This Privacy Notice explains in detail the types of personal data we may collect about you when you interact with us. It also explains how we’ll store and handle that data, and keep it safe.
We know that there’s a lot of information here, but we want you to be fully informed about your rights, and how The Original London Sightseeing Tour Limited ('we', 'us' or 'our') which includes the Bath Bus Company Limited and RATP DEV Global Sightseeing Limited (RDGS) uses your data.
We hope the following sections will answer any questions you have but if not, please do get in touch with us, see section 14 below.
It’s likely that we’ll need to update this Privacy Notice from time to time. We’ll notify you of any significant changes, but you’re welcome to come back and check it whenever you wish.
2. Explaining the legal bases we rely on
The law on data protection sets out a number of different reasons for which a company may collect and process your personal data, including:
In specific situations, we can collect and process your data with your consent.
For example, when you tick a box to receive email newsletters and promotions.
When collecting your personal data, we’ll always make clear to you which data is necessary in connection with a particular service.
In certain circumstances, we need your personal data to comply with our contractual obligations.
For example, if you order tickets from us, we’ll collect your address details to deliver your tickets.
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting us to law enforcement.
In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
For example, we will use your purchase history to send you or make available personalised offers.
We also combine the purchase history of our customers to identify trends and ensure we can keep up with demand or develop new products/services.
3. When do we collect your personal data?
- When you visit any of our websites, buy products and services.
- When you engage with us on social media.
- When you download or install one of our apps (mobile applications).
- When you contact us by any means with queries, complaints etc.
- When you ask us to email you information about a product or service.
- When you enter prize draws or competitions.
- When you book any kind of appointment with us or book to attend an event.
- When you choose to complete any surveys we send you.
- When you comment on or review our products and services.
- When you travel in our vehicles or visit our premises which usually have CCTV systems operated for the security of both passengers and members of the public. These systems may record your image during your visit.
- When you report lost property.
- Any individual may access personal data related to them, including opinions. So if your comment or review includes information about who provided that service, it may be passed on to them if requested.
- When you've given a third party permission to share with us the information they hold about you.
4. What sort of personal data do we collect?
- If you have made a purchase with us: your name, gender/age bracket, billing/delivery address, orders and receipts, email address and telephone number.
- Details of your interactions with us through contact centres, online, or by using one of our apps.
For example, we collect notes from our conversations with you, details of any complaints or comments you make, details of purchases you made, items viewed or added to your basket, vouchers, redemptions, web pages you visit and how and when you contact us.
- Copies of documents you provide to prove your age or identity where the law requires this, (including your passport and driver's licence). This will include details of your full name, address, date of birth and facial image. If you provide a passport, the data will also include your place of birth, gender and nationality.
- Details of your visits to our websites or apps, and which site you came from to ours.
- Personal details which help us to recommend items of interest.
For instance, you might tell us that you have an interest in travelling to one of the cities we operate in, which we will use to guide our suggested products.
We’ll only ask for and use your personal data collected for recommending items of interest. Of course, it’s always your choice whether you share such details with us.
- Payment card information.
- Your comments and reviews.
- To deliver the best possible web experience, we collect technical information about your internet connection and browser, the web pages viewed during your visit, the advertisements you clicked on, and any search terms you entered.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
5. How and why do we use your personal data?
We want to give you the best possible customer experience. One way to achieve that is to get the richest picture we can of who you are by combining the data we have about you.
We then use this to offer you promotions, products and services that are most likely to interest you.
The data privacy law allows this as part of our legitimate interest in understanding our customers and providing the highest levels of service.
Of course, if you wish to change how we use your data, you’ll find details in the ‘What are my rights?’ section below.
Remember, if you choose not to share your personal data with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.
Here’s how we’ll use your personal data and why:
- To process any travel orders that you make by using our websites or apps. If we don’t collect your personal data, we won’t be able to process your order and comply with our legal obligations.
For example, your details may need to be passed to a third party to supply or deliver the product you ordered, and we may keep your details for a reasonable period afterwards in order to fulfill any contractual obligations such as refunds, guarantees and so on.
- To respond to your queries, refund requests and complaints. Handling the information you sent enables us to respond. We may also keep a record of these to inform any future communication with us and to demonstrate how we communicated with you throughout. We do this on the basis of our contractual obligations to you, our legal obligations and our legitimate interests in providing you with the best service and understanding how we can improve our service based on your experience.
