checking the appropriate boxes on the forms we use to collect your information, or by telling us that you do not want to participate in marketing
Updating own data.
Alternatively, if you do not wish to be contacted by us, you may do so yourself depending on the nature of your enquiry. Example:
You can update the details we hold about you by logging into your booking under the Manage Bookings tab on our site and following the instructions to edit your details, or by contacting us to change the details of your booking;
If you wish to remove your information from our marketing mailing lists, which include receiving marketing emails, you may unsubscribe by scrolling to the bottom of the email and clicking on the “unsubscribe” link.
We will comply with your requests unless we have a legitimate reason not to.
10.4. What we need from you to process your requests
Please be aware that we may need you to provide additional information (for example, to verify your identity and/or to confirm what information you wish to access) in order to process your request.
11. WHERE IS YOUR INFORMATION?
11.1. Our service providers and suppliers
11.2. Please contact us using the contact information at the top of this Privacy Notice if you would like more information about the specific mechanism we use when transferring your personal data from the EEA.
11.3. Territories of destination
As we noted above, in certain circumstances we are required to provide information about you to immigration or other government authorities.
12. HOW WE CARE FOR YOUR INFORMATION
12.1. Our security measures
We are committed to constantly reviewing our security practices to ensure that we are keeping your information as secure as possible. We use a variety of technical and operational security measures to protect your information from unauthorized access or illegal use. For example, we:
- Ensure the physical and digital security of our equipment, devices and systems through mandatory password protection, encryption and access restrictions;
- Provide appropriate access controls so that access to your information is granted only to those of our employees who need to use it in the course of work;
- Conduct regular penetration testing of our systems and third-party audits of our software;
- We adhere to internal policies and conduct data protection and privacy training to ensure that our employees also understand their responsibilities to safeguard your information and undertake to take appropriate steps to fulfill these responsibilities.
12.2. How you can help keep your information safe
You can also participate in keeping your information safe. Here are some helpful starting points:
- Choose strong passwords and change them regularly;
- Keep your booking details and passwords confidential and do not share them with anyone or use your password for more than one account;
- Exit Manage My Booking after each session if you are using a shared computer;
- Notify us immediately if you know or suspect that your password or booking link has been compromised, or if someone may have accessed your account;
- Protect your devices by making sure you are running the latest version of your operating system and have the appropriate anti-virus software, if available;
- Be wary of any fraudulent emails that may appear to be from us but are not. All emails we send will come from [email protected]
12.3. Links to other sites and resources
13. HOW LONG DO WE KEEP YOUR INFORMATION
We retain your information for as long as is reasonably necessary for us to provide you with the services you have requested from us, to comply with any legal obligations that require us to retain the information, or for as long as we reasonably require to our legitimate interests, including, for example, to exercise our legal rights or defend against lawsuits. We follow a data retention policy and look for ways to reduce the amount of information we keep and the length of time we need to keep it. Example:
- We try to go paperless where possible and securely destroy any paper correspondence we receive on a regular basis, unless we are required to retain it for evidence or legal purposes;
- We maintain a blacklist of individuals who no longer wish to be contacted indefinitely. We need to retain this information to honor their wishes not to be contacted;
- We retain any unsuccessful CVs or job applications we receive for a period of up to 2 years in case we think you may be suitable for another opportunity that becomes available in the near future.
However, if you still wish to make a formal complaint or have concerns about how we use your information, you can contact the Information Commissioner’s Office (also known as the ‘ICO’). The ICO is the UK’s independent authority and watchdog for rights to information.
You can register your concerns on the ICO website: https://ico.org.uk/make-a-complaint/
LAST UPDATED: December 1, 2022