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1. OUR IDENTITY AND CONTACT DETAILS
1.1 We collect, use and are responsible for certain personal information about you. When we do so we are subject to the General Data Protection Regulation, which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
1.2 Please note that we are not the controller of any personal information provided directly by individuals to hotels or relating to hotel guests or travellers where a booking is made through another travel company. The data controllers in these cases will be the relevant hotel or travel company via which a booking was made. In these circumstances, it is the responsibility of the hotel or travel company to ensure they have authorisation for Miki Travel to use your personal data to fulfil our obligations in respect of providing the service requested. In such cases, if you are a hotel guest or traveller and have any queries regarding the use of your personal data or wish to access your personal data, you should contact the relevant data controller directly (or contact us, and we will try to assist with directing you to the relevant person).
1.5 It would be helpful to explain some key terms used in this policy and providing our contact details:
2. PERSONAL INFORMATION WE COLLECT ABOUT YOU
How your personal information is collected
However, we may also collect information:
Information we collect about you
2.2 The information we collect when you engage with us for any of the purposes described above may include, for example:
3. USES MADE OF THE INFORMATION
3.1 We use information held about you in the following ways:
4. OUR LEGAL GROUNDS FOR PROCESSING YOUR INFORMATION
We will only process special category information with your explicit consent.
5. PROMOTIONAL COMMUNICATIONS
5.1 We may use your personal information to send you updates (by email, text message, telephone or post) about our products and services.
5.2 We have a legitimate interest in processing your personal information for promotional purposes (see 3 above). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
5.3 We will always treat your personal information with the utmost respect and never sell or share it with other organisations outside the Miki group for marketing purposes.
5.4 You have the right to opt out of receiving promotional communications at any time by:
We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.
6. WHO WE SHARE YOUR PERSONAL INFORMATION WITH
6.2 The personal information you provide to us may also be routinely shared with and processed by:
6.3 We may also share personal information with our own professional advisors and auditors for the purpose of seeking professional advice or to meet our audit responsibilities.
6.4 We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
6.4 We may also need to share some personal information with other parties, such as another organisation to whom we transfer our agreement with you or potential buyers of some or all of our business or during a re-structuring.
7. WHERE YOUR PERSONAL INFORMATION IS HELD
7.1 Information may be held at our offices and those of our group companies, third party agencies, service providers, representatives and agents as described above (see section 6 above).Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see section 9 below.
8. HOW LONG YOUR PERSONAL INFORMATION WILL BE KEPT
8.1 We will keep your personal information while you have an account with us or we are providing products and services to you. Thereafter, we will keep your personal information for as long as we consider necessary:
8.2 We will not retain your personal information for longer than necessary for the purposes set out in this policy. When it is no longer necessary to retain your personal information, we will delete or anonymise it
9. TRANSFERRING YOUR PERSONAL INFORMATION OUT OF THE EEA
9.1 To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
These transfers are subject to special rules under European and UK data protection law.
Some of these non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, only do so where the transfer complies with data protection law (for example, using standard data protection contract clauses that have been approved by the European Commission).
10. YOUR RIGHTS
10.1 You have the following rights, which you can exercise free of charge:
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
10.2 If you would like to exercise any of those rights, please:
11. KEEPING YOUR PERSONAL INFORMATION SECURE
11.1 We keep your information secure by taking appropriate technical and organisational measures to guard against unauthorised or unlawful processing, accidental loss, destruction or damage. For example:
11.2 However, while we will take reasonable care to protect your personal information, we cannot guarantee the security of your information which is transmitted to any website or any other online platform operated by us via an internet or similar connection. Where you have a password or username which enables you to access certain parts of our website, you are responsible for keeping these confidential.
11.3 We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
12. HOW TO COMPLAIN
12.1 We hope that we can resolve any query or concern you may raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: 0303 123 1113.
14. HOW TO CONTACT US
Data Protection Compliance Manager,
68 Upper Thames Street,
London EC4V 3BJ