TripHunters is an associated brand of, and operated by, TH Travel LTD (registered in England & Wales, company number 1233377).
- IMPORTANT INFORMATION AND WHO WE ARE
- THE DATA WE COLLECT ABOUT YOU
- HOW AND WHY WE USE YOUR PERSONAL DATA
- DISCLOSURES OF YOUR PERSONAL DATA TO THIRD PARTIES
- INTERNATIONAL TRANSFERS
- DATA SECURITY
- DATA RETENTION
- YOUR LEGAL RIGHTS
1. IMPORTANT INFORMATION AND WHO WE ARE
This website is not intended for children and we do not knowingly collect data relating to children.
Full name of legal entity: TH Travel LTD Limited
Email address: firstname.lastname@example.org
Postal address: TH Travel Ltd, 50 Arlington Avenue, Unit 1 (GF), London, N1 7AY
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 (www.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.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2. 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:
- Personal and contact information when you register your details at TripHunters online (or update that information in your account), including your name, email address, phone number.
- Details of any conversations that you have with our customer support team or otherwise, including by email, telephone (voice recordings), post and online via webchat, the feedback button or on our social media channels.
- Copies of documents you provide to prove your identity (including driving licence and passport) when you are claiming a prize, or where there is a legal reason to request this from you.
- Transaction details including payments from you for TripHunters prize draw entries, payments to you (for example prizes) and details of which prize draws you have entered and the outcome of those entries.
- Payment card information when you make a purchase. Note that your full payment card details are never stored on our servers but only with our fully PCI compliant payment processor.
- Personal and contact information, including your image, voice, footage (and any other information that identifies you) when contributing to our advertising and/or media content, assuming you have signed an appropriate consent/release form.
- Information about how you use and interact with our website, and which website(s) you came to the TripHunters website from.
- Technical information about your device or browser when you use our website, including geolocation data to determine what country you are accessing our website from, your internet protocol (IP) address, device ID, browser type and version and time zone setting, which may in some circumstances be personal data.
- We may also receive personal data directly from you or from various third parties and public sources, such as social media channels (if you interact with us through those channels), or other third parties used to verify age/indentity.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
3. HOW AND WHY WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
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.
|How we use your personal data||Why we use your personal data|
We use your personal and contact information to register you as a new customer.
We collect financial information if you register payment card information to your account or set up entering by subscription.
|Performance of a contract with you.|
We use technical information such as the location or time zone from which you access our website, the personal details you provide at account set up and, where relevant, any identity documents you have provided to check whether you are eligible to enter our prize draws.
When you set up your account we may use an automated process to verify that the details you provide are correct and to verify you are over 18, and that you are a UK resident.
|Necessary to comply with a legal obligation.|
|We may require copies of documents to verify your identity where we are required by law to provide assistance or in order to comply with any request you may make regarding a TripHunters account.||Necessary to comply with a legal obligation.|
|We use the personal and contact information provided by you and the transaction details about your purchases, to provide our games and other services to you.||Performance of a contract with you.|
|We use your personal and contact information, financial information, and transaction details about your TripHunters purchases, to manage your TripHunters account, to contact you if you’ve won a prize, and to pay those prizes.||Performance of a contract with you.|
|We use your personal and contact information to contact you if you’ve won a prize, and to pay (or facilitate payment of) those prizes.||Performance of a contract with you.|
|We use the personal and contact information provided by you, copies of your communications with us and, in some circumstances, transaction details, to manage our relationship with you.|
Performance of a contract with you.
Necessary to comply with a legal obligation.
Necessary for our legitimate interests (to keep our records updated and to study how customers interact with our prize competitions).
|We may use the personal and contact information you have provided to ask you to take part in market research or a survey in order to improve our website and service.||Necessary for our legitimate interests (to ensure that we are able to provide the best service to you).|
|We may use your personal and contact information, transaction details, and financial information as part of a prize draw or competition (including to enter, take part and pay any prizes due as part of that prize draw or competition).||Performance of a contract with you.|
|We use information about your use of our website, together with technical information about your device and (in some circumstances) your personal and contact information, and other relevant information that we receive from you or third parties (including aggregated information that we combine with your personal data), to deliver relevant website content and other direct marketing to you on various channels, including on social media platforms, and to manage the delivery of that content.|
Necessary for our legitimate interests (to ensure that you are shown relevant content based on your use of our website).
|We use information about your use of our website and, in some circumstances, personal and contact information about you, to measure or understand the effectiveness of the advertising we serve to you.||Necessary for our legitimate interests (to determine how effective advertising is in order to improve advertising and its relevance).|
|We use information about your use of our website and technical information, including about your device or where you are accessing our website from, to optimise our service and to improve our website, games, services, direct marketing, customer relationships, behaviour profiling and experiences.||Necessary for our legitimate interests (to measure the interactions with our website, to define types of customers of TripHunters prize competitions, how customers interact with the prize competitions, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).|
|If you win on a TripHunters prize competition, we may use your personal and contact information to contact you to arrange support.||Necessary for our legitimate interests (to manage our winner services).|
|We may use your personal and limited contact information in any publicity materials or events, provided that you have given your consent.||Your consent.|
|We may use your personal data in marketing and/or media content where you have agreed to and signed a consent form, including in advertisements, customer communications and in any other marketing content, across all media.||Necessary for our legitimate interests (to consider and/or to publish your use of our website).|
|We may use your personal and contact information, financial information, information about any transaction between you and us, copies of your communications with us (including voice recordings), information about your use of the website, or technical information, in order to undertake analysis for the purposes of identifying and dealing with any fraud or fraudulent activity.|
Necessary to comply with a legal obligation.
