At Balkan Holidays, your right to privacy is of paramount importance to us. We are subject to certain data protection laws that govern how we collect, use, retain and disclose your personal data. We can assure you that every effort is made by us to ensure the security of your personal data and to keep you informed about why we collect your data, what we do with it, and how long we keep it for (among other things). We regularly review and, where necessary, update our privacy information.
About us and this policy
Categories of personal data
we collect from you
This will depend upon the nature of your transaction with us. Usually we will collect data where you make a booking with us, but we may collect data in certain other scenarios, as set out below. In certain cases, providing particular information will be mandatory if you would like to take advantage of our services (such as a travel booking – see the section headed ‘Uses and legal grounds’ below). We will tell you where that is the case. We will also make clear where providing information is optional.
In the case of a direct booking, we will require your name, date of birth, postal address, telephone number and email address where you are the lead name for the booking, together with the names and dates of birth of any other party members.
If you are the lead name for the booking, we will also require your payment (credit and /or debit) card details in order to administer relevant payment(s).
Special category (or 'sensitive') personal data
We may also require certain sensitive information from you, regarding your health, dietary and /or access requirements for example in relation to any particular request you make with regard to your booking. We may also require sensitive information about you which is relevant to any investigation we need to undertake in relation to any personal injury claim you make against our company in order to comply with our legal obligations.
In the case of an indirect booking (i.e., where you make a booking through a travel agent), we will only receive the names and dates of birth of the lead name and the other party members for that booking, to enable us to enable us to process the booking.
Types of data in the event of a dispute
In the event of a query and / or dispute, we may require more personal information from you (and the other members of your party) to assist us with our investigation. Please see the sections headed 'International transfers' and 'Data sharing' below for further information.
Depending on the nature and extent of your relationship with us, we will use your personal data for one or more of the purposes listed below:
We will always tell you in advance where we require your personal data for any new purpose. Should that be the case, we will provide you with all relevant information and if appropriate seek your consent to the new purpose and processing.
- Bookings: In order to process and administer your travel booking, i.e. performing your holiday contract with us (see further detail in this section below).
- Marketing: In order to email you information about existing or new products and services similar to those you have received from us previously and/or that you have expressly confirmed you would like to receive from us (see further detail in this section below).
- Call monitoring: In order to improve our services to you, we may monitor any telephone call you make to us for training and quality control purposes and/or in order to investigate any complaint you may make about any aspect of our travel services (see further detail in this section below).
- Job applicants: In order process, any job application you may make to us (see further detail in this section below).
- [Advertising and behaviour monitoring: please see the sections headed 'Cookies', 'Google Analytics' and 'Website Retargeting' below.]
Legal ground: [consent]
We also process your information via our website in the following cases, where you do not make a booking with us:
- Feedback form
- Contact us form
- Brochure request
- Subscribe form
Legal grounds for core uses
We make use of your data for the purposes set out above on the basis of one of the following legal grounds in relation to each purpose:
- Consent: With your clear, affirmative consent. Where we ask you to give your consent to any use we would like to make of your data, for example to enable us to provide you with holiday updates by email, as mentioned above, you will always be given the option to withdraw your consent at any time (which in the above example will involve unsubscribing from our marketing emails) and, in the event of your doing so, your withdrawal of consent will be recorded (and in the above example you will be removed from our mailing list).
- Should we need to process any sensitive information (called "special category" data under applicable law) of the type and for the limited purpose described above, we will only do so with your explicit consent and in order to process your request./li>
- Legal obligation: In order to comply with any legal obligation, we may be subject to (for example, in order to comply with any court orders).
- Legitimate interests: Where we consider it in our legitimate interests to do so having carefully assessed and balanced our interests against your own interests, rights and freedoms.
- Vital interests: In order to protect your vital interests (likely to be relevant in an emergency only).
- Public interest: For reasons of substantial public interest (likely to be relevant in an emergency only).
Further detail: Bookings
Legal ground: performance of contract
In order to process your booking with us, keep you informed of any relevant information relating to it, and ensure that your travel arrangements run smoothly and meet your requirements, we need to collect and process certain personal details from you. As set out above, this will usually include the names and addresses of you and any other party members, your credit/debit card details, and any particular health, dietary or access requirements.
In processing your travel booking, we are obliged to pass certain information on to the relevant suppliers of your travel arrangements, such as airlines, hotels, transport companies and credit/debit card companies. Some of these third parties may be outside the UK and/or outside the European Union and/or European Economic Area. While some countries have laws to protect personal data that are of a sufficiently similar standard to the GDPR, in other countries steps will need to be taken to ensure the appropriate level of protection is in place. These steps include, but are not limited to, appropriate contract clauses approved by the European Commission and appropriate security measures. We will ensure we comply with our own obligations to ensure your information is properly protected in this regard.
We will not however, pass any personal information (including any sensitive/'special category' personal data) onto any persons that are not responsible for any part of your travel arrangements.
If you believe that we may be storing incorrect details relating to you, please write to our webmaster at Balkan Holidays at Sofia House, 19 Conduit Street, London, W1S 2BH and we will correct them as soon as possible.
Further detail: Marketing
Legal ground: Your consent
From time to time, we may contact you with our newsletter, telling you about our latest holidays and/or special offers, which may be of interest to you. We will only contact you however where you have confirmed you would like to receive such updates, or where you have booked a previous holiday with us (or even requested a brochure and/or enquired about our holidays and indicated that you would like to hear from us in this way). If we do contact you, you will always be given the option to unsubscribe from our mailing list and we will then arrange for your details to be removed.
