Your privacy is important to us

This statement explains how we collect, use, transfer and store your personal data. We would encourage you to read this information. This statement is applicable to those resident in the UK and Northern Ireland. Please continue for information relating to those resident in the Republic of Ireland.

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IMPORTANT INFORMATION AND WHO WE ARE

About this privacy notice

This privacynotice explains how BordessaHolidays collects and processesyour personal information. We would encourage you to read this information.

It is important that you read this privacy notice together with anyother privacy notice or fair processing notice we may provide on specificoccasions when we are collecting or processing personal data about you so thatyou are fully aware of how and why we are using your data. This privacy noticesupplements the other notices and is not intended to override them.

Who’s responsible for your personal information?

We refer to Bordessa Holidays in this statement. Bordessa Holidays is a trading name of Bordessa Holidays. Bordessa Holidays is responsible for this website and is the‘data controller’ for your data (collectively referred to as “Bordessa Holidays”,“we”, “us” or “our” in this privacy notice).

How can you contact us?

We have appointed a data protection manager to overseecompliance with this privacynotice. If you have any questions about this privacy notice or how we handleyour personal information, please contact the Data Protection Manager at or bywriting to: Data Protection Manager, 2, Old Stables, Carmarthen, SA31 1BX

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You can also contactus using the contactdetails on our website. If you are resident in the Republic of Ireland, please contactThe Data Protection Commission at www.dataprotection.ie

If you do not think that we have processed your data in accordance with this noticeyou should let us know assoon as possible. You have the right to make acomplaint at any time to the Information Commissioner's Office (ICO),the UK supervisory authority for data protection issues. We would, however,appreciate the chance to deal with your concerns before you approach the ICO soplease contact us in the first instance.

Changes to the privacynotice and your duty to inform us of changes

We may changethis privacy noticefrom time to time. You should check this notice occasionally to ensure you are aware of the most recentversion.

It is important that the personalinformation we hold about you is accurateand current. Please keep us informedif your personalinformation changes duringyour relationship with us.

Links to other websites

This websitemay include links to third-party websites, plug-ins and applications. Clicking on those links or enabling thoseconnections may allow third parties to collect or share data about you. Whenyou leave our website, we encourage you to read the privacy notice of everywebsite you visit as we do not control those.

THE KIND OF INFORMATION WE COLLECT ABOUT YOU

Personal data, or personal information, means anyinformation about an individual from which that personcan be identified. It does not includedata where the identity has beenremoved (anonymous data).

We may collect,use, store and transfer different kinds of personaldata about you (andabout any other person you include on yourbooking) which we have grouped together as follows:

Identity Data includes your name, title, date of birth,gender and passportdetails.

Contact Data includes your address,email address and telephone numbers.

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Sensitive Data includes information concerning medical conditions, disabilities, religious or philosophical beliefs and criminal convictions andoffences.

Financial Data includes bank account and payment card details.

Transaction Data includes details aboutpayments to and from you and otherdetails of products andservices you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browsertype and version, time zone setting and location, browser plug-in types andversions, operating system and platform and other technology on the devicesyou use to accessthis website.

Profile Data includes your username and password, purchasesor orders made by you, your interests, preferences,feedback, survey and promotional responses.

Usage Data includes information abouthow you use our website,products and services. Marketing and Communications Data includes your preferences inreceiving marketing from us and ourthird parties and your communication preferences.

We also collect, use and share AggregatedData such as statistical or demographic data for any purpose.Aggregated Data may be derivedfrom your personaldata but is not considered personal data in law asthis data does not directly or indirectly reveal your identity. For example, wemay aggregate your Usage Data to calculate the percentage of users accessing aspecific website feature. However, if we combine or connect Aggregated Datawith your personal data so that it can directly or indirectly identify you, wetreat the combined data as personal data which will be used in accordance withthis privacy notice.

Apart from theSensitive Data referred to above, we do not collect any other Special Categories of Personal Data aboutyou (this also includes detailsabout your race,sex life, sexual orientation, political opinions, trade union membership and information about your genetic and biometric data).

