Introduction

This is a notice to inform you of our policy about all information that we record about you. It sets out the conditions under which we may process any information that we collect from you, or that you provide to us. It covers information that could identify you (“personal information”) and information that could not. In the context of the law and this notice, “process” means collect, store, transfer, use or otherwise act on information.

We take seriously the protection of your privacy and confidentiality. We understand that all visitors to our website are entitled to know that their personal data will not be used for any purpose unintended by them, and will not accidentally fall into the hands of a third party.

We undertake to preserve the confidentiality of all information you provide to us, and hope that you reciprocate.

Our policy complies with UK law accordingly implemented, including that required by the EU General Data Protection Regulation (GDPR).

We have in place procedures and training for data protection, confidentiality and information security. These are regularly reviewed to ensure that they remain effective.

The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at www.knowyourprivacyrights.org

With the exception of the detail set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.

Data we process - We aim to process data, whether personal data or not, only to the extent necessary for us to provide our clients with our services and for other agreed purposes. In most cases, your personal data will have been provided to us by you. Often we may aggregate information in a general way and use it to provide class information. If we use it for this purpose, you as an individual will not be personally identifiable.

Clients

In order to provide you with a holiday, we must process personal information.

This information includes your name and address, your proficiency at and previous experience of the sports that you might undertake on your holiday, travel arrangements, dietary preferences, insurance policy information and copies of identification documents.

We also process information deemed to be “special category” information, which may include information that identifies your race or ethnic origin, information about your health and medical history, and information that discloses sexual orientation.

With your consent, we may process images and video of you taken during a holiday.

We process the same types of information about children who accompany us on our holidays as we do about adult clients.

Guides and other service providers

If you supply our business with goods or services, including subcontracted services that we supply to our clients, then we may process your personal information. However, we do so only to the extent necessary to contract with you. If you are a guide, we may process information deemed to be “special category” information, which may include information that identifies your race or ethnic origin, information about your health and medical history, and information that discloses sexual orientation.

The bases on which we process information about you

The law requires us to determine under which of six defined bases we process different categories of your personal information, and to notify you of the basis for each category. If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data. If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Information we process because we have a contractual obligation with you

We process your personal information when doing so is necessary to carry out our obligations under a contract between us, or when doing so is necessary in order to form a contract.

Additionally, we may aggregate this information in a general way and use it to provide class information, for example to monitor our performance with respect to a particular service we provide. If we use it for this purpose, you as an individual will not be personally identifiable.

We shall continue to process this information until the contract between us ends or is terminated by either party under the terms of the contract.

Information we process with your consent

Through certain actions when otherwise there is no contractual relationship between us, such as when you browse our website or ask us to provide you more information about our business, you provide your consent to us to process information that may be personal information.

Wherever possible, we aim to obtain your explicit consent to process this information, for example, by asking you to agree to us sending you a regular newsletter.

Except where you have consented to our use of your information for a specific purpose, we do not use your information in any way that would identify you personally. We may aggregate it in a general way and use it to provide class information, for example to monitor the performance of a particular page on our website.

We continue to process your information on this basis until you withdraw your consent or it can be reasonably assumed that your consent no longer exists.

You may withdraw your consent at any time by contacting us.

Information we process because we have a legal obligation

There may be occasions where we must process your information in order to comply with a statutory obligation.

For example, we may be required to give information to legal authorities.

This may include your personal information

Specific uses of information you provide to us:

Communicating with you 

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address so as to be able to track our communications with you to provide a high quality service.

Dealing with complaints

When we receive a complaint, we record all the information you have given to us.

We use that information to resolve your complaint.

If your complaint reasonably requires us to contact some other person, we may decide to give to that other person some of the information contained in your complaint. We do this as infrequently as possible, but it is a matter for our sole discretion as to whether we do give information, and if we do, what that information is.

If the complaint relates to information on our website and we feel it is justified or if we believe the law requires us to do so, we shall remove the information while we investigate.

If we think your complaint is vexatious or without any basis, we shall not correspond with you about it.

We may compile statistics from information relating to complaints to assess the level of service we provide, but not in a way that could identify you or any other person.

