Welcome to The Lotus Group t/a DialAFlight and Supertravel's privacy notice.
The Lotus Group respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.
This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below.
Please also use refer to the Glossary that we have set out at the end of the Policy, if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.
This privacy notice aims to give you information on how Lotus collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you request a quote from us, when you purchase travel services, when you sign up to our newsletter, when you take part in a competition etc.
This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
The Lotus Group is made up of different legal entities, as follows:
(a) Lotus Travel Limited;
(b) Lotus International Limited; and
(c) Lotus Leisure Limited.
This privacy notice is issued on behalf of the Lotus Group so when we mention "Lotus", "we", "us" or "our" in this privacy notice, we are referring to the relevant company in the Lotus Group responsible for processing your data. We will let you know which entity your are dealing and contracting with when you purchase a product or service with us.
We have appointed a data privacy 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 privacy manager using the details set out below.
Our full details are:
|Full name of legal entity:||Lotus Group Limited, Lotus Travel Limited, Lotus International Limited and Lotus Leisure Limited.|
|Name or title of data privacy manager:||Karen Hart|
|Postal address:||The Lotus Group, Sandpiper House, 37-39 Queen Elizabeth Street, London, SE12BT|
|Telephone number:||0207 459 3762|
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 (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.
This version was last updated on 24/05/2018 and historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
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.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
This includes data relating specifically to your identity, such as your first name, maiden name, last name, marital status, title, date of birth, gender and, in certain circumstances, passport information.
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
This includes data relating to your means and methods of payment, such as your bank account and payment card details.
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login 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 this website.
This includes information about how you use our website, products and services.
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
We collect the following special categories of personal data about you.
Details about your:
Details about your:
We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.
You are not under any obligation to consent to us processing your sensitive personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking.
If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time. However, as this will prevent us or (where we are acting as an agent) the supplier of your chosen travel service from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellation charges referred to in our Booking Terms and Conditions will become payable.
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.
Where we are acting as an agent and we need to collect personal data to enter you into a contract with the supplier of your chosen travel arrangements, we may not be able to take steps to enter you into that contract if you fail to provide the data when requested.
In other words, where we require details from you in order to provide you with your chosen travel services, if you do not provide us with the necessary details then we will not be able to provide (or arrange for the provision of) the services you have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary date, we may either not be able to process your booking or we may have to cancel your booking, in which case we will treat this as a ‘cancellation by you’ in accordance with our Booking Terms and Conditions https://www.dialaflight.com/bookingconditions.aspx. We will notify you if we are unable to process a booking or are required to cancel a booking for this reason.
We use different methods to collect data from and about you including through:
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
We may receive personal data about you from various third parties as set out below:
(i) analytics providers such as Google based outside the EU and ResponseTap based inside the EU.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally we do not rely on consent as a legal basis for processing your personal. If there are any circumstances where we do obtain and rely on your consent, you will have the right to withdraw consent to marketing at any time by contacting us.
We have set out below, in a table format, 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. We have also identified what our legitimate interests are where appropriate.
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. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new customer.||(a) Identitiy;
|Performance of a contract with you or taking steps to enter you into a contract.|
|To process and deliver your booking including:
(a) Manage payments, fees and charges;
(b) Collect and recover money owed to us.
(e) Marketing and Communications.
|(a) Performance of a contract with you or taking steps to enter you into a contract;
(b) Necessary for our legitimate interests (to recover debts due to us).
|To provide you with visa application services and process any applications for visas on your behalf, where you have instructed us to do so.||(a) Identity;
|Performance of a contract with you or taking steps to enter you into a contract.|
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey.
(c) Marketing and Communications.
|(a) Performance of a contract with you;
(b) Necessary to comply with a legal obligation;
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services).
|To enable you to partake in a prize draw, competition or complete a survey.||(a) Identity;
(d) Marketing and Communications.
|(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).||(a) Identity;
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(d) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
|For the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure||(a) Identity
|Necessary for our legitimate interests (protection and assertion of our legal rights, your legal rights and the legal rights of others)|
|For the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice||(a) Identity
|Necessary for our legitimate interests (the proper protection of our business against risks)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We have set out below the various ways in which you can exert your choices accordingly.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Lotus group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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.
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
(A) External Third Parties as set out in the Glossary.
(B) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
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.
Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.
For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the 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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
If you book with us we will keep your information for 8 years from your return date of travel (in the case of adults) for tax purposes and in order to enable us to defend any legal claims that you may pursue against us.
In addition, in relation to any children that travel on the booking we will keep your information for 6 years from the date of your 18th birthday in order to enable us to defend any legal claims that you may pursue against us.
If you require any further information regarding our retention periods then you can request the same by contacting us.
In some circumstances you can ask us to delete your data: see Request erasure below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
(A) Request access to your personal data.
(B) Request correction of your personal data.
(C) Request erasure of your personal data.
(D) Object to processing of your personal data.
(E) Request restriction of processing your personal data.
(F) Request transfer of your personal data.
(G) Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us via Privacy@lotusgroup.co.uk.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data or to exercise any of your other rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the right to:
LOTUS GROUP TAX STRATEGY
This strategy is approved by the board of Lotus Group Ltd and sets out the Group’s policy and approach to conducting its tax affairs and dealing with tax risk. This strategy will be periodically reviewed. It is effective for the year ending 31 October 2017 and will remain in effect until amendments are approved by the Board.
Group Tax Policy
The Lotus Group philosophy is that the health of its business is directly related to the health of the society in which it operates and that companies which operate within a society should make their proper contribution to the essential institutions of that society.
Lotus Group is committed to:
Tax risks are assessed on a case by case basis with the aim of arriving at well-reasoned conclusions on how each risk should be managed. Where there is any uncertainty as to how a particular tax law should be applied, expert external advice is consulted.
When reviewing tax risk and arriving at a decision the following are taken into account.
The Group firmly believes that it should pay all the of tax legally due in any tax jurisdiction in which it may from time to time operate. It reserves the right to take its commercial needs into consideration but these will not override compliance with all applicable laws and regulations.
The Group’s policy has always been that it will not get involved with artificial, complex or aggressive tax planning strategies. In particular, the commercial logic of any actions will not be overridden for purely tax purposes. It does not make use of any low tax regimes overseas to mitigate tax.
Where internal resources are unclear on tax issues or feel that they do not have the necessary depth of knowledge, expert external advice will be sought.
Dealings with HMRC and Overseas Tax Authorities
The group committed to an open and transparent relationship with tax authorities with particular reference to:
The average woman in this company is paid 26.5% less than the average man. We are an equal opportunities employer and 94% of our staff are on the same basic salary and commission regardless of gender. In addition, three out of eight board directors are female.