Privacy Policy

Company information

This privacy policy is for Batutta, a trading name of Serendipity Tailormade Ltd (company number 07449868) and whose registered office is at 1A Local Board Road, Watford, WD17 2JP. (“Batutta”). Where this Privacy Notice refers to “Batutta”, “we”, “us” or “our”, it is referring to Serendipity Tailormade Limited. Our telephone number is 0203 397 4397 and are open from Monday to Friday inclusive, 10am – 6pm. Our e-mail address is mail@serendipity.travel

This Privacy Notice sets out how we collect and process your personal data in relation to the brand known as Batutta. This Privacy Notice also provides certain information that is legally required and lists your rights in relation to your personal data.

This Privacy Notice relates to personal information that identifies “you” meaning a customer or potential customer, individuals who browse our website or individuals outside our organisation with whom we interact. If you are an employee, contractor or otherwise engaged in work for us or applying to work for us, a separate privacy notice applies to you instead.

This Privacy Notice covers the Serendipity Tailormade Ltd portfolio of brands, its websites, mobile applications and mobile websites (collectively referred to as the “Platforms”)

We refer to this information throughout this Privacy Notice as “personal data” and section 3 sets out further detail of what this includes.

This Privacy Notice may vary from time to time so please check it regularly. This policy was last updated on 11th November 2020.

Data controller and contact details

For the purposes of relevant data protection legislation, we are a controller of your personal data and as a controller we use the personal data we hold about you in accordance with this Privacy Notice.

If you wish to correct your personal data held by us or to opt out at any time from receiving marketing correspondence from us or to alter your marketing preferences please visit here for how to do this.

If you need to contact us in connection with our processing of your personal data, then our contact details are mail@serendipity.travel

Data Protection Officer

Our Data Protection Officer can be contacted at 1a Local Board Road, Watford, WD17 2JP or by email at mail@serendipity.travel

The personal information we collect

When you purchase a plan with us we will collect the following personal information:

• Name

• Title

• Date Of Birth

• Address

• Contact Details (Including Email Address And Telephone/Mobile Number)

• Gender

• Payment Card Details

• Nationality And Other Information For Tax Purposes (Some Countries Only)

• Country of residence

• Nationality

• Preferred language

• marketing preferences

How we use this personal information

We use your personal information to:

• fulfil our agreement with you and/or deal with your itinerary or intended itinerary, including processing your itinerary, sending you your itinerary or other details relating to your trip

• update you on changes to your travel itinerary (for example, if there is a change to your booking pre travel; if a flight is delayed or cancelled)

• process payments for your plan purchase and for accounting or audit purposes

• personalise the service and offers you receive (for example, by being aware of previous travel experiences, transactions or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile)

• personalise the look and feel of our Platforms and communications with you, so as to align with preferences you may have told us about or which we have inferred from your use of our Platforms, market research, your interactions with us on social media and previous transactions (details on How we use your personal information for marketing purposes, profiling and analytics are below)

• communicate and interact with you at different touch points throughout your journey

• improve the products and services we offer or help us to create new ones

• conduct customer satisfaction surveys so that we can obtain a better understanding of how we can continue to improve the products and services we offer or help us to create new ones. During these surveys we may collect personal information from you relating to your thoughts/comments about your experience with us

• market our products and services to you (details on How we use your personal information for marketing purposes, profiling and analytics are below)

• manage our business such as for systems testing, IT maintenance or development training, benchmarking and performance measurement

• use in connection with your online account (details on Personal information we collect and use if you register an online account with us are below)

• as you may authorise or consent to additionally from time to time

We use the personal information we collect if you register an online account, together with the Personal information we collect and use if you make a booking with us, to:

• manage the online account in accordance with its terms and conditions

• communicate and interact with you at different touch points throughout your journey (for example, in the event of service failures, compliments or complaints)

• provide insights about travel behaviours (such as the industries and companies using our services for business travel) in order to provide industry or company specific offers

• extend invitations to our events

• authenticate log-ins to your online account and detect and prevent fraud in connection with your online account

• as you may authorise or consent to additionally from time to time

Any information we collect will also be used in accordance with the terms and conditions of the online account.