Information relating to your method of payment

Payment information is never taken by us or transferred to us. Our employees and contractors never have access to it.

At the point of payment, you are transferred to a secure page on the website of Stripe. It is the payment service provider that records your credit or debit card information.

Sending a message to our support team

When you contact us, whether by telephone, through our website or by e-mail, we collect the data you have given to us in order to reply with the information you need.

We record your request and our reply in order to increase the efficiency of our business.

We keep personally identifiable information associated with your message, such as your name and email address only as long as required.

Use of information we collect through automated systems when you visit our website:

Cookies

Cookies are small text files that are placed on your computer's hard drive by your web browser when you visit any website. They allow information gathered on one web page to be stored until it is needed for use on another, allowing a website to provide you with a personalised experience and the website owner with statistics about how you use the website so that it can be improved.

Some cookies may last for a defined period of time, such as one day or until you close your browser. Others last indefinitely.

Your web browser should allow you to delete any you choose. It also should allow you to prevent or limit their use.

Our website uses cookies. They are placed by software that operates on our servers, and by software operated by third parties whose services we use.

We use cookies to track how you use our website and to record whether you have seen specific messages relating to privacy preferences that we display on our website.

Personal identifiers from your browsing activity

Requests by your web browser to our servers for web pages and other content on our website are recorded.

We record information that your browser reports such as your geographical location, your browser software and version, the type of computer or device you are using and the screen resolution.

We use this information in aggregate to assess the popularity of the webpages on our website and how we perform in providing content to you.

This data cannot be used to identify you personally.

Disclosure and sharing of your information:

Credit reference

To assist in combating fraud, we share information with credit reference agencies, so far as it relates to clients or customers who instruct their credit card issuer to cancel payment to us without having first provided an acceptable reason to us and given us the opportunity to refund their money.

Data is not processed outside the European Union

Our websites are hosted in the United Kingdom. We do not process personal data outside the European Union.

Transfers of personal information

We work with third party service providers to whom we may pass your personal information. These may include:

· your guide

· the hotels in which you stay

· transfer agencies

· other tour operators with whom we partner to provide some part of your holiday

· our accountants, lawyers and other professional service providers

· online marketing platforms

We manage the information we transfer carefully, making sure that it is restricted to that which is necessary to provide you with the highest level of service.

All third parties we use or with whom we partner are themselves compliant with the same data protection law to which we are subject.

Access to your own information

At any time you may review or update personally identifiable information that we hold about you.

To obtain a copy of any information you may send us a request.

After receiving the request, we will tell you when we expect to provide you with the information, and whether we require any fee for providing it to you.

Removal of your information

If you wish us to remove personally identifiable information you may contact us.

Removal of information may limit the service we can provide to you.

Verification of your information

When we receive any request to access, edit or delete personal identifiable information we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to safeguard your information.

Images of you on our holidays

It is possible that our clients, staff or suppliers may take photographs/films of moments of your holiday which may include photographs/films of our clients. We may use these images in future marketing materials and these will be stored physically and digitally. 

If you do not wish you or your family to be photographed or filmed or for any photographs and films which may contain images of you or your family to be used in this manner, please advise your Tracks and Trails guide at the beginning of your trip. If, for any reason, you find that you or any of your family are portrayed in images displayed on our website or in our marketing material against your will, please contact us and we will remove the images immediately. 

Other matters:

How you can complain

If you are not happy with our privacy policy or if you have any complaint then you should tell us by email.

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Information Commissioner's Office. This can be done at https://ico.org.uk/concerns/

Retention period for personal data

Except as otherwise mentioned in this privacy notice, we keep your personal information only for as long as required by us:

• to provide you with the services you have requested;
• to comply with other law, including for the period demanded by our tax authorities;
• to support a claim or defence in court.

Compliance with the law

Our privacy policy has been compiled so as to comply with the law of every country or legal jurisdiction in which we aim to do business. If you think it fails to satisfy the law of your jurisdiction, we should like to hear from you.

However, ultimately it is your choice as to whether you wish to use our services and our website.

Review of this privacy policy

We review our privacy policy regularly, and may update this notice from time to time as necessary.

If you have any question regarding our privacy policy, please contact us.