Further detail: Call Monitoring
Legal ground: Our legitimate Interests & legal obligations
In order to improve our services to you, we may monitor any telephone call you make to us for training and quality control purposes and/or in order to investigate any complaint you may make about any aspect of our travel services. We will only retain and process your information captured for these purposes for as long as it is necessary and to meet any legal or regulatory requirements that may be necessary in connection. If you have any queries about how we handle your information in this regard, please write to Balkan Holidays at Sofia House, 19 Conduit Street, London W1S 2BH.
Further detail: Job Applicants
Legal ground: Our legitimate interests
If you apply for a job with us, all of the information you provide will be treated in the strictest confidence and for the purpose of progressing your application. We will only retain and process your information for as long as it is necessary and to meet any legal or regulatory requirements that may be necessary in connection with your application. If you have any queries about how we handle your information in this regard, please write to us at Balkan Holidays, Sofia House, 19 Conduit Street, London, W1S 2BH.
Further detail: Cookies
Legal ground: Your consent & legitimate interests
Cookies may in some cases constitute personal data. You can find out more about cookies and how we use them on our Cookies page. Please also see the section below headed Website Retargeting.
Further detail: Google analytics
Legal ground: Your consent & legitimate interests
When you visit our website, we use a third-party service, Google Analytics, to gather standard internet log information and details of visitor behaviour patterns. We do this to discover things such as the number of visitors to the different parts of our website. This information is only processed in a way which does not identify anyone (i.e. it is anonymised so that it cannot be attributed to any particular individual). We do not make, and do not permit, Google to take any attempt to discover the identities of those visiting our website. If we want to accumulate personally identifiable information though our website, we will be transparent about it. We will make it apparent when we gather personal information and will explain what we plan to do with it.
Further detail: Website Retargeting
Legal ground: Your consent & legitimate interests
Our advertising partners may place a pixel tag or cookie on certain pages of our website, such as an email registration page or our booking confirmation page. This enables our partner companies to later display a relevant advertisement to you based on your website browsing behaviour. This type of online, targeted advertising — known as "retargeting" — is used to re-engage consumers who previously visited a website. Certain information may be collected and shared with these partners, including what page you viewed, when you viewed it and whether you clicked on the advert (see our above policy on "Cookies").
Further detail: Aggregated Data
Legal ground: Our legitimate interests
During your interaction with our website we collect data which relates to your use of our website, such as your internet protocol (IP) address, login data, traffic data, weblogs and other communication data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website. We also obtain and use certain aggregated data such as statistical or demographic data for any purpose (“Aggregated Data”). Aggregated Data may be derived from your personal data but does not directly or indirectly reveal your identity. For example, we may aggregate your Operation Data to calculate the percentage of users accessing a specific feature on our website. This data is collected to enable us to better understand the use of our website in order to improve the website user experience.
However, if we re-combine or re-connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice. This is done to deliver more relevant marketing messages to website users who have shown legitimate interest in our products and services.
We will only share your personal data (including any sensitive information/special category data) with the travel service providers who are relevant to your booking, in order to meet your request(s), and will always do so in a secure manner. We also take steps to ensure that the travel service partners we work with will not share your data with any other party not connected with your booking, and will only retain it for as long as it is necessary to process your booking and /or request. We also take steps to ensure that they keep your data safe and secure whilst it is being processed. We do not sell your personal data to any third parties.
In the event of any complaint or dispute, we may need to share this data with other relevant parties, such as your hotel or airline to help us with our investigation. In the case of a serious dispute involving legal proceedings, we will need to share your data with our insurance company and legal advisors in order to comply with legal obligations and to assist with the handling of the matter.
We fully respect your right to privacy and take our responsibility for the collection of your personal information very seriously. We make every effort to ensure that your personal information is kept secure and is only used for the purpose for which it is collected. We will also only retain your data for as long as it is necessary and in accordance with the basis upon which it was collected. In the case of a complaint or a claim, we may need to retain your data for up to 4 years in order to comply with any of our legal obligations. In the unlikely event that you have a complaint about the information which we collect about you, please write to us at Balkan Holidays, Sofia House, 19 Conduit Street, London, W1S 2BH.
We will implement all technical and organisational measures which are appropriate, practicable and/or reasonable to safeguard your information.
For more information on our website security, please visit Security Policy page.
You also have the right to make a complaint to the UK Information Commissioner's Office, which has the power to investigate our compliance with applicable law. The ICO can be contacted via their website at www.ico.org.uk
- Under the UK GDPR you have the following rights (although these rights may not apply to all circumstances):
- The right to have the personal data which we collect on you corrected if it is inaccurate, or completed where it is incomplete
- As set out above, the right to withdraw your consent or explicit consent (in the case of special category personal data) to our use of your data on that basis
- The right to object to the processing of your personal data in certain circumstances
- The right to restrict the processing of your personal data in certain circumstances
- The right to have to have your personal data erased in certain circumstances (i.e. the so-called “right to be forgotten”)
- The right to request access to your personal data and information about how we process it. Although this access request is free, please note that if your request is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee based on our administrative costs.
- The right to transfer your data (i.e. the right to “data portability”)
- Rights with regard to automatic decision making, including profiling