Privacy Policy

1. Introduction

Welcome to Albion English Trips (“we”, “us”, or “our”). We operate the website albionenglishtrips.com. We are committed to protecting your privacy and ensuring that your personal data is handled in compliance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and the UK General Data Protection Regulation (“UK GDPR”), as well as the Data Protection Act 2018 in the UK.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our Website, interact with our services, or otherwise engage with us. By using our Website, you consent to the practices described in this Privacy Policy.

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), we act as the data controller for your personal data. Our contact details are:

• Data Controller: Albion English Trips limited
• Address: 17 Bradley Street, Sheffield, United Kingdom
• Email: info@albionenglishtrips.com

For any questions about this Privacy Policy or our data practices, please contact us at the above email address.

2. Personal Data We Collect

We collect personal data that you provide to us directly, as well as information collected automatically through your use of the Website. Personal data means any information relating to an identified or identifiable natural person.

2.1 Data You Provide Directly

• Contact Information: Name, email address, phone number, when you fill out forms or contact us for support.
• Enquiry Content: Information you include in your enquiry, such as the student’s English level and the trip you are interested in.
• Other Information: Any additional details you voluntarily provide, such as in surveys or inquiries.

We do not collect or process payment method information, as we do not handle financial transactions directly on the Website.

2.2 Data Collected Automatically

• Device and Usage Information: IP address, browser type, operating system, device identifiers, pages visited, time and date of visits, referring URLs, and interaction data (e.g., clicks, scrolls).
• Privacy-friendly Analytics: We use privacy-first, cookieless analytics to understand aggregate Website usage.
• Location Data: Approximate location based on IP address (we do not collect precise geolocation without consent).

We do not collect sensitive personal data (e.g., racial or ethnic origin, political opinions, religious beliefs, health data) unless explicitly provided by you for a specific purpose, in which case we will seek your explicit consent.

3. How We Collect Your Data

• Directly from You: Through forms, emails, or other interactions.
• Automatically: Via server logs and privacy-friendly analytics tools.
• From Third Parties: We may receive data from service providers (e.g., analytics partners) or publicly available sources, but only where lawful.

4. Purposes and Legal Basis for Processing Your Data

We process your personal data only for specified, explicit, and legitimate purposes. The legal bases under GDPR/UK GDPR include:

• Consent: Where you have given clear consent (e.g., for marketing emails).
• Contractual Necessity: To perform a contract with you (e.g., providing services you requested).
• Legitimate Interests: For our business interests, provided they do not override your rights (e.g., improving Website functionality, fraud prevention).
• Legal Obligation: To comply with laws (e.g., record-keeping for tax purposes).
• Vital Interests: In rare cases, to protect life or safety.

Specific purposes include:

• Providing and maintaining the Website and services.
• Communicating with you (e.g., responding to inquiries, sending updates).
• Analyzing usage to improve our offerings.
• Marketing and promotions (with consent or opt-out options).
• Detecting and preventing fraud, abuse, or security issues.
• Complying with legal requirements.

We will not use your data for automated decision-making, including profiling, that produces legal effects or significantly affects you without your consent or another lawful basis.

5. Sharing Your Personal Data

We may share your personal data with:

• Service Providers: Third-party vendors who assist us (e.g., hosting providers, email services, analytics tools) under strict data processing agreements ensuring GDPR/UK GDPR compliance.
• Business Partners: If we collaborate on services, only with your consent.
• Legal Authorities: If required by law, court order, or to protect our rights.
• Successors: In the event of a merger, acquisition, or asset sale.

We do not sell your personal data to third parties.

6. International Data Transfers

If we transfer personal data outside the EEA or UK (e.g., to service providers in the US), we ensure appropriate safeguards are in place, such as:

• Adequacy decisions by the European Commission or UK Government.
• Standard Contractual Clauses (SCCs) or International Data Transfer Agreements (IDTAs).
• Binding Corporate Rules (if applicable).

We will provide details of transfers upon request.

7. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These include:

• Encryption (e.g., SSL/TLS for data in transit).
• Access controls and firewalls.
• Regular security audits.
• Employee training on data protection.

However, no system is completely secure, and we cannot guarantee absolute security.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined in this Policy, or as required by law. For example:

• Enquiry data: As long as needed to handle your enquiry and any resulting booking.
• Usage logs: Up to 12 months for analytics.
• Legal records: As mandated (e.g., 6 years for tax purposes in the UK).

After retention periods, data is securely deleted or anonymized.

9. Your Rights

Under GDPR/UK GDPR, you have the following rights regarding your personal data:

• Access: Request a copy of your data.
• Rectification: Correct inaccurate data.
• Erasure (“Right to be Forgotten”): Delete data in certain circumstances.
• Restriction: Limit processing.
• Portability: Receive data in a structured format.
• Objection: Object to processing based on legitimate interests or for direct marketing.
• Withdraw Consent: At any time, without affecting prior processing.
• Automated Decisions: Not to be subject to solely automated decisions.

To exercise these rights, contact us at info@albionenglishtrips.com. We will respond within one month (extendable if complex). There is no fee unless requests are excessive.

If unsatisfied, you can complain to a supervisory authority:

• In the EU: Your local data protection authority (list at edpb.europa.eu).
• In the UK: Information Commissioner’s Office (ICO) at ico.org.uk.

10. Cookies and Tracking Technologies

We keep the use of cookies to a minimum. Our analytics are cookieless and privacy-friendly. Any cookies used are strictly necessary for Website operation (no consent required). If we introduce analytics or marketing cookies in the future, we will ask for your consent first.

11. Children’s Privacy

Our Website is not intended for children under 16. We do not knowingly collect data from children through the Website. Information about student participants is provided to us by their parents or guardians as part of the booking process.

12. Changes to This Privacy Policy

We may update this Policy to reflect changes in our practices or legal requirements. We will notify you via email or Website notice for significant changes. Continued use after updates constitutes acceptance.

13. Third-Party Links

Our Website may contain links to third-party sites. We are not responsible for their privacy practices. Review their policies separately.

Thank you for trusting us with your data. For any concerns, contact us at info@albionenglishtrips.com.