This policy provides information about how we use and share personal data relating to our business contacts and their representatives. It answers the following questions:
You have the right to object and withdraw your consent to our use of your personal data in certain circumstances. Please see section 9 to find out more.
It is important that you read this policy 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 policy supplements the other notices and is not intended to override them.
This policy was last updated on 15th July 2021. Any changes we may make to this policy in the future will be posted on our websites, and, where we are permitted to contact you by email, notified to you by email.
We are SevenTravel, part of SevenCapital plc (our group), which is a group of companies. The registered address is 97 Park Lane Mayfair, London, W1K 7TG. our group companies independently control data about our business contacts and their representatives. For an up-to-date list of our trading companies please contact our data protection office or our legal team on:
You can contact us about issues relating to personal data, including the contents of this notice, by any of the following methods:
This section explains the purposes for which we use personal data about our business contacts and their representatives. More detail about the types of personal data that we might use for these purposes can be found in section 4 below.
We use personal data for marketing purposes. This includes informing you about products and services that we think may be of interest to you and providing you with related materials such as news items and blog posts.
We will only make contact with you for marketing purposes by email if you have given us your consent to do so or if we have a legitimate interest in doing so (to develop our products/services and grow our business). However, we might also contact you for marketing purposes through other channels such as by telephone or post unless you specifically request us not to. You might also be contacted through any channel for other communication purposes – for example, if you have purchased an event we will contact you to ensure you are updated with progress.
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.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a purchase, product/service experience or other transactions.
We use personal data for relationship management purposes. Relationship management is the ongoing maintenance of our relationship with our clients and their representatives. This could include activities such as letting you know about product launches, build updates, inviting you to events and webinars or dealing with your enquiries. We will only make contact with you for marketing purposes by email if you have given us your consent to do so or if we have a legitimate interest in doing so (to develop our products/services and grow our business).
Sometimes we might need to use your personal data to provide you with information, services and facilities that you have asked for. We will do this for the performance of a contract we have with you, for our legitimate interests (in supporting our clients in their search for third party providers), or on the basis of your consent.
We use information such as how different people navigate around our websites, how long they spend on particular pages, whether they download any of our content in order to help improve the user experience of our websites. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).
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.
We will ask for your consent where necessary to make contact with you by email for marketing purposes. You can withdraw that consent and ask us to delete your information at any time – please see section 9.
The united kingdom’s data protection law also allows the use of personal data where the benefits (or “legitimate
interests”) of doing so outweigh the possible negative implications for the relevant individuals. These are the grounds
on which we usually rely when we use your information for anything other than making contact with you by email for
marketing purposes. If you object to us using these grounds you can do so at any time as explained in section 9.
The benefits that are being pursued are:
We have an interest in promoting our products and services
Helping people learn about products and services that might be of use to them
Other people have an interest in learning about products and
Understanding our clients and potential clients
Running a business
We have an interest in learning about our clients and potential
In some circumstances, we may have other grounds to process personal data. These are set out in the following table, along with examples of the circumstances in which they might apply.
Necessary for performance of a contract with the relevant individual, or to take steps for entering into a contract.
If you purchase a property, it will often be necessary for us, our legal representatives to use your details to ensure the processing of the sale and that you are kept up to date throughout the build process.
Necessary in order to comply with a legal obligation.
Regulators, government bodies and courts have powers to order us to provide information and, like any other organisation, we sometimes have to comply with their requests.
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.
We obtain and use information from various different sources. these are summarised in the following table.
Type of information
Name and contact details
This is personal data about you, and how to get in touch with you.
This information is usually provided directly by the relevant individuals; it could for example be given over the telephone, in an email, through our websites, or in person at an event
This is information about our dealings with you, such as what information we have sent you, who in our group knows you, what properties you are interested in, which events you have attended or newsletter you have signed up to. it also includes your behaviour in response to our interactions with you, such as whether you have opened our emails, clicked on a link or watched a video.
This is information about the device you are using to access our websites, such as the type of device, its operating system, browser, its ip address, and what cookies are on it.
We produce these records ourselves or with the assistance of third party service providers, acting as data processors, based in the Uk.
This is information about your use of our websites, such as what pages you have visited and what content you have downloaded.
We produce these records ourselves (or with the assistance of third party service providers, acting as data processors, based in the Uk) by monitoring your use of our websites – this will include the future use of marketing automation platforms to deliver a more tailored service to you.
We may gather information about your general internet use by using the cookie. Where used, these cookies are downloaded to your computer and stored on the computer’s hard drive. Such information will not identify you personally; it is statistical data which does not identify any personal details whatsoever.
We may provide your information to third parties who help us use it. For example:
—We might use a third party email broadcasting service in order to send you marketing emails (if you have agreed to receive them).
—We might use a printing company to produce and send personalised direct mail.
—We also use business software providers including crm, web hosting and security measures to keep your data safe as we don’t want to let competitors know exactly what software we use.
These service providers will not be allowed to use your information for their own purposes or on behalf of other organisations.
We may also provide personal data to named 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 only use your personal data in the same way as set out in this policy.
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.
We are based in the United Kingdom, and will normally access and use your information from here.
Sometimes we will need to send information elsewhere in the world. This might be the case, for example:
—When one of our overseas group companies or branch offices based overseas needs to use the information in accordance with this notice. Currently, these overseas offices are in dubai and hong kong.
Whenever we transfer your personal data out of 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.
—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.
If your information has been sent overseas like this, you can obtain further information about the safeguards used by contacting us using the details set out in section 1 above.
We will normally keep your personal data while you have an ongoing relationship with us or if you have demonstrated an interest in our products within the past five years. You can request us to delete it earlier as explained in section 9.
We use certain profiling techniques in order to help us to understand our clients and potential clients. This in turn helps us to understand which people might be interested in our products.
We do not use automated decision-making or profiling to make any decisions that will significantly affect you. For example, we do not use it to set the prices that we charge for our products.
You have several different rights in relation to the personal data that we hold about you. These are briefly described below. To enquire about exercising these rights, please use the contact details set out section 1.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.
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.
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.
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.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.
If we hold your data where we have no contact or request to delete your data after a period of 5 years, your data will be deactivated on our systems.
If we hold your data due to a legally binding contract, such as a sale of a property or purchase of services, we will retain your personal data for a minimum of 10 years or longer should you have an ongoing relationship with the seven capital group.
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.
We try to ensure that we deliver the best levels of customer service but if you are not happy you should make contact so that we can investigate your concerns. Please contact us using these details:
Post: Angelee Rathor, 97 Park Lane, Mayfair, London, W1K 7TG
Email: [email protected]
Telephone: +44 (0)207 659 4430
You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO), which is the body that regulates the handling of personal data in the united kingdom. You can do this online through the ICO’s website at www.Ico.org.uk, by telephone on 303 123 1113, or by writing to them at information commissioner’s office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF.