1. Definitions and Recitals
1.1 References in this policy to "data protection law" mean (as applicable) the Data Protection Act 1998 (and any law which replaces it, including the new UK Data Protection Bill) (the “DPA”), the General Data Protection Regulation (Regulation (EU) 2016/679) (the ‘’GDPR’’), and all related data protection legislation having effect in the United Kingdom from time to time (including the Data Protection Act 2018).
1.2 Ride World Wide Limited (‘’RWW’’ also "us" or "we") is committed to protecting and respecting your privacy. For the purposes of data protection law, the data controller (in other words, the organisation that determines how your personal information is used) is Ride World Wide Limited, Staddon Farm, North Tawton, Devon EX20 2BX.
2. Personal information we collect, how we use it & lawful basis for processing
2.1 We may collect and use various types of personal information about you. The following is an overview of this information, the way we use it and our lawful bases for processing it. Where our lawful basis for processing your data is because it is in our legitimate interest to do so, in accordance with data protection law, we always weigh your interests, fundamental rights and freedoms against the legitimate interest we have to process your information in the way we do and we will only do so where we are satisfied we are justified in doing so.
A) Enquiries and Bookings:-
i) We will collect and hold personal information from you when you make an enquiry or request a brochure through our website or by corresponding with us by telephone or email.
ii) This information may include your name and contact details; it may also include your riding experience, the destinations and countries you are most interested in, the trips you have been on before and any additional information relating to your travel wishes that you give to us.
iii) We may collect similar information from you about friends or family intending to travel with you and we may ask how you heard of us.
iv) We also may collect personal information about you if it is forwarded to us by a travel agent or another person making an enquiry or booking on your behalf.
We will use this information to contact you and to advise, answer questions and send you information we feel will be helpful in planning your trip. We do this on the basis of your consent where appropriate or because it is in our legitimate interest to respond to enquiries and try to find the best holiday for customers and potential customers. If the information has been supplied to us by a third party, we will contact you if they ask us to and because it is in our legitimate interest to follow up enquiries.
v) If you book with us, we will ask for certain further information which may include details of your:- passport, nationality, emergency contacts, next of kin, insurance, diet preferences, health or other special requirements, flights (if you arrange your own) or other travel arrangements and frequent flier club membership; we may request similar details of friends or family accompanying you as part of your booking (although where this is sensitive personal information we may need and seek their explicit consent).
We need and will use this information to carry out obligations arising from our contract with you, including taking pre-contract steps, ensuring the trip is appropriate for you and providing you (and anyone accompanying you) with the information, products and services requested.
vi) When your booking has been completed or you cease a particular enquiry, we may retain your personal information for use in your future bookings and enquiries and so we can maintain accurate internal records. We may also post or email a brochure to you annually.
We do this as we have a legitimate interest in looking after repeat customers, in keeping accurate records and in keeping in touch with customers and potential customers. You can opt out of receiving brochures at any time.
vii) When you visit our website we will automatically collect certain technical information about you and your visit. This may include: the Internet protocol (IP) address you use, your login information, browser type and version (eg Chrome or Internet Explorer), time zone setting, operating system and platform (e.g. Windows or Mac), the dates and times you access our website, the full URLs of the pages you visit and the websites or links you use to access it, login information, details of products or services viewed, the length of visits to certain pages, page interaction information (eg scrolling, clicks and mouse-overs), methods used to browse away from the page and any phone number used to call us.
We use this information for website management, security (eg troubleshooting and testing) and improvements. We do not use this data to try to identify individual users or usage habits. Raw data logs may be retained temporarily for security and site management purposes only.
We collect this information as it is in our legitimate interest to ensure our website promotes our services appropriately, including by displaying information our customers are interested in, to measure customer satisfaction and troubleshoot website issues. If we are required to by law, we will seek your consent.
viii) We may collect information about you from various sources in connection with the marketing and advertising of our services.
Where you have given us your details in connection with an enquiry or booking, we may send you marketing information about our holidays on the basis of the ‘soft opt- in’ under the Privacy and Marketing Communications Regulations OR because it is in our legitimate interests to promote our services.
Where your details have been passed to us by another source (eg a friend or group of which you are a member), we contact you about our products because it is in our legitimate interests to promote our services.
In either case, you can unsubscribe from marketing communications at any time using the unsubscribe option in any email or by contacting us.
ix) We may also collect your details from occasional competitions, promotions or surveys in which case we rely on your consent to receiving marketing messages (and you can ‘opt out’ at any time) OR if we use your data to carry out market research, we do so because it is in our legitimate interest (although we always weigh up your rights and freedoms against our interest).
x) We may collect details about you, such as your user name, through social media (eg if you mention or tag us in a post or comment on a post). We do this so we can respond to any comments you have and because it is in our legitimate interest to keep in touch.
xi) We may also use data we collect from you (either directly or via our website or advertising) to help assess the effectiveness of our advertising and establish what interests you and what doesn't. It is in our legitimate interest to process your data in this way
2.2 As well as collecting personal information directly from you, we also collect some from third parties such as Google Analytics.