Necessary for our legitimate interests (to ensure that transactions and interactions with us are not fraudulent).
|We may use your personal and contact information, financial information, information about any transaction between you and us, copies of your communications with us (including voice recordings), information about your use of the website, or technical information for the purpose of dealing with any request, complaint or query from you.|
Necessary to comply with a legal obligation.
Necessary for our legitimate interests (to respond to you and to deal with any request you may have).
We use your personal data to create aggregated data sets. You are not identifiable from that aggregated data and it is not considered personal data.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You will be given the choice of whether or not to receive marketing messages when you buy your TripHunters ticket(s).
You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
You can also ask us to stop sending you marketing messages by logging in to your TripHunters account and modifiying your email preferences.
SHARING YOUR INFORMATION WITH OUR MARKETING PARTNERS
We may share your data with our marketing partners, including advertisers, advertising networks and agencies to provide targeted advertising or to exclude you from our targeted advertising. We may also share your data with social media providers, including Facebook for custom audiences (for information on to opt out of Facebook custom audiences see the information provided by Facebook in its Help Centre (https://www.facebook.com/help/1415256572060999).
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.
There are four main types of cookies and technology. Here's how and why we use them:
Strictly necessary cookies
These are cookies that are required for the operation of our website. Without these cookies, you will not be able to use some functionality on our website, such as signing into your account.
These cookies collect information about how you use our website and help us improve the way our website works by making it easier for you to navigate to and complete various tasks.
These cookies allow us to identify whether you are logged into your TripHunters account and to remember choices you make and your preferences, in order to improve your experience of our website.
Advertising cookies and pixels
Our carefully selected media partners place third party cookies, pixels and ad tags onto our website on our behalf. These cookies record your visit to our website, the pages you have visited and the links you have followed. We use this information to make our website, and the content displayed on it, more relevant to you. They are also used to limit the number of times you see certain content, as well to measure the effectiveness of our digital campaigns. We may share this analytics information with third parties for these purposes. You can opt out of these cookies and still continue to use the website using your browser settings.
Below is a list of our main partners that may place cookies, pixels or other similar technology on your browser or device when visiting our website:
|Partner name||What their cookies are used for|
|Google Analytics is a web analytics platform that allows your interactions with the website to be measured. The cookies are used to identify you as an distinct user, but not with personally identifiable information.|
|The Facebook cookie allows us to record your actions after you have seen or clicked on an ad in order to measure its effectiveness and to serve you with targeted ads based on your visits to our website.|
5. DISCLOSURES OF YOUR PERSONAL DATA TO THIRD PARTIES
We sometimes share the data we collect from you with the following trusted third parties:
- Prize fulfilment partners – for the purposes of winner management and prize fulfilment, ensuring prizes get delivered/organized.
- Banks and payment providers – to set up a recurring payments on your account, to pay prizes to you and to obtain payment of any amounts due to us.
- Our IT system providers – in order to provide software to set up your player account, to communicate with you via webchat and other communications providers and to provide our systems to us, including for the purposes of hosting, support and software licensing.
- Marketing service providers – to allow us to send email communications and notifications.
- Marketing agencies – for the purposes of providing you with relevant advertising or marketing on our website or on social media, including for the purposes of undertaking behavioural modelling for that purpose.
- Social media platforms – for the purpose of targeted advertising.
- Online survey companies and market research agencies – to undertake surveys and other market research and to analyse the results.
- Digital analytics companies – for the purposes of website analytics and reporting in respect of our analytics and marketing.
- Public relations agencies – for the purposes of managing external communications about us and our winners.
- Professional advisers including lawyers, bankers, auditors and insurers – for the purposes of providing consultancy, banking, legal, insurance and accounting services.
- Police or other such regulatory authority – as part of an investigation or otherwise for legal or regulatory purposes.
- Dispute Resolution agencies – for the purposes of dealing with any complaints.
- Credit reference agencies – for the purpose of checking the details that you have provided us with are correct.
- Security companies and research institutions – for the purposes of security, including prevention and detection methods, for the protection of TripHunters.
- Auditors – to audit our systems and transactions for the purposes of ensuring efficiency, or regulatory or contractual compliance.
- UK law enforcement agencies and third party security companies – for the purposes of ensuring that we comply with the law and have adequate security measures in place.
- We will disclose your personal information to third parties if we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request. We do this in order to protect our rights, property or safety or of our players, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
6. INTERNATIONAL TRANSFERS
We do not transfer your personal data outside the European Economic Area (EEA).
7. 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 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.
8. 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.
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 could 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.
9. 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.
- 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.