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Updated: October 10, 2019
Privacy Statement
Unique Caribbean Holidays Limited is an affiliate of the worldwide representative, Unique Travel Corp. (together, “Unique”, “we”, “us”, “our”), for Sandals and Beaches resorts. Unique is committed to protecting your privacy and this Privacy Notice sets out what personal data we collect, how we collect it, what we use it for and who we share it with.
By “personal data” we mean information about you which could identify you such as your name and contact details, your holiday arrangements, and booking history. Personal data does not include data where you can no longer be identified from it such as anonymised aggregate data.
For the purposes of data protection legislation, Unique is considered the “data controller” of personal data processed in connection with this Privacy Notice. This means that we are responsible for deciding how we hold and use personal data about you. Our address is 32 St Ives Street, London, SW3 2ND. Should you have any questions about this Privacy Notice you can contact us at privacy@uniquecaribbean.co.uk.
We have appointed a data protection officer (DPO) to oversee our data privacy matters. If you have any questions about this privacy notice or how we handle your personal data, please contact the DPO at privacy@uniquecaribbean.co.uk.
This Privacy Notice applies to personal data about you that we collect, use and otherwise process in connection with your relationship with us as a representative of or as an individual tour operator agent or travel agent, including when you book a familiarisation trip with us. Where you also provide us with personal data of others, for instance, guests accompanying you on a familiarisation trip, please provide those persons with a copy of this Privacy Notice.
We may provide supplemental privacy notices 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 personal data. Those supplemental notices should be read together with this Privacy Notice.
Where you also provide us with personal data of others, for instance, guests accompanying you on your holiday, please provide those persons with a copy of this Privacy Notice.
What information do we collect about you and what do we use it for?
The types of personal data about you we may collect, store and use are set out in the table below and in each case we have specified what we use it for and our ‘lawful basis’ for processing it. The law specifies certain ‘lawful bases’ under which we are allowed to use your personal data. Most commonly, we will rely on one or more of the following lawful bases for processing your personal data:
- Where we need to perform the contract we have entered into with you (i.e. we need to provide the services you have booked);
- Where we need to comply with a legal obligation;
- 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 you have consented to us doing so.
| Category of personal data | What we use this data for | Lawful basis |
|---|---|---|
|
Personal contact details including name, contact number, e-mail address, postal address |
Contacting you in relation to the services you have booked and in order to collect and recover payment due to us
|
To perform our contract with you
|
Date of birth |
Booking the services that you requested |
To perform our contract with you |
Payment card information |
Processing your payment for the services you have booked |
To perform our contract with you |
Name(s) and date(s) of birth of any accompanying guests, including children |
Booking the services that you have requested |
To perform our contract with you |
Flight details |
Coordinating reservations and your pick-up and drop-off to and from the airport at your trip destination |
To perform our contract with you |
Dates of stay |
Identifying the dates on which you have reserved our services |
To perform our contract with you |
Name of your host resort |
Identifying the resort at which you have booked our services |
To perform our contract with you |
Information about how you use our website (for example, the pages you visit and how you navigate through our website) |
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we deliver to you. To use data analytics to improve our website, products/services, marketing, client relationships and experiences |
Processing is necessary for the purposes of our legitimate interests in studying how our customers use our products/services, to develop them, grow our business and inform our marketing strategy. Processing is necessary for the purposes of our legitimate interests to define types of customers for our products/services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy. |
Information about your location based on your IP address |
Knowing the country you are in helps us to provide you with more relevant content. We also use this information to analyse how our website users interact with our websites. |
Processing is necessary for the purposes of our legitimate interests in providing you with relevant content and studying how our website users interact with our websites. |
Information on your marriage certificate and passport (if your legal name has changed) |
To request a legal name change for your airline ticket from the airline provider |
To perform our contract with you |
Information on driving license or other legal identification document |
To prove the identity of winners (and their travel companions) of sweepstakes, giveaways and contests |
Our legitimate interests in providing the prize to the rightful winner together with their travel companions To comply with our legal obligations Our legitimate interests in maintaining our accounts and records in relation to our sweepstakes, giveaways and contests. |
Other information you give during a call to one of our call centres or customer service agents (please note that such calls are recorded) |
To provide customer care training and for quality purposes |
Our legitimate interests in training our staff and reviewing the quality of care provided by our staff. |
Special categories of personal data
Certain categories of personal data, such as race, religion or health, are considered to be “special categories” of personal data as they are more sensitive types of data. We try to limit the circumstances where we process special categories of personal data as much as possible, however, we may also occasionally collect, store and use the special categories of personal data set out in the table below.
"Special categories" of more sensitive personal data require higher levels of protection whereby we need to have further justification for collecting, storing and using this type of personal data. We may process special categories of personal data with your explicit consent. Less commonly, we may process this type of information where it is needed in relation to legal claims.
| Category of special category personal data | What we use this data for | Lawful basis |
|---|---|---|
|
Dietary requirements revealing or suggesting a religious or philosophical belief or a health condition |
Minimising health risks (e.g. allergic reactions) and accommodating guest preferences |
Your explicit consent |
Relevant medical information such as current medications taken |
In case of an emergency
|
Your explicit consent |
Special categories may also encompass other requests in relation to your travel arrangements that may contain or suggest some details about you that could be categorised as more sensitive personal data. For instance, you may request that special meals are available to you in resort which could imply or suggest that you hold particular religious beliefs or have a particular medical condition.