Information about other people

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You are responsible for ensuring that the other members of your travel party are awareof the content of this Privacy Policy and are in agreement with you supplyingtheir personal data to us to make a booking or other purchase on their behalf.

If you fail to providepersonal data

Where we need to collect personaldata by law, orunder the terms of a contract we havewith you and you fail to provide that data when requested, we may not be ableto perform the contract we have orare trying to enter into with you (for example, to provide you with ourproducts and services). We will notify you if this is the case at the time.

HOW YOUR PERSONAL INFORMATION IS COLLECTED

We use different methodsto collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Financial, Sensitive andTransaction Data by filling in forms or by corresponding with us online or by post, phone, email or otherwise. This includespersonal data you provide when you:

apply to purchaseour products and services;enquire about our goods and services; subscribe to our services orpublications; request marketing to be sent to you;

enquireabout our community involvement; enter a competition, promotion or survey;or give us some feedback.

Automated technologies orinteractions. As you interact with our website, wemay automatically collect Profileand Usage Data. We will also collectTechnical Data about your equipment, browsing actionsand patterns. We collect this personal data by using cookies, server logs and othersimilar technologies. Please see our cookie policy for further details.

Third partiesor publicly available sources. We may receive personaldata about you from various third parties and publicsources as set out below:

Identity, Contactand Sensitive Data from schoolsor other organisations making a partybooking on your behalf and carers or other healthcare providers in relation toyour

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booking. Contact,Financial and Transaction Data from providersof technical, payment and delivery services. Identityand Contact Data from data brokers or aggregators.

Identity and Contact Data from publiclyavailable sources such as social media.Technical Data from the following parties:

analyticsproviders; advertising networks; and search information providers.

HOW WE USE YOUR PERSONAL INFORMATION

It’simportant that you understand what we’ll do with the data that we hold aboutyou. We will only use your personal data when the law allowsus to. Most commonly, we willuse your personal data in the following circumstances:

Where we need to performthe contract we are about to enter into or have enteredinto with you.

Where it is necessary for our legitimate interests (or those of a third party) and yourinterests and fundamental rights do not override those interests.

Where we need to complywith a legal or regulatory obligation.

Generally,we do not rely on consent as a legal basis for processing your personal dataother than in relation to the collection and use of Sensitive Data and sendingthird party direct marketing communications to you via email or text message.You have the right to withdraw consent to marketing at anytime by contacting us.

Marketing

We strive to provide you with choicesregarding certain personaldata uses, particularly around marketing andadvertising.

Promotional offersfrom us

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

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You will receive marketingcommunications from us if you have requested information from us or purchased goods orservices from us or if you provided us with your details when you entered acompetition or registered for a promotion.

Third-party marketing

We will get your expressopt-in consent beforewe share your personal data with any internal or external third partiesfor marketing purposes.

Opting out

We won’t use your personal data for marketing purposes at all ifyou’ve told us not to. You can ask                         us or third partiesto stop sendingyou marketing messagesat any time by following the opt-out links on any marketing messagesent to you or by contacting us.

Cookies

You can set your browser to refuse all or some browser cookies, orto alert you when websites set or access cookies.If you disable or refusecookies, please note that someparts of this website may become inaccessible or not function properly. Formore information about the cookies we use, please see our cookie policy.

Change of purpose

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

If we need to use your personal data for an unrelated purpose,we will notifyyou and we will explain the legal basis which allows us to do so.

Pleasenote that we may process your personal data without your knowledge or consent, in compliancewith the above rules, wherethis is required or permitted by law.

SHARING YOUR PERSONALINFORMATION

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

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External third parties includingthe following:

·    Travel companies, airlines, hotels,insurers and other organisations involvedin performing your contract.

·    Industry regulatory bodiessuch as the Civil AviationAuthority and ABTA.

·    Government bodies or otherorganisations in the UK and in other countries, such as those responsible for immigration, bordercontrol, security and anti-terrorism.

·    Organisations that provide foreignexchange services in respect of travel money sales.

·    Organisations to which we may outsource certain of our activities, such asprinting, mailing and distribution services.

·     Organisations that provide customeridentity and addressverification services.

·     Organisations doing research for us.

