Privacy Policy

Introduction

Your privacy is important to us and we are committed to protecting your personal information. We will never misuse or sell your data to a third party. This Privacy Policy outlines what information we may collect from you, how and why we store and process it in the course of our business, and your rights over your information that we fully respect.

Please read this Privacy Policy carefully. If you do not agree to our use of your personal information as set out below, we may not be able to accept a booking from you.

Who We Are

Angelfish Limited (“Angelfish”, “We”) is a UK based company specialising in bespoke, luxury, long-haul travel services. We operate our business to the highest ethical standards and take compliance with applicable laws and regulations seriously. We hold our own ATOL (no. 6062) and we are a member of ABTA (no. W6703).

Trading Name

Our principal trading name is Angelfish Travel, and we also own other trading names including Maldives Direct, Seychelles Direct, Mauritius Direct Holidays & Oman Direct. In all circumstances your booking contract is with Angelfish, and our policies, including this Privacy Policy, apply and are adhered to irrespective of the trading name used.

We have a legal duty to protect personal data that we collect and for the purposes of the Data Protection Act and GDPR, Angelfish is the “data controller”, (i.e. the organisation that determines how your data is used).

Information We Collect & How We Use It

This section outlines the various types of information we may collect about you, how we use it and our lawful basis for storing and processing it. This will normally be with your consent, in the performance of our contract with you, where we have a legal obligation, or for a legitimate business interest.

Enquiries & Bookings

When you make an enquiry with us we collect a range of details that you provide voluntarily including your name, contact information, and your preferences with respect to your proposed travel plans. The information is stored digitally in our database, and we use this only for legitimate interests in helping find the most suitable travel options for you.

If you make a booking with us we may ask you to provide certain additional information about you and your travel arrangements, such as personal preferences and special requirements, flights (if you arrange your own flights), frequent flier numbers, nationality and passport details, travel insurance and so on.

We will also require details of any other passengers who are travelling with you as part of your booking. To the extent that you provide us with information about other members of your party we ask that you have obtained consent from them to do so, or consent on the behalf of any children as their parent or guardian. Please inform them about this Privacy Notice and ask them to contact us if they have any queries or concerns.

We collect and use this information in order to organise your trip and make the necessary reservations on your behalf, and thereby fulfil our contract with you. We may retain some of this personal information for when you next book with us, in order to ensure that you receive the high standard of personal service that we aim to deliver.

Special Category Data

Certain categories of sensitive personal information (e.g. ethnicity, religion, health) are considered “special category data”. We do not collect or process such data as a rule, but under some circumstances you may provide us with sensitive personal data, either directly or by implication, when asking us to make travel arrangements on your behalf, such as special dietary requirements, mobility assistance, accommodation requests and so on.

By voluntarily providing us with information that could be considered sensitive personal data, you explicitly consent to our collecting, processing, sharing and transfer (including outside the EEA) of your information within the guidelines of the Privacy Policy. If you withdraw your consent it may mean that we are unable to provide contracted services to you, in which case our cancellation (by you) terms would apply.

Telephone Call Recording

We record telephone calls with a legitimate interest for monitoring and training purposes. We pause the call recording when taking card payment details so that these are not retained in any format.

Feedback

After you return from your trip we invite you to provide feedback on your experiences, which we use with legitimate interest to help improve our services and those of our business partners and suppliers.

Direct Email Marketing

We circulate a periodic newsletter containing items of interest for our travel destinations, as well as offers that we think may appeal to you. You are only added to our mailing list if you consent to this by explicitly asking us to do so, or by signing up via our website through the ‘double-opt-in’ process. You may withdraw your consent by unsubscribing at any time, using the link in the newsletter, or by asking us to remove you. Note that we may retain your contact details to ensure that you do not receive emails from us once you have unsubscribed.

Services Communication

Even if you have opted out of receiving our newsletter, where there is a legitimate interest we may still send you other communications regarding your booking and travel itinerary. This may contain offers and options in relation to the services you have requested, such as seating reservations and upgrades, transfer upgrades, excursions and so on.