We do not generally collect other categories of personal information from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it and handle it with extra care. We also share this information with third parties (who help manage our business and deliver services such as those parties who provide wheelchairs at airports) and other companies within the Serendipity Tailormade Ltd Group (who help manage your booking or journey), and we transfer it globally.

Where you (or any passenger travelling) provides us with special categories of personal information you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which it was collected.

If you have any queries about any of our products or services, compliments or complaints, or requests, we will need to collect information from you, including your contact details, in order for us to respond to your query or provide you with assistance. We will collect this information when you submit a form on our Platforms, send us an email, call our customer service centre, visit a local office or retail centre, or contact us via another form of communication such as through social media or an online chat tool.

We also keep a record of the communications we have with you including call recordings so that we can monitor and improve the quality of our customer support services, comply with relevant legal obligations and to make and defend claims.

How we use this personal information

We use your personal information to:

• address your inquiry or any other interaction with us as efficiently as possible

• analyse the types of inquiries received to improve our products and services and interactions with our customers

• to authenticate your identity such as when you call our customer service centre

• manage any claims you make for compensation or otherwise

• as you may authorise or consent to additionally from time to time

We may from time to time hold contests, competitions or prize draws or make available promotional offers. If you want to take place in any of these, we ask you to provide us with certain personal information and we also use this information to keep in touch with you about our products, services and any special offers which we think may be of interest.

Types of personal information we collect

The types of personal information we collect includes your:

• name

• title

• date of birth

• address

• contact details (including email address and telephone/mobile number)

How we use this personal information

We use your personal information to:

• administer the contest, competition, prize draw or promotional offers and improve them

• as you may authorise or consent to additionally from time to time

Any information we collect will also be used in accordance with the terms and conditions of the contest, competition, prize draw or promotional offer.

Personal information we collect and use when you use our Platforms

Our Platforms use cookies. A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet, and helps us provide better Platform services to you and tailor certain content. Cookies may collect personal information about you.

Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes

We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order, and to protect our property, rights and interests as well as the property, rights and interest of other persons.

We also process your personal information for crime prevention and detection purposes, including the prevention of fraud for online payments, for identity verification, for credit checking and credit scoring purposes and accounting or audit purposes. In each case, we do so in compliance with applicable laws.

Personal information we collect and use from third parties

We collect personal information from third parties who you have authorised to provide your personal information to us (for example, this may be your travel agent or another person planning a trip on your behalf, your travel companion, your travel coordinator, our promotion partners, social media and other digital platforms). We combine this information with the information we collect directly from you or about you for the purposes set forth in this Privacy Notice.

We also collect personal information from individuals who may refer you as a friend to our products or services. We ask these individuals to confirm that you are happy to hear from us.

Personal information we collect and use when you are making a payment

We collect different personal information depending on your payment method (such as credit card, bank transfer, cash). For example, for credit card payments we may collect the credit card holder name, address, card number, expiry date and CVC code. You may also choose to store your credit card details with us for future use. We do not store your CVC/CVV code (which is the security code on the back of a credit card).

Planning a trip on behalf of another person

If you are planning a trip on behalf of another person(s), it is your responsibility to obtain their consent to do so and share their details with us (as anticipated by this Privacy Notice), which we will assume that you have done prior to initiating the process. Where required by local laws, we would advise you to keep a record of their agreement and provide them with a copy of, or link to, this Privacy Notice.

Legal basis for using your personal information

We will only collect, process use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• we need to use your personal information to perform a contract or take steps to enter into a contract with you. For example, to take payment for your plan purchase

• we need to use your personal information for our legitimate interest as a commercial organisation. For example, we may record calls to our customer service centre so that we can review how we handle calls and make any necessary improvements or we may share your personal information with other Serendipity Tailormade Ltd Group companies to improve our products and services. We may also capture your interactions with our website and planning journey via tools on our website in order to identify errors or issues and ensure your customer experience meets expectations. In all such cases, we will look after your information at all times in a way that is proportionate, that respects your privacy rights and is in accordance with our Privacy Notice, and you have a right to object to processing as explained in Legal rights available to help manage your privacy;

• we need to use your personal information to comply with a relevant legal or regulatory obligation that we have.