3. How we share personal information
3.1 We don’t share your personal information with anyone except where we are required to by law, to efficiently run our business, protect our rights or improve and expand our products and services. In order to achieve these purposes, we may share your data with the following:
(a) Selected independent business partners (eg local ride operators) and service providers related to the provision of services under our contract with you.
(b) Prospective buyers of our business or assets subject to them entering into strict confidentiality obligations with us and only to the extent permissible under data protection law;
c) Our professional advisers (eg accountants and solicitors) who are subject to professional duties of confidentiality.
d) Outsourced IT providers who may occasionally require access to data held on our systems, for example when we need to troubleshoot a technical issue. Such providers are subject to strict contractual obligations to treat your personal information with the utmost sensitivity, to keep it confidential and to comply with data protection law at all times;
(e) Our bonding authorities, trade associations and other third parties if necessary to comply with our legal obligations (eg we may be required to provide airlines with a passenger mobile ‘phone number and email contact so they can inform you directly of any operational difficulties)
(f) Any other third parties if the law requires or allows us (eg police, law enforcement agencies) or as necessary to protect our or your rights, property or safety and/or those of others.
3.2 We do not sell your personal information or share it with third parties to use for their own marketing or other purposes.
3.3 We do not make automated decisions about you based on your information.
4. Where we transfer & store personal information
From time to time we may process (or ask or permit a third party to process) your personal information outside the European Economic Area (EEA) where local laws may not provide legal protection in the same way as is applicable in the EEA. For example, when you book a trip, we will need to provide your information to local service providers. Or we may need to share your information with someone who hosts or guides the rides. Whenever we send (or permit a third party to send) your personal data outside the EEA, we take steps to protect your data as required by applicable laws and we only share information limited to what is necessary. The personal data we collect from you will also be processed by staff operating outside the EEA who work for our suppliers, including among other things, providing support services.
5. Security of your personal information
We take the security of your personal information seriously and have strategies in place to help protect it as required by law. We will always keep these under review to make sure the measures remain appropriate. Unfortunately, the transmission of information via the internet is not completely secure and we cannot guarantee the security of data transmitted to us on the internet or through our website. Transmission is at your own risk. Once we have received your information, we will use strict procedures and security safeguards to try to prevent unauthorised access or disclosure.
6. Retention of personal information
We will keep your personal information for limited and appropriate periods of time only. These are linked to the purposes for which we process the information so vary according to the type of information. For example, some transaction information will be kept for a number of years to comply with various finance and tax related obligations. We keep time periods under review. If you need more information on this, please contact us.
7. Your Rights
a) Information: You have a right to be informed, including but not limited to the right to know what information we gather, process and store, what we do with it, who we share it with and how long we keep it for. This information is set out in this policy.
(b) Access: At your request we will confirm to you whether or not we are processing and using personal information about you and, if requested will provide you with a copy of such personal information and the other details to which you are entitled.
(c) Rectification: If required we will correct any inaccurate personal data and complete any incomplete personal data that we hold about you.
(d) Prevention of processing likely to cause damage or distress: We will respect your rights to require us to cease or not to begin processing your personal information for a specific purpose, or in a specific way, that is likely to cause you or any third parties unwarranted damage or distress.
(e) Erasure: We will erase your personal information at your request without undue delay where there is no good reason for us to continue to keep it.
(f) Restriction: We will restrict the processing of your personal information in certain circumstances, if you ask us to do so.
(g) Data portability: We will provide you or third parties on your behalf with a copy of any personal information we hold about you which you have provided to us in a structured, commonly used and machine readable format.
(h) Objection (including objection to direct marketing): We will respect your general rights to object to the processing of your personal information for direct marketing purposes and in certain circumstances, for other purposes.
(i) Automated decisions and profiling: We do not make automated decisions or profile you based on your data.
7.2 You also have the general right to complain to us (in the first instance) and to the Information Commissioner's Office (if you are not satisfied by our response) if you have any concerns about how we hold and process your information. Our contact details are below. You will find further information on your rights under data protection law and how to exercise them on the Information Commissioner's Office website www.ico.org.uk).
8.1 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your device if you agree. Cookies contain information that is transferred to your device's hard drive.
8.3 We use the following cookies:
8.3.1 Strictly necessary cookies.
These are cookies required for the operation of our site. They may include, for example, cookies that enable you to log into secure areas of our site or use a shopping cart.
8.3.2 Analytical/performance cookies.
These allow us to recognise and count the number of visitors and see how visitors move around our site when they are using it. This helps us to improve the way the site works, for example, by ensuring users are finding what they are looking for easily.
8.3.3 Functionality cookies.
These are used to recognise you when you return to our site. This enables us to personalise content for you, greet you by name and organisation and remember your preferences (for example, your choice of language or region).
8.3.4 Targeting cookies.
These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site more relevant to your interests. We may also share this information with third parties for this purpose. Except for essential cookies, all cookies will expire after 30 [thirty] days.
8.4 Third party cookies.
8.5 Blocking cookies.
You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
9. Changes to our Policy
Ride World Wide Limited, Staddon Farm, North Tawton, Devon EX20 2BX.
You may also contact the UK Information Commissioner at telephone number 0303 123 1113 or https://ico.org.uk/.