·    Organisations for the detection, investigation and prevention of crime, such asthe National crime Agency in respect of money laundering.

·    Financial organisations for purposessuch as paymentprocessing, finance plans and refunds.

·    Third parties to whom we may chooseto sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businessesor merge with them. If a changehappens to our business, then the new ownersmay use your personal data in the same way as set out in this privacy notice.

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

We require all third partiesto respect the security of your personaldata and to treatit in accordance with the law.We do not allow our third-party service providers to use your personal data fortheir own purposes and only permit them to process your personal data forspecified purposes and in accordance with our instructions.

International transfers

It may be necessary to pass your booking detailsto third parties,such as airlines, hotels and transfer providers, situated outside of the EuropeanEconomic Area (EEA) in order

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to perform our contract with you. Wheneverwe do so, we will try to make sure that your personal information is adequatelyprotected.

KEEPING YOUR INFORMATION SECURE

Wehave put in place appropriate security measures to prevent your personal datafrom being accidentally lost, used or accessed in an unauthorised way, alteredor disclosed. For example, all information you provide to us is stored on oursecure servers which means that your information can’t be read by anyone whodoesn’t need to see it. Any payment transactions will be encrypted using SSLtechnology. When you get in touch with us, we’ll ask you a couple of securityquestions before we share any personal details just to check it’s you. Inaddition, we limit access to your personal data to those colleagues, 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 subjectto a duty of confidentiality.

Where we have given you (or where you have chosen) a password whichenables you to access certain parts of our site, youare responsible for keeping that password confidential. We ask you not to sharea password with anyone.

We stronglyrecommend that you do not disclose your Invisible TravelAgent account log in details to anyone. Please alwaysremember to logout of your account when you have finished using our website.

We have also put in placeprocedures to deal with any suspected personaldata breach and will notifyyou and any applicable regulator of a breach where we are legally required todo so.

DATA RETENTION

How long will you use my personaldata for?

We will only retain your personal data for as long as necessary tofulfil the purposes we collected it for, including for the purposesof satisfying any legal, accounting, or reporting requirements.

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Todetermine the appropriate retention period for personal data, we consider theamount, nature, and sensitivity of the personal data, the potential risk ofharm from unauthorised use or disclosure of your personal data, the purposesfor which we process your personaldata and whetherwe can achieve those purposesthrough other means, and theapplicable legal requirements.

Details of retention periodsfor different aspectsof your personaldata are availablein our retention policy which you can request from us by contacting us.

YOUR RIGHTS

Under certaincircumstances, by law you have the right to:

Request access to your personal information (commonly known as a "data subjectaccess request"). This enables you to receivea copy of the personalinformation we hold about you and to check that we arelawfully processing it.

Request correction ofthe personal information that we hold about you. This enables you to have any incomplete orinaccurate information we hold about you corrected.

Request erasure of your personal information. This enables you to ask us to deleteor remove personal information 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 information where you have exercised your right to object to processing (seebelow).

Object to processing of your personal information where we are relying on a legitimateinterest (or those of a third party) and there is something about yourparticular situation which makes you want to object to processing on thisground. You also have the right to object where we are processing your personal information for direct marketingpurposes. Request the restrictionof processing of your personalinformation. This enables you toask us to suspend the processing of personal information about you, for exampleif you want us to establish its accuracy or the reason for processing it.

Request the transfer of your personal information to another party.

Ifyou want to review, verify, correct or request erasure of your personalinformation, object to the processing of your personaldata, or requestthat we transfera copy of your personalinformation to another party, please contact the Data Protection Manager.

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No fee usually required

Youwill not have to pay a fee to access your personal information (or to exerciseany 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

Wemay need to request specific information from you to help us confirm youridentity and ensure your right to access the information (or to exerciseany of your other rights). This is another appropriatesecurity measure to ensure that personal information is not disclosed to anyperson who has no right to receive it.

Time limit to respond

We try to respondto all legitimate requests withinone month. Occasionally it may take us longer than a month if yourrequest is particularly complex or you have made a number of requests. In thiscase, we will notify you and keep you updated.