• we have your consent to using your personal information for a particular activity. For example, where you consent to us sharing with you special offers about the Serendipity Tailormade Ltd Group which we think may be of interest

We set out more information about the legal bases for which we process personal information in the table which you can access here. There may be one or more legal bases relevant to an activity listed in this table. The table may be amended and updated from time to time.

Sharing your personal information with others

We share your personal information in the manner and for the purposes described below:

• with other entities within the Serendipity Tailormade Ltd Group where such disclosure is necessary to provide you with our products and services or to manage our business, including loyalty schemes. We may also share your personal information within the Serendipity Tailormade Ltd Group to personalise the service and offers you receive (for example, by being aware of previous travel experiences, transactions or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile); to develop a single view of our customers’ transactions, interactions, preferences and behaviours across the Serendipity Tailormade Ltd Group; to improve the products and services we offer or help us to create new ones and for marketing, profiling and analytics as detailed in Personal information we collect and use for marketing purposes, profiling and analytics below; and for the purposes described in this Privacy Notice. Brands under the Serendipity Tailormade Ltd group include Serendipity Tailormade, Luxury Halal Travel, The Serendipity Foundation, Tryp Hacker and Rihaala.

• With third parties who help us manage our business and deliver our products and services, including loyalty schemes. These third parties have agreed to confidentiality obligations and use any personal information we share with them or which they collect on our behalf solely for the purposes of providing the contracted service to us. These third parties include service providers who help manage our IT and back office systems, detect fraudulent transactions and security incidents, provide customer service centre support, manage airport operations, manage communications and tailor marketing and advertising; verify payments such as banks and payment card companies; manage our data warehouses; provide services to administer our Platforms; provide internet services; host our facilities; provide airport ground handling and assistance; provide car services; and conduct research that assists us with understanding consumer interests.

• with third party advertising and social media platforms to provide advertising as detailed in Personal information we collect and use for marketing purposes, profiling and analytics below;

• bank and payment providers to authorise and complete payments;

• we may share in aggregate, statistical form, non-personal information regarding the visitors to our Platforms, traffic patterns and Platform usage with our other entities within the Serendipity Tailormade Ltd Group or third party advertisers and social media and digital platforms to provide advertising;

• if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third party purchaser of our business or assets.

Personal information we collect and use for marketing purposes, profiling and analytics

How we use personal information to keep you up to date with our products and services

We use personal information to let you know about Serendipity Tailormade Ltd Group products and services that we think may be of interest to you. This may be based on your preferences, derived from Cookies, inferred from your interactions with us including on our social media accounts or market research. We may also let you know about our corporate services which we believe may be relevant to you in a professional capacity.

We also work with social media and other digital platforms to provide you with advertisements within those platforms. We provide them with your name and contact details (such as your email address or phone numbers). If these social media and digital platforms match profile information provided by us with your profile information held by them then they will serve you our advertisements. The social media platforms will not identify you or share other personal information in your social media account to us.

We will only send you direct marketing, whether about us, carefully selected third parties or partners, products or services, in accordance with your marketing preferences. We may contact you by email, SMS/text, social media, or through other communication channels that we think you may find helpful. If at any time you would like us to stop sending you marketing material contact us or choose the relevant "unsubscribe" option set out below.

How you can manage your marketing preferences

To protect your privacy and to ensure you have control over how we manage marketing with you (and provided that you have indicated that you would like to receive it):

• we will take steps to limit direct marketing to a reasonable and proportionate level;

• only send you communications which we believe may be of interest or relevance to you and at all times in line with your permissions, which, as appropriate, may include:

o telling you about developments in the products and services available through our Platforms and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);

o allowing other companies within the Serendipity Tailormade Ltd Group to send you information about developments in their products and services; and

o allowing third parties to send you marketing or updates relating to their products or services.

• you have the ability to change your cookie settings to block certain types of cookie - this is explained in more detail in our Cookie Policy

• you can click the "unsubscribe" link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us or changing your account settings which will remove you from the relevant marketing list;

• if you do not want to be served with our advertisements within social media or other digital platforms, you can manage your preferences within these platforms.

