ATLAS TRAVEL SOLUTIONS LIMITED

PRIVACY NOTICE

Introduction

Welcome to the Atlas Travel Solutions Limited privacy notice.

Atlas Travel Solutions (“ATS”) respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone) and tell you about your privacy rights and how the law protects you.

This privacy notice is provided in a layered format so that you can easily click through to the specific areas set out below. Alternatively you can download a pdf version of the policy here .

Please also use refer to the Glossary that we have set out at the end of the Policy if there is any terminology used in this privacy notice that you are unfamiliar with or that you don’t fully understand.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW YOUR PERSONAL DATA IS COLLECTED
• HOW WE USE YOUR PERSONAL DATA
• HOW WE DISCLOSE YOUR PERSONAL DATA
• WHEN WE TRANSER YOUR DATA OVERSEAS
• HOW WE SECURE YOUR DATA
• HOW LONG WE RETAIN YOUR DATA FOR
• YOUR LEGAL RIGHTS
• GLOSSARY

Purpose of this privacy notice

This privacy notice aims to give you information on how ATS collects and processes your personal data, including any data you may provide when you purchase travel services via one of our partner tour operators or travel agencies and any data in respect of individuals who we deal with at the tour operators or travel agencies.

This website is not intended for children and the only circumstances in which we collect data relating to children, is where you make a booking of travel services and you have children in your party.

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

Controller

ATS is a destination management company and receptive/ground handler inbound only, with dedicated offices for its specific destinations (United Kingdom, Ireland and USA).

ATS is made up of the following different legal entities:

• Atlas Travel solutions Limited (Registration number 06643762) with registered office at 416 Green Lane, Ilford, Essex, IG3 9JX and head office based in London at the following address: Atlas Travel Solutions Ltd, 25-27 Horsell Road, London N5 1XL, England, UK.

• Atlas Travel Solutions Scotland (Registration number 481878) is based in Edinburgh at the following address: Atlas Travel Solutions Scotland, 6a Mill Lane, Edinburgh EH6 6TJ, Scotland, UK

• Atlas Travel Solutions Ireland (Registration number 581469) is based in Dublin at the following address: Atlas Travel Solutions Ireland, 15 Harcourt Street, Dublin D02 XY47, Ireland.

• Atlas Travel Solutions USA is based in Florida (Registration number ST 39199) at the following address:

• Atlas Travel Solutions USA, 3939 Hollywood Blvd, Hollywood Florida, FL 33021, USA

This privacy notice is issued on behalf of Atlas Travel Solutions Limited so when we mention "ATS", "we", "us" or "our" in this privacy notice, we are referring to that company. ATS is the controller and responsible for your personal data.

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

Contact details

Our full details are:

Full name of legal entity: Atlas Travel Solutions Limited

Name or title of data privacy manager: Miss Valentina Pinna

Email address: valentina@atlastravelsolutions.com

Postal address: 25-26 Horsell Road, London N5 1XL

Telephone number: +44(0)20 72587730

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 (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 notice and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 13/06/2018 and 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 any of the details you provide to us should change, during the course of 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 notice 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

This includes data relating specifically to your identity, such as your first name, maiden name, last name, passport details, ID number, marital status, title, date of birth and gender.

Contact Data

This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.

Financial Data

This include data relating to your means and methods of payment, such as your bank account and payment card details.

Transaction Data

This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

Membership Data

This includes the membership number(s) allocated to you by third party suppliers or associations (for example, hotel chains).

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 will treat the combined data as personal data which will be used in accordance with this privacy notice.

Special Categories of Personal Data

We do not request special categories of personal data about you and we will only receive this when your tour operator or travel agent sends it to us. The special categories of personal data about you which we may be sent are:

Details about your:

• dietary requirements which may disclose your religious or philosophical beliefs

• health

• race or ethnicity (from copy passports)

• religious beliefs

We collect and process the above data only where it is strictly necessary to do so in order to deliver the travel service that you have purchased. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so via your tour operator or travel agent.

You are not under any obligation to consent to us processing your sensitive personal data. However, if the sensitive personal data is required in order to proceed with your booking then, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you have booked or are attempting to book. As a result, if you do not provide your consent, we will be unable to proceed with your booking and we will notify your tour operator or travel agent accordingly.

If you are happy to consent to the use of your sensitive personal data, you will also be able to withdraw your consent at any time either by contacting us directly or via your tour operator or travel agent. However, as this will prevent us from arranging the provision of the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and will inform the tour operator or travel agent via whom you have booked, in which case the cancellation terms of the relevant tour operator or travel agent will become applicable.