Complaints to the regulator

Ifyou do not think that we have processed your data in accordance with thisnotice you have the right to make a complaintat any time to the Information Commissioner's Office (ICO), the UKsupervisory authority for data protection issues. You can contact them by going to their website at ico.org.uk,phoning them on 0303 123 1113 or by post to: Information Commissioner’s Office,Wycliffe House, Water Lane, Wilmslow, SK9 5AF. Or in the Republic of Irelandplease refer to The Data Protection Commission at www.dataprotection.ie

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Privacy Policy

Your privacyis important to us. This statement is applicable to those residentin the Republic of Ireland.

This statement explains how we collect, use, transfer and store your personal data whenyou visit our website. We would encourage you to read this information.

Table of contents

1.   Important information and who we are

2.   The kind of information we collect about you

3.   How your personalinformation is collected

4.   How we use your personalinformation

5.   Sharing your personalinformation

6.   Keeping your information secure

7.   Data retention

8.   Your rights

9.   Cookie Policy

1.  Important information and who we areAbout this privacy notice

This privacy noticeaims to give you information on how Bordessa Holidays collects and processesyour personal information through your use of this website including when youenquire about the goods and services offered by Sports Entertainment Tours, sign up to a newsletter or take part in a competition.

This websiteis not intended for childrenand we do not knowinglycollect information relatingto children.

It is important that you read this privacy noticetogether with any otherprivacy notice or fair processing notice we may provideon specific occasions when we are collecting or processing personal informationabout you so that you are fully aware of how and why we are using your information. This privacy noticesupplements the other notices and isnot intended to override them.

Who’s responsible for your personalinformation?

We refer to BordessaHolidays in this statement. This means Bordessa Holidays and its subsidiaries and any brandsit owns. Bordessa Holidays isresponsible for this website and is the ‘data controller’ for your data.

How can you contactus?

We have appointeda data protection manager to oversee compliance with this privacy notice. Ifyou have any questions about this privacy notice or how we handle your personalinformation, please contact our Data Protection Manager at sales@bordessaholidays.com, bytelephone on 01267 468188 or by writing to: Data Protection Manager, BordessaHolidays. 2, Old Stables, CarmarthenSA31 1BX.

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If you do not think that we have processed your data in accordance with this noticeyou should let us know as soon as possible.

Changes to the privacynotice and your duty to inform us of changes

We may change this privacy noticefrom time to time. You should check this notice occasionally to ensure you areaware of the most recent version.

It is important that the personalinformation we hold about you is accurateand current. Please keep us informedif your personalinformation changes duringyour relationship with us.

Links to otherwebsites

This websitemay include links to third-party websites, plug-ins and applications. Clicking on those links or enabling thoseconnections may allow other parts of Bordessa Holidays and third parties tocollect or share data about you. When you leave our website, we encourage youto read the privacy notice of every website you visit, particularly third partywebsites as we do not control those.

2.  The kind of information we hold about you

Personal data, or personal information, means any information aboutan individual from which that person can be identified. It does not include data where the identity has beenremoved (anonymous data).

We may collect, use, store and transfer differentkinds of personaldata about you whichwe have grouped together as follows:

Identity Data includes first name, last name, usernameor similar identifier, marital status, title, date of birth, country of birth andgender.

Contact Data includes address,email address and telephone numbers. Transaction Data includes detailsabout payments to and from you

Technical Data includes internetprotocol (IP) address,browser type and version, time zone setting and location, browserplug-in types and versions, operating system and platform and other technologyon the devices you use to access this website.

Usage Data includesinformation about how you use our website.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third partiesand your communication preferences.

Apart fromthe Sensitive Data referred to above, we do not collect any other SpecialCategories of Personal Data about you (this also includes details about yourrace, sex life, sexual orientation, political opinions, trade union membership and information about your genetic and biometric data)

Information about other people

You are responsible for ensuring that the other members of your travelparty are aware of the content of this PrivacyPolicy and are in agreement with your supplying their personal data to us tomake a booking or other purchase on their behalf.