Be aware that if you unsubscribe completely from our marketing communications we may be unable to notify you of tailored offers to meet your needs. If you do unsubscribe from marketing communications you will still receive operational and service messages from us regarding your booking including where you may not have completed a booking (such as abandoned cart emails or pop-up notices), and responses to your enquiries made to us.

When and how we undertake analytics and profiling

Analytics

We aggregate personal information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Platform use, to improve our content and products and services, to customise our Platforms’ content, layout, products and services, and to support our business operations and we may appoint third parties to do this on our behalf, as set out above in Sharing personal information with others.

We gather certain usage information like the number and frequency of visitors to our Platforms. This information includes which webpage you just came from, which webpage you next go to, what browser you are using, your device ID and your IP address. This collective data helps us to determine how much our customers use parts of our Platforms, and do research on our users’ demographics, interests, and behaviour to better understand and serve you. One of the ways we do this is by installing and using Cookies on your browser or device. You can find out more about cookies and our Cookie Policy in the section entitled Cookies below.

If you use buttons on our Platforms linked to social media or similar sites (for example, "Like" and/or "Share" buttons), content from our Platforms may be sent back to those sites and, depending on your privacy settings, may be privately or publicly visible (for example, to friends, followers or generally to anyone who has access to your profile page).

Profiling

We use personal information such as your date of birth, gender, country of residence, transactions (for example, payments made with us and flights taken), information derived from Cookies and your preferences and behaviours for profiling. Some of the legitimate purposes we profile personal information include:

• to obtain a better understanding of what you would like to see from us and how we can continue to improve our services for you;

• to personalise the service and offers you receive from us, including with invitations to special events;

• to provide you with tailored content online and optimise your experience of our Platforms;

• to provide you with tailored advertisements on other websites you visit and social media and digital platforms;

• to share marketing material we believe may be of interest to you, including from other companies within the Serendipity Tailormade Ltd Group and our third party partners;

• to help us operate our services more efficiently;

• to authenticate log-ins on our Platforms and detect and prevent fraud.

Where required under applicable privacy laws:

• we will take steps to ensure that prior to profiling your personal information for a legitimate interest that our legitimate interest is not overridden by your own interests or fundamental rights and freedoms; and

• you may have rights to object to us profiling your personal information. You can learn more about such rights in Legal rights available to help manage your privacy.

Transferring personal information globally

The Serendipity Tailormade Ltd Group is a global business, which means your personal information may be transferred and stored in the United Kingdom and other countries which may be outside your country of residence. Some of these countries are subject to different standards of data protection than your country of residence.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, and we only transfer personal information to another country where:

• we are satisfied that adequate levels of protection are in place to protect your information; and

• the transfers are fully managed to protect your privacy rights and interests and are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

To this end:

• we ensure transfers within the Serendipity Tailormade Ltd Group will be covered by adequate and consistent level of protection wherever it is transferred within the Serendipity Tailormade Ltd Group;

• where we transfer your personal information outside the Serendipity Tailormade Ltd Group or to third parties (who help us to provide our products and services), we obtain contractual commitments from them to protect your personal information; or

• where we receive requests for information from law enforcement or regulators, we carefully review and validate these requests before any personal information is disclosed.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.

You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.

How we protect and store your personal information

Protection of your personal information

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and safeguard the privacy of such information. For example, the measures we take include:

• placing confidentiality requirements on our staff members and service providers;

• destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected; and

• following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and

• using secure communication channels such as SSL ("secure sockets layer") or TLS (“transport layer security”) for transmitting data that is sent to us. SSL and TLS are industry standard encryption protocols used to protect online transaction channels.

As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

Here are some simple steps you can take to ensure your personal information is kept securely:

• Customer log-in details confidential. You should not share your log in details with anyone else. You should also log out when you finish using our Platforms. This is especially important if you are using a publicly accessible computer; and

• be aware of "Phishing", which is where someone tries to represent themselves as someone else to gain information from you - always check whether emails from any sender are actually from them, and if in doubt, go directly to their website and do not click on links in emails, as these may take you to "clone" websites which use your information illegally.