- To protect our business and your account from fraud and other illegal activities. This includes using your personal data to maintain, update and safeguard your account. We’ll also monitor your browsing activity with us to quickly identify and resolve any problems and protect the integrity of our websites. We’ll do all of this as part of our legitimate interest.
For example, by using automated monitoring of IP addresses to identify possible fraudulent log-ins from unexpected locations.
- To process payments and to prevent fraudulent transactions. We do this on the basis of our legitimate business interests. This also helps to protect our customers from fraud.
- If we discover any criminal activity or alleged criminal activity through our use of CCTV, fraud monitoring and suspicious transaction monitoring, we will process this data for the purposes of preventing or detecting unlawful acts. We aim is to protect the individuals we interact with from criminal activities.
- With your consent, we will use your personal data, preferences and details of your transactions to keep you informed by email about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.
Of course, you are free to opt out of hearing from us by any of these channels at any time.
- To send you relevant, personalised communications by post in relation to updates, offers, services and products. We’ll do this on the basis of our legitimate business interest.
You are free to opt out of hearing from us by post at any time.
- To send you communications required by law or which are necessary to inform you about our changes to the services we provide you. For example, updates to this Privacy Notice, any changes to the service or product you have purchased and legally required information relating to your transactions. These service messages will not include any promotional content and do not require prior consent when sent by email or text message. If we do not use your personal data for these purposes, we would be unable to comply with our legal obligations.
- To display the most interesting content to you on our websites or apps we will use data about your favorite products and so on. We do so on the basis of your consent to receive app notifications and/or for our website to place cookies or similar technology on your device.
For example, we might display a list of products or services you’ve recently looked at, or offer you recommendations based on your purchase history and any other data you’ve shared with us.
- To administer any of our prize draws or competitions which you enter, based on your consent given at the time of entering.
For example, by combining this data, this will help us personalise your experience and decide which content to share with you.
- To develop, test and improve the systems, services and products we provide to you. We’ll do this on the basis of our legitimate business interests.
For example, we’ll record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having
- To comply with our contractual or legal obligations to share data with law enforcement.
For example, when a court order is submitted to share data with law enforcement agencies or a court of law
- To send you survey and feedback requests to help improve our services. These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
Of course, you are free to opt out of receiving these requests from us at any time.
To build a rich picture of who you are and what you like, and to inform our business decisions, we'll combine data captured from across the group and third parties we'll do this on the basis of our legitimate interest.
To decide which information to show you, with the help of computer algorithms, we do so on the basis of your consent.
For example, if you consent through our apps, we may use your purchasing preferences to offer you tailored products.
6. How we protect your personal data
We know how much data security matters to all our customers. With this in mind we will treat your data with the utmost care and take all appropriate steps to protect it.
We secure access to all transactional areas of our websites and apps (mobile application) using ‘https’ technology.
Access to your personal data is password-protected, and sensitive data (such as payment card information) is secured by SSL/TLS encryption.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security.
7. How long will we keep your personal data?
Whenever we collect or process your personal data, we’ll only keep it for as long as is necessary for the purpose for which it was collected.
At the end of that retention period, your data will either be deleted completely or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis and business planning.
8. Who do we share your personal data with?
We sometimes share your personal data with trusted third parties.
For example, for fraud management or to handle complaints and so on.
Here’s the policy we apply to those organisations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, any of your data held by them will either be deleted or rendered anonymous.
Examples of the kind of third parties we work with are:
- IT companies who support our website and other business systems.
- Re-sellers and agents who sell products and services on our behalf.
- Operational companies such as delivery couriers.
- Direct marketing companies who help us manage our electronic communications with you.
- Google/Facebook to show you products that might interest you while you’re browsing the internet. This is based on either your marketing consent or your acceptance of cookies on our websites. See our Cookies Notice for details.
- Data insight companies to ensure your details are up to date and accurate.
Sharing your data with third parties for their own purposes:
We will only do this in very specific circumstances, for example:
- With your consent, given at the time you supply your personal data, we may pass that data to a third party for their direct marketing purposes.
- For fraud management, we may share information about fraudulent or potentially fraudulent activity in our premises or systems. This may include sharing data about individuals with law enforcement bodies.