If you fail to providepersonal data

Where we need to collect personaldata by law, orunder the termsof a contract we have with you and you fail to providethat data when requested, we may not be able to perform the contractwe have or are trying to enterinto with you. We will notifyyou if this is the case at the time.

3.  How your personalinformation is collected

We use differentmethods to collectdata from and about you including through:

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Direct interactions. You may give us your Identity, Contactand Financial Data by filling in forms or by corresponding with us bypost, phone, email or otherwise.

This includes personaldata you providewhen you:

apply to purchase our products and services whethervia our sales agents or directthrough our website;

enquireabout our goods and services create an account on our website; subscribe to our serviceor publications; requestmarketing to be sent to you;

enter a competition, promotionor survey; or give us some feedback.

Automatedtechnologies or interactions. As you interact with our website, we mayautomatically collect Technical Data about your equipment, browsing actions andpatterns. We collect this personaldata by using cookies, serverlogs and other similartechnologies. Please see our cookie policy for further details.

Third partiesor publicly available sources. We may receive personaldata about you from various third parties and publicsources as set out below:

Technical Data from the followingparties:

(a)  analytics providers;

(b)  advertising networks;and

(c)  search information providers.

Contact, Financialand Transaction Data from providers of technical, paymentand delivery services.

Identity and ContactData from data brokers or aggregators.

Identity and ContactData from publiclyavailably sources such as the Electoral Register.

4.   How we use your personal information

We will only use your personaldata when the law allowsus to. Most commonly, we willuse your personal data in the following circumstances:

Where we need to perform the contract we are about toenter into or have enteredinto with you.

Where it is necessary for our legitimate interests (or those of a third party)and your interests andfundamental rights do not override those interests.

Where we need to complywith a legal or regulatory obligation.

Generally wedo not rely on consent as a legal basis for processing your personal data otherthan in relation to sending third party direct marketing communications to youvia email or text message. You have the right to withdraw consentto marketing at any time by contacting us.

Purposes for which we will use your personalinformation

We have set outbelow, a description of all the ways we plan to use your personal data, andwhich of the legal bases we rely on to do so. We have also identified what ourlegitimate interests are where appropriate. Note that we may processyour personal data for more than one lawful grounddepending on the specific purpose for which we are using your data.

Purpose/Activity - To manage our relationship with you which includes:

(a)  Notifying you about changesto our terms or privacypolicy

(b)  Asking you to leave areview or take a survey

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Type of dataused:

(a)  Identity

(b)  Contact

(c) Profile

(d)  Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

(a) Performance of a contract with you

(b)  Necessary to comply with a legal obligation

(c)  Necessary for our legitimate interests (to keep our recordsupdated and to study how members/customers use ourproducts/services)

Purpose/Activity - To enable you to take part in a prize draw, competition or to complete a survey

Type of Dataused:

(a) Identity

(b)  Contact

(c)  Profile

(d)  Marketing and Communications

(e)  Usage

Lawful basis for processing including basis of legitimate interest:

(a)  Performance of a contractwith you

(b)  Necessary for our legitimate interests (to study how members/customers use ourproducts/services, to develop them and grow our business)

Purpose/Activity - To administer and protect our business and this website(including monitoring and recording communications, troubleshooting,data analysis, testing, system maintenance, support, reporting and hosting ofdata)

Type of Data used:

(a) Identity

(b)  Contact

(c)  Technical

Lawful basisfor processing includingbasis of legitimate interest:

(a)  Necessary for our legitimate interests (for runningour business, qualityassurance, training, provision of administration and IT services, network security, to prevent fraud and in the context of a businessreorganisation or group restructuring exercise)

(b)  Necessary to comply with a legal obligation

Purpose/Activity - To deliverrelevant website contentand advertisements to you and measure or understand theeffectiveness of the advertising we serve to you Type of Data used:

(a) Identity

(b)  Contact

(c)  Profile

(d)  Usage

(e)  Marketing and Communications

(f)  Technical

Lawful basisfor processing including basis of legitimate interest: Necessary for ourlegitimate interests (to study how members/customers use our products/services, to develop them, to grow our business and to inform ourmarketing strategy)

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Purpose/Activity - To use data analytics to improve our website, products/services, marketing,member/customer relationships and experiences