If you fail to provide personal data

Where we need to collect personal data by law and you fail to provide that data when requested, we may not be able to perform the contract we have.

In other words, where we require details from you in order to arrange for the provision of your chosen travel services, if you do not provide us with the necessary details via your tour operator or travel agent then we will not be able to arrange for the provision of the services you have booked.

In this case, depending upon when you fail to provide the necessary data, we may not be able to arrange for the provision of your booking and we may be required to cancel your booking, in which case we will notify your tour operator or travel agent accordingly.

How your personal data is collected

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 corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

make a booking of travel services for your clients;

create an account on our website;

subscribe to our newsletter or other publications;

request marketing to be sent to you;

enter a competition, promotion or survey;

give us some feedback.

Third parties

We may receive personal data about you from various third parties as set out below:

Identity and Contact Data, dietary requirements which may disclose your religious or philosophical beliefs and health information from the tour operator, travel agent or other third party whom you have entered into a contract with for the provision of the travel services.

Technical Data from analytics providers such as Google based outside the EU.

Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Barclay, Barclay Card and Western Union based inside and outside the EU.

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.

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 or regulatory obligation.

When we have entered into a contract with a tour operator, travel agent or other third party with whom you have booked travel services where we are required to carry out some or all of those travel services.

Generally, we do not rely on consent as a legal basis for processing your personal data except where we have to process special categories of personal data.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us if you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

Monitoring communications

We may monitor, record, store and use any email or other communication with you in order to check any instructions given to us, for training purposes, for crime prevention and to improve the quality of our customer service.

Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our COOKIE POLICY.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

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.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

(1.a.i.A)Internal Third Parties as set out in the Glossary.

(1.a.i.B)External Third Parties as set out in the Glossary.

(1.a.i.C)Specific third parties, such as all suppliers involved in the process of booking the services you required.

(1.a.i.D)Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers

We share your personal data within the ATS Group for the purposes of performing the services which you have booked. All of the companies within the ATS Group also use the same systems and therefore may be able to access your information (subject always to each group company’s data protection obligations). The ATS Group has companies based in the UK, the Republic of Ireland and the USA and this will therefore involve transferring your data outside the European Economic Area (EEA).

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the EEA, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the EEA in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the EEA, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA ( as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the EEA, controls on data protection may not be as wide as the legal requirements within the EEA.

For all other transfers of data, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit

access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

No fee usually required

You will not 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 is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these 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 your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Glossary

LAWFUL BASIS

Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us

Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to

THIRD PARTIES

Internal Third Parties

Other companies in the ATS Group based in UK, Europe and USA acting as joint controller or processor, such as

GCA, Global Congress Accomodations (FHT Direct and SPARGO inc)

External Third Parties

Suppliers of travel services acting as processors based in UK, Europe and USA, who provide the travel services that make up any booking of travel services that you make via us or which your travel agent or tour operator books on your behalf.

Service providers acting as processors based in UK, Europe and USA, which provide IT and system administration services and undertake leadership reporting, such as:

- Forge Dynamic Ltd, Monohaus 143 Mare Street, London E8 3FW

- Resolved IT, Momentium Ltd, 31 Lower London Road, Edinburgh EH7 5TE

- Tourplan UK Ltd, 13 Swan Yard, London N1 1SD

- Wintravel, OBJ Media Viale Gorzia 20, 00198 Roma

and as partner Production and Marketing Company.

- KIDU Creative Creators srl, Via Italia 46, 20900 - Monza (MB)

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK, Europe, and USA who provide consultancy, banking, legal, insurance and accounting services such as:

- Prime Numbers, Exchange Place 2, Semple Street, Edinburgh, EH3 8LL

- Comerford Foley, Unit 502 Riverstown 5 Complex, Riverstown Business Park,

Tramore Waterford, Ireland

ABACUS & Co,416 Green Lane, Ilford IG3 9JX

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK, Europe, and USA, who require reporting of processing activities in certain circumstances.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in UK, Europe, and USA who provide consultancy, banking, legal, insurance and accounting services.

HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK, Europe, and USA, who require reporting of processing activities in certain circumstances.

YOUR LEGAL RIGHTS

You have the right to:

Request access

to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction

of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure

of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing

of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing

of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

if you want us to establish the data's accuracy;

where our use of the data is unlawful, but you do not want us to erase it;

where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer

of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time

where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.