By providing us with special categories of personal data you explicitly consent to our collecting, using and sharing this information with third parties and transferring such data outside of the EU as described in this Privacy Notice. We do not require you to provide us with special categories of personal data, however, if you do not do so we are unlikely to be able to accommodate your needs. Similarly, if you withdraw your consent (see Right to withdraw consent below) we are unlikely to be able to accommodate your needs.
Please note that we may use your personal data without your knowledge or consent, in compliance with the above rules, if we are required by law to do so or if we reasonably believe that it is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
What if you do not provide the personal data we request?
If you do not provide us with certain information when requested, we will not be able to provide all or some of the trip elements (such as booking your flights or hotel).
Change of purpose
We will only use your personal data for the purposes for which we collected it (as identified above in the What we use this data for column), unless we reasonably consider that we need to use it for another reason which is compatible with the original purpose. 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.
How do we collect this information?
We typically collect personal data about you when you book a familiarisation trip with us or otherwise contact us in relation to your role as a tour operator agent or travel agent.
In addition, we may receive personal information about you from third parties, such as:
- Companies contracted by us to provide services to you
- Companies involved in your travel plans
Who will it be shared with?
- The resort at which you are staying;
- The airline providing your flights;
- Other entities within our group who participate in the booking process for the services provided to you;
- Our booking system providers;
- Our tour provider if you choose to book a tour;
- The Sandals Foundation if you choose to make a donation;
- Third party service providers we are using to provide services that involve data processing such as IT and system administration services;
- Professional advisers including our legal teams (both internal and also external law firms), bankers, auditors and insurers to the extent such information is relevant to the performance of their services;
We will share your personal data with other entities in our group who participate in the booking process for the services provided to you, as part of our regular reporting activities in company performance, in the context of a business reorganisation or group restructuring exercise, for system maintenance support and hosting of data.
In the event of our insolvency we, or any appointed insolvency practitioner, may disclose your personal data to the Civil Aviation Authority (“CAA”) and/or ABTA so that they can assess the status of your booking and advice you on the appropriate course of action under any scheme of financial protection. You can find the CAA’s general privacy notice at https://www.caa.co.uk/Our-work/About-us/General-privacy-notice/ and ABTA’s privacy notice at https://www.abta.com/privacy-notice (links correct at the time of the last update to this privacy notice). We do not control these third party websites and are not responsible for their privacy notices.
We may share your personal data with third parties, for example in the context of the possible sale or restructuring of the business. We may also need to share your personal data with a regulator or to otherwise comply with the law or a judicial process. We may disclose your personal data if we are required by law to do so or if we reasonably believe that disclosure is necessary to protect our rights and/or to comply with judicial or regulatory proceedings, a court order or other legal process.
We may transfer the personal data we collect about you to Canada UK and Canada where our servers are located for our legitimate interests in hosting all data on our central servers there. There is an adequacy decision by the European Commission in respect of Canada which means it is deemed to provide an adequate level of protection for your personal data.
We may also transfer the personal data we collect about you to countries where the third parties listed above are located including the United States, Panama, Jamaica, Bahamas, St. Lucia, Antigua, Grenada, Barbados and Turks & Caicos in order to book your requested familiarisation trip. Your personal data may also be transferred to Honduras and India where our database maintenance teams are located for our legitimate interests in maintaining such database. These countries may not have the same standard of data protection laws as the EU.
However, to ensure that your personal data does receive an adequate level of protection we will put in place appropriate safeguards such as the EU-approved standard contractual clauses to ensure that your personal data is treated in a way that is consistent with and which respects the EU and UK laws on data protection. If you require further information about this protective measure you can request it from privacy@uniquecaribbean.co.uk.
How long will we retain your information?
We will only retain your personal information 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.
Generally, we will keep information relevant to our dealings with you for up to 7 years once you have ceased being a customer. Exceptional circumstances will or may apply to customer service data where we will keep information for up to 10 years.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you as it is no longer personal data.
Once we no longer require your personal data for the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements, we will securely destroy your personal data in accordance with applicable laws and regulations.
Your rights in relation to your information
It is important that the personal data we hold about you is accurate and current. Please let us know if your personal data changes during your relationship with us.
You have rights as an individual which you can exercise in relation to the information we hold about you under certain circumstances. These rights are to:
- Request access to your personal data (commonly known as a “data subject access request”) and request certain information in relation to its processing;
- Request rectification of your personal data;
- Request the erasure of your personal data;
- Request the restriction of processing of your personal data;
- Object to the processing of your personal data;
- Request the transfer of your personal data to another party.
If you want to exercise one of these rights please contact us at privacy@uniquecaribbean.co.uk.
You also have the right to make a complaint at any time to a supervisory authority for data protection issues.
Fees
You will not usually 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 for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact privacy@uniquecaribbean.co.uk. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose(s) you originally agreed to unless we now have an alternative legal basis for doing so.
Changes to this privacy notice
We reserve the right to update this privacy notice at any time, and we will make an updated copy of such privacy notice available on our website and notify you when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.