Type of Dataused:

(a)  Technical

(b)  Usage

Lawful basis for processing including basis of legitimate interest:Necessary for our legitimate interests (to define types of members/customersfor our products and services, to keep our websiteupdated and relevant,to develop our business and toinform our marketing strategy)

Purpose/Activity - To make suggestions and recommendations to you aboutgoods or services that may beof interest to you

Type of Dataused:

(a)  Identity

(b) Contact

(c)  Technical

(d)  Usage

(e)  Profile

(f)  Marketing and Communications

Lawful basis for processing including basis of legitimate interest:

Necessary for our legitimate interests (to developour products/services and grow our business)

Marketing - We strive to provideyou with choicesregarding certain personal data uses,particularly around marketing and advertising.

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

You will receivemarketing communications from us if youhave requested information from us or purchased goods or servicesfrom us or if you provided us with your detailswhen you entered a competition or registered for a promotion.

We won’t use yourpersonal data for marketing purposes at all if you’ve told us not to and we’ll give you the opportunity to opt-out of receiving marketinginformation whenever wecontact you directly for that purpose.

Third-partymarketing - We will get your express opt-in consent before we share yourpersonal data with any external companyoutside The Sports and Leisure Travel Ltd.Ltd Group for marketing purposes.

Opting out - You can ask us or third partiesto stop sending you marketingmessages at any time byfollowing the opt-out links on any marketing message sent to you or bycontacting us at any time.

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

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If we need to use your personal data for an unrelated purpose,we will notify you and we will explain the legal basis whichallows us to do so.

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

5.   Sharing your personal information

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

Internal Third Parties such as otherlegal entities in TheSports and Leisure Travel Ltd. Group who provide administrativeservices and undertake management reporting.

External Third Partiesincluding the following:

Organisations that provide outsourcedprinting, mailing and distribution services Organisations to which we may outsourcecertain other activities, such as database cleansing.

Electoral Reform Servicesin connection with our Board member elections.

Third partiesto whom we may chooseto sell, transfer,or merge parts of our business or our assets. Alternatively, we may seekto acquire other businesses or merge with them. If a change happens to ourbusiness, then the new owners may use your personal data in the same way as setout in this privacy notice.

Professionaladvisers acting as processors or joint controllers including lawyers, bankers, auditorsand insurers who provide consultancy, banking, legal, insurance and accounting services.

We requireall third partiesto respect the security of your personaldata and to treat it inaccordance with the law. We do not allow our third-party service providers touse your personal data for their own purposes and only permit them to processyour personal data for specified purposes and in accordance with ourinstructions.

International transfers

It may be necessaryto pass your booking detailsto third parties,such as airlines, hotels andtransfer providers, situated outside of the European Economic Area (EEA) inorder to perform our contract with you. Whenever we do so, we will try to makesure that your personal information is adequately protected.

6.  Keeping your information secure

We have put in place appropriate security measures to preventyour personal data frombeing accidentally lost, used or accessed in an unauthorised way, altered ordisclosed. In addition, we limit access to your personal data to thosecolleagues, agents, contractors and other third parties who have a businessneed to know. They will only process your personal data on our instructions andthey are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personaldata breach and will notify you and any applicable regulator of a breachwhere we are legally requiredto do so.

7.  Data retention - How long will you use my personal data for?

We will only retain your personal datafor as long as necessary to fulfil the purposes we collected it for, including for the purposesof satisfying any legal,accounting, or reporting requirements.

To determine theappropriate retention period for personal data, we consider the amount, nature,and sensitivity of the personaldata, the potentialrisk of harm fromunauthorised use or disclosure of your personal data, the purposes for which we

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process your personal data and whetherwe can achieve those purposesthrough other means, and theapplicable legal requirements.

Details of retention periodsfor different aspectsof your personal data are available in our retention policy which you canrequest from us by contacting us.

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

In some circumstances we may anonymise your personal data (sothat it can no longer be associated with you) forresearch or statistical purposes in which case we may use this informationindefinitely without further notice to you.