- We may also be required to disclose your personal data to the police or other enforcement, regulatory or Government body, in your country of origin or elsewhere, upon a valid request to do so. These requests are assessed on a case-by-case basis and take the privacy of our customers into consideration.
- We may, from time to time, expand, reduce or sell our company or a group company and this may involve the transfer of divisions or the whole business to new owners. If this happens, your personal data will, where relevant, be transferred to the new owner or controlling party, under the terms of this Privacy Notice.
- For further information please contact our Data Protection Officer.
To help personalise your journey through our website we currently use the following companies, who will process your personal data as part of their contract with us:
- Fat Media Ltd
- Your Digital Heroes Ltd t/a Reckless
- Syyco Ltd
- Internet Business Group Ltd t/a Affiliate Future
- Rocket Science Group t/a Mailchimp
- Rackspace Ltd
- Transmach Systems Ltd
- Barclaycard PLC
- PayPal (UK) Ltd
- SurveyMonkey UK Ltd
We may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies and other such software on our website contain information that is transferred to your computer's hard drive. They help us to improve the website and to deliver a better and more personalised service. Find out more about our cookies by following this link.
This includes, but is not limited to:
- Your IP address
- Your operating system
- Your browser type
- The name of your internet service provider
- The date, time and duration of your visit
- The name and URL of pages you access
The purpose of this is for system administration and to report aggregate information to our advertisers. This contains statistical data about our users' browsing actions and patterns, and does not identify any individual.
The website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
10. Where your personal data may be processed
Sometimes we will need to share your personal data with third parties and suppliers outside the European Economic Area (EEA), such as USA.
Protecting your data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway. We may transfer personal data that we collect from you to third-party data processors in countries that are outside the EEA.
For example, this might be required in order to fulfil your order, process your payment details or provide support services.
If we do this, we have procedures in place to ensure your data receives the same protection as if it were being processed inside the EEA. For example, our contracts with third parties stipulate the standards they must follow at all times. If you wish for more information about these contracts please contact our Data Protection Manager.
Any transfer of your personal data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice.
11. What are your rights over your personal data?
An overview of your different rights
You have the right to request:
- Access to the personal data we hold about you, free of charge in most cases.
- The correction of your personal data when incorrect, out of date or incomplete.
- That we stop using your personal data for direct marketing (either through specific channels, or all channels).
- That we stop any consent-based processing of your personal data after you withdraw that consent.
- Review by us of any decision made based solely on automatic processing of your data (i.e. where no human has yet reviewed the outcome and criteria for the decision).
You have the right to request a copy of any information about you that we hold at any time, and also to have that information corrected if it is inaccurate. To ask for your information, please contact, Data Protection Officer or email email@example.com.
To ask for your information to be amended, please contact our Data Protection Officer at firstname.lastname@example.org.
If we choose not to action your request we will explain to you the reasons for our refusal.
Your right to withdraw consent
Whenever you have given us your consent to use your personal data, you have the right to change your mind at any time and withdraw that consent.
Where we rely on our legitimate interest
In cases where we are processing your personal data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal data.
You have the right to stop the use of your personal data for direct marketing activity through all channels, or selected channels. We must always comply with your request.
Checking your identity
To protect the confidentiality of your information, we will ask you to verify your identity before proceeding with any request you make under this Privacy Notice. If you have authorised a third party to submit a request on your behalf, we will ask them to prove they have your permission to act.
12. How can you stop the use of your personal data for direct marketing?
There are several ways you can stop direct marketing communications from us:
- Click the ‘unsubscribe’ link in any email communication that we send you. We will then stop any further emails from that particular division.
- In our apps, you can manage your preferences and opt out from one or all of the different push notifications by selecting or deselecting the relevant options in the ‘Settings’ section.
- Email email@example.com
- Write to Data Protection Officer, The Original Tour, Jews Row, Wandsworth, SW18 1TB.
Please note that you may continue to receive communications for a short period after changing your preferences while our systems are fully updated.
13. Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence. Details can be found in Section 16.
14. Any questions?
We hope this Privacy Notice has been helpful in setting out the way we handle your personal data and your rights to control it.
If you have any questions that haven’t been covered, please contact our Data Protection Officer who will be pleased to help you:
- Email us at firstname.lastname@example.org
- Or write to us at Data Protection Officer, The Original Tour, Jews Row, Wandsworth, SW18 1TB
This notice was last updated on 23 May 2018