Gift List

If you elect to hold a honeymoon gift list with Angelfish we will store additional information about your wedding date and preferences, with your consent. We will record and store information about contribution payments towards your gift list from friends and family, including their names and messages that they leave for you. We may ask for your bank details to reimburse funds to you.

Administrative Purposes

Where there is a legal requirement or legitimate interest we may use your information for internal record keeping, auditing and regulatory requirements, for detecting and preventing fraudulent or criminal activity, and for resolving complaints and dealing with disputes.

Sharing Of Your Data

In order to provide services to you, and during the course of our business, it is necessary for us to share your personal information with third parties. We do not share your data with third parties for their own marketing purposes, or any purpose other than that designated by us.

Business Partners & Suppliers

To reserve and confirm your travel arrangements we will necessarily share some of your personal information with third parties, such as airlines, hotels, ground handlers, and in some cases their booking agents and service providers, who will process and store your data accordingly. Some of these partners may be based outside of the EEA.

Legal & Regulatory Requirements

We may share your personal information with third parties such as industry regulators or governments where it is necessary to comply with legal obligations or enforce agreements, or to protect the rights, safety or property of you and/or others.

In the event of our insolvency we, or any appointed insolvency practitioner, may disclose your personal information to the CAA, and/or ABTA so that they can assess the status of your booking and advise you on the appropriate course of action under any scheme of financial protection. The CAA's General Privacy Notice is at https://www.caa.co.uk/Our-work/About-us/General-privacy-notice/ ABTA’s Privacy Notice is at https://www.abta.com/privacy-notice.

Selling Information

Angelfish does not buy data from, sell data to, or rent data to any third party.

Links To Other Websites

For your information and convenience, we occasionally provide links to external websites, either from our own sites or in dialogue with you. Angelfish is not responsible for the content or policies of third party sites, or for the privacy and security of any information you provide to them. Please read the Privacy Notice for any third party site before submitting your personal information.

Consent

By providing your personal information, you consent to the processing, storing, transferring and sharing of your information and data for the purposes set out in this Privacy Policy.

Your Legal Rights & Control Of Your Data

You have certain rights, outlined below, in respect of the personal information that we hold about you. To exercise any of these rights, please contact us.

Information & Access

At your request we will confirm whether or not we are storing and processing your personal information and provide a copy of the information that we hold.

Rectification

We will correct any inaccurate or incomplete personal information that you advise us of.

Erasure

We will delete your personal information and data at your request without undue delay where there is no valid reason for us to continue to use it.

Processing Restriction

We will restrict the processing of your personal information under valid circumstances if you ask us to do so.

Data Portability

We will provide you, or transfer to a third party that you designate, your personal information and data, in a structured, commonly used, and machine readable format.

Objection

We will cease processing your personal information if there is no valid reason for us to continue. We will cease using your data for any direct marketing purposes as soon as you instruct us to do so.

Automated Decisions & Profiling

We do not make automated decisions or profile you based on your personal information.

Security

We take the security of your information very seriously and use industry standard physical and technical security measures to protect your data. We keep these under review to make sure that the measures we have in place remain appropriate.

Personal Information Retention

We will keep your personal information for limited and appropriate periods of time only and for the appropriate processing purposes set out in this Privacy Policy. Note that some transaction information may be kept for a number of years to comply with accounting and tax related obligations. We may retain your Personal Information for the duration of any period necessary to establish, exercise or defend any legal rights.

Changes To Our Privacy Policy

We reserve the right to modify this Privacy Policy from time to time should we change the ways that we use your personal information or to reflect changes in legal requirements. Any amendments we make will be posted on our website and, where appropriate, we will notify you by email. This policy was last updated in January 2020 to include consent to transfer your information to ABTA and the CAA in event of our insolvency.

Contact Us

If you have any questions, comments, requests or complaints regarding this Privacy Policy and/or our use of your personal data, please contact dataprotection@angelfish.travel, or write to us at Angelfish Travel, Cranbrook Business Centre, High Street, Cranbrook, Kent TN17 3EJ, U.K.

If you have any complaints that you cannot resolve with us directly, you may also contact the UK Information Commissioner via the website https://ico.org.uk/.