8.   Your rights- Your duty to informus of changes

It is important that the personalinformation we hold about you is accurateand current. Please keep usinformed if your personal information changes.

Your rights in connection with personal information - Under certain circumstances, by law you have the right to:

Requestaccess to your personal information (commonly known as a "data subjectaccess request"). This enables you to receivea copy of the personalinformation we hold about you and to check that we arelawfully processing it.

Request correction of the personalinformation that we hold about you. This enables you to have any incomplete or inaccurateinformation we hold about you corrected.

Requesterasure of your personal information. This enables you to ask us to delete orremove personal information where there is no good reason for uscontinuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing(see below).

Object toprocessing of your personal information where we are relying on a legitimateinterest (or those of a third party) and there is something about yourparticular situation which makes you want to object to processing on thisground. You also have the right to object where we are processing your personal information for direct marketingpurposes. Request the restriction of processing of your personalinformation. This enables you to ask us to suspend the processing of personalinformation about you, for example if you want us to establish its accuracy orthe reason for processing it.

Request the transferof your personal information to another party.

If you want toreview, verify, correct or request erasure of your personal information, object to the processing of your personaldata, or requestthat we transfera copy of your personalinformation to another party, please contact the Society’s Data Protection Manager.

No fee usually required

You will not haveto pay a fee to access your personal information (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 specificinformation from you tohelp us confirm your identity and ensure your right to access the information(or to exercise any of your other rights). This is another appropriate securitymeasure to ensure that personal information is not disclosed to any person whohas no right to receive it.

Time limit torespond - 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 complexor

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you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints tothe regulator - If you do not think that we have processed your data inaccordance with this notice you have the right to make a complaint at any timeto the Commission for AviationRegulation, the Irish supervisory authorityfor data protection issues.You can contact them by going to their website at https://www.aviationreg.ie/, phoning them on (01)661 1700 or by post to: Commission for Aviation Regulation, 3 EarlsfortTerrace, Saint Kevin's, Dublin.

9. Cookie Policy- Our Use of Cookies

Our Site mayplace and access certain first party Cookies on your computer or device. Firstparty Cookies are those placed directly by Us and are used only by Us. We useCookies to facilitate and improve your experience of Our Site and to provideand improve Our productsand services. We have carefully chosenthese Cookies and havetaken steps to ensure that your privacyand personal data is protected and respected at all times.

All Cookiesused by and on Our Site are used in accordance with current CookieLaw.

Before Cookiesare placed on your computer or device, you will be shown a pop-up requestingyour consent to set those Cookies. By giving your consent to the placing ofCookies you are enabling Us to providethe best possibleexperience and service to you.You may, if you wish, deny consent to the placing of Cookies; however certainfeatures of Our Site may not function fully or as intended.

We use both sessioncookies and persistent cookies on Our Website. Sessioncookies exist only for the length of time that you visit our site andare deleted once you close your browser. Persistent cookies remain stored on your browser readyfor use the nexttime you visit our website. Like most sites, We use a combination of both.Certain features of Our Site depend on Cookies to function.

When using our Site, the following Cookies may be placed on your computer or device:

·        PHPSESSID - stores information about customer's selections in the booking journey

·        rvhbxs - storesinformation about the recently visitedhotel pages

·        _ga, _gat, _gid - GoogleAnalytics Software used to analyseand track

·        Our Site uses analytics servicesprovided by Google Analytics. Website analytics refers to a set of tools usedto collect and analyse anonymous usage information, enabling Us to betterunderstand how Our Site is used. This, in turn, enables Us to improveOur Site and the servicesoffered through it. You do nothave to allow Us to use these Cookies, however whilst Our use of them does notpose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.

In addition to the controls that We provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wishto disable all cookies or onlythird party cookies.By default, most internet browsers accept Cookies but this can bechanged. For further details, please consult the help menu in your internetbrowser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enablesy ou to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating systemup-to-date and that you consult the help and guidance provided by thedeveloper of your internet browser and manufacturer of your computer or deviceif you are unsure about adjusting your privacy settings.

Changes to this PrivacyPolicy - We reserve the right to update or alter this PrivacyPolicy from time to time.

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