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IMPORTANT INFORMATION AND WHO WE ARE
Black Tomato respects your privacy and is committed to protecting your personal data. This privacy policy is designed to tell you about our information collection practices – that is, the ways we collect information; what kinds of information we collect; why we collect information; how we use information we collect; with whom we share information we collect; how you can access, amend, and delete information we collect from you; and what kinds of security we use to protect information you provide.

It is important that you read this privacy policy together with any other privacy policy or fair processing notice that 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 policy supplements other notices and privacy policies and is not intended to override them.

Controller

Black Tomato Limited is the data controller and responsible for your personal data (referred to as “Black Tomato”, “we”, “us” or “our” in this privacy policy).

We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights please contact the Data Privacy Manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our Data Privacy Manager by post, telephone or email as follows:

Full name of legal entity: Black Tomato Limited

Email address: dataprotection@blacktomato.com

Postal address: LG Floor, 4-14 Tabernacle Street, London, EC2A 4LU

Telephone number: 0207 426 9888 from UK or 1 646 558 3644 from US

COMPLAINTS

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 (www.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.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review and reserve the right to make changes. This version was last updated on 10th May 2019. 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 your personal data changes during your relationship with us.

Third-party links

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 policy of every website you visit.

 

THE DATA WE COLLECT ABOUT YOU
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 as follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you and other details of travel services you have purchased from us.
Technical Data includes 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.
Profile Data includes your username and password, details of previous enquiries, itineraries or bookings made by you, your interests, preferences, feedback and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 treat the combined data as personal data which will be used in accordance with this privacy policy.

Special category data:

Health/mobility data: When you make an enquiry for a travel booking with us, we will ask you to/you may disclose any medical conditions/health issues or any restrictions on your mobility. This is to enable us (and the operators/suppliers of your holiday) to provide for your health, safety and welfare during your trip, which is our legal responsibility.  Any information of this type that you provide to us constitutes special category data under applicable data protection laws and so when you provide it to us, you give your consent to us using such information for the purpose of making your travel arrangements including our sharing of your information with the suppliers of your trip for this purpose (see section 5 Disclosure of your Personal Data).

If you choose not to disclose this information to us or your consent to use it for the outlined purposes, we may not be able to provide the services you have requested due to our legal responsibility to provide you with a safe holiday.

Religious beliefs: We will also ask you to disclose to us any dietary requirements that you have and you may also choose to disclose to us your religious beliefs if this informs your particular travel itinerary choices/interests. Religious beliefs constitute special category data. Accordingly, when you provide this information you confirm your consent to us using such information for the purpose of making your travel arrangements, including our sharing of your information with the suppliers of your trip for this purpose.

IF YOU FAIL TO PROVIDE PERSONAL DATA

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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

HOW WE COLLECT YOUR PERSONAL DATA
We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by communicating with us by post, phone, email or otherwise. This includes personal data you provide when you:
enquire about or book our travel services (either directly or via a travel agent);
create an online account via our website;
subscribe to our newsletters or other publications;
request marketing to be sent to you;
enter a competition, promotion or survey;
give us feedback or contact us; and
contact us via social media or follow/like our social media pages.
Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy https://www.blacktomato.com/cookie-policy/ for further details. Whilst some of this Technical Data does not allow us to personally identify you, we may link this data with personally identifiable information you have provided to us.
Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
(a)  analytics providers such as Google Analytics based inside or outside the EU;

(b)  advertising networks such as Bing based inside or outside the EU; and

(c)  email marketing service providers such as “dotmail” based inside or outside the EU;

(d) data and trend analysers such as Pulsar based inside or outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EU.
Information about other people.

If you provide information to us about any person other than yourself, such as people you are enquiring or making a booking on behalf of or people you are travelling with, you must ensure that they understand how their information will be used and that they have given their permission for you to disclose it to us and for you to allow us, and our service providers, to use it in accordance with this Privacy Policy.

HOW WE USE YOUR PERSONAL DATA
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:

Where we need to perform the contract we are about to enter into or have entered into with you (i.e. in order to service your travel enquiry or your booking).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending direct marketing communications to you if you have not previously enquired or booked a holiday with us and in order to share your personal data with any third party for their marketing communications. We will also rely on your consent to our use of special category data as outlined in the paragraph “Special Category Data” above.

You have the right to withdraw consent to marketing at any time by contacting us (see Section 1 Contact Details) or in the case of email marketing, including our newsletter, if you unsubscribe.
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