Storage of your personal information

We keep your personal information for as long as is reasonably necessary for the purposes for which it was collected. For example, to manage bookings and provide you with any relevant Serendipity Tailormade Ltd. products or services, as explained in this Privacy Notice. We will ensure that it is disposed of in a secure manner.

In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

If you require further information about how we retain particular information please contact us.

Cookies

A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Platforms and the internet, and helps us provide better Platform services to you and tailor certain content.

Cookies may collect personal information about you. Cookies help us remember information about your visit to our Platforms, like your country, language and other settings and searches. Cookies enable us to understand who has seen which webpages and how frequently, and to determine which are the most popular areas of our Platforms. They can also help us to operate our website more efficiently, and make your next visit easier and customise your view of the Platforms to reflect your preferences and activities. They also help us tailor our marketing and advertisements to you on our Platforms, other websites you visit, social media platforms and your other devices.

For more information on how we use cookies please read our Cookie Policy, where you can also find information so you can delete cookies or block certain types of cookie. You should note that this may have an impact on our ability to provide the Platform services to you.

Legal rights available to help manage your privacy

If you are subject to laws that provide you with such rights, depending on certain exceptions, and in some cases dependent upon the processing activity we are undertaking, you may have certain rights in relation to your personal information:

• To access personal information

• To rectify / erase (‘right to be forgotten’) personal information

• To restrict the processing of your personal information

• To object to the processing (including direct marketing) of personal information

• To transfer your personal information

• To obtain a copy of personal information safeguards used for transfers outside your jurisdiction

• To lodge a complaint with your local supervisory authority

If you wish to access any of the rights set out above, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you. We reserve the right to charge a fee where permitted by law, for example, if your request is manifestly unfounded or excessive.

You can exercise your rights by emailing us mail@serendipity.travel or by sending us a communication at 1a Local Board Road, Watford WD17 2JP. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: the source of your personal information; the purposes, legal basis and methods of processing; the data controller’s identity; and the entities or categories of entities to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:

• it is no longer needed for the purposes for which it was collected; or

• you have withdrawn your consent (where the data processing was based on consent); or

• following a successful right to object (see right to object); or

• it has been processed unlawfully; or

• the personal information must be erased for compliance with a legal obligation under European Union or Member State law to which the relevant Serendipity Tailormade Ltd Group brand is subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:

• for compliance with a legal obligation; or

• for the establishment, exercise or defence of legal claims.

Right to object to the processing (including direct marketing) of your personal information

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

You can request that we stop contacting you for marketing purposes.

You can request that we not transfer your personal information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

If you have joined our mailing list, you can manage your marketing preferences automatically by clicking the "unsubscribe" link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us or changing your account settings which will remove you from the relevant marketing list.

Right to transfer your personal information

You can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller, but in each case only where:

• the processing is based on your consent or on the performance of a contract with you; and

• the processing is carried out by automated means.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or

• the processing is unlawful, but you do not want it erased; or

• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or

• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:

• we have your consent; or

• to establish, exercise or defend legal claims; or

• to protect the rights of another natural or legal person.

Right to lodge a complaint with your local supervisory authority

You have a right to lodge a complaint with your local supervisory authority (i.e. your place of habitual residence, place of work or place of alleged infringement) if you have concerns about how we are processing your personal information.

California Shine the Light Disclosure

If we share your personal information with carefully selected third parties for the third party’s own marketing purposes and you are a California resident, you may contact us once per year to request the name of that third party(ies) and the categories of information shared about you. To do so, please send a request to us as set out below with valid proof of California residency. Please note that it may take up to 30 days to process your request.

How to contact us

The primary point of contact for all issues arising from this Privacy Notice is our Data Protection Officer, who can be contacted at mail@serendipity.travel or by sending us a communication to 1a Local Board Road, Watford, WD17 2JP, United Kingdom.

If you have any questions, concerns or complaints regarding our compliance with this Privacy Notice, we encourage you to first contact our Data Protection Officer. We will investigate and attempt to resolve complaints and disputes as quickly as possible and in any event, within the timescales provided by applicable data protection laws.

Issue date of Privacy Notice: November 2020