The following Hulah privacy policy sets out how we collect, store, use and disseminate data relating to you and applies to all use of data by Yonder Travel Limited (“Hulah”, “we”, “us" or “our”). This privacy policy forms a part of the terms of use on our website, www.hulah.com and the Hulah app.

For the purpose of the Data Protection Act 1998, the data controller is YONDER TRAVEL LIMITED of 123 Bensham Lane, Thornton Heath, United Kingdom, CR7 7EW.

If you have any concerns about your privacy, this Hulah privacy policy or any websites or apps operated by Hulah, please contact Hulah at hello@hulah.com.

  1. ABOUT THE SERVICE AND THIS PRIVACY POLICY

    1. The Hulah app (the “App”) is an application and service owned and operated by Yonder Travel Limited. The Hulah website at www.hulah.com (the “Website”) is an online information service that we own and operate.

    2. The Website provides information about us, the App and our other services. The Website and the App enable individuals to arrange and buy holidays and other travel products and services from third parties.

    3. In these terms of use, the “Service” is a reference to the App and the Website or to any part of any of them.

  1. WHAT DATA DO WE COLLECT?

    1. We may ask you for, or you may submit, personal and non-personal information and data to us when you use the Service. This could include:

      1. your name, address, gender and age

      2. your username and password

      3. your holiday preferences

      4. your email address

      5. your phone number

      6. your browsing and log data collected by Google advertising cookies and other technical means that we may employ to recognise your device when you visit the Website; and

      7. any content you submit to the Service ("Your Content”), such as comments and marketing preferences or responses to surveys and questionnaires.

    2. Please also see our Cookies section below for information about how we use cookies.

    3. When you get in contact with us we may keep records of what is communicated. This is to ensure we have a record of our discussion for future reference and so we can provide services to you more efficiently.

    4. We might collect sensitive information about you, but we will never collect your sensitive information without your explicit consent.

  1. USES OF DATA

    1. We use data for the following purposes:

      1. Name, address: to enable you to receive offers and to manage your user account

      2. Gender, age: to provide features and content which are better suited to you

      3. Username, password: to manage your user account

      4. Holiday preferences : to understand what types of products or services may interest you, or may interest people who have similar characteristics to you.

      5. Email address: to contact you with news, including to notify you about any purchases made through the App and/or the Website, or to offer you additional services. By accepting this Privacy Policy you consent to us using your email address for direct marketing and advertising purposes where you have consented that we may do so

      6. Phone number: to contact you about matters requiring your urgent attention, to verify your identity or to provide other Hulah services with your consent (such as text message notifications)

      7. Your Content: to process and make available Your Content to the Service, to market to you and to determine your interests in products and services or general consumer trends

      8. Google advertising cookies and anonymous identifiers: to conduct analytics on your visit to the Website, including by recording and analysing user behaviour, location, audience, demographic and interest data. This information may be used in order to enable the remarketing of users and may be shared with Google.

    2. Information submitted to the Service may also be used to:

      1. enable our compliance with applicable laws and regulations

      2. enable our compliance with any agreements entered into between us

      3. enable your use of the Service and associated services

      4. understand how the Service is being used

      5. provide you with an up to date, efficient and reliable service; and

      6. generally run and improve the Service.

  1. DATA SHARING

    1. We may disclose personal information about you to other members of our group of companies or to trusted third parties (both inside and outside of the European Economic Area):

      1. for the purposes and uses set out in this privacy policy;

      2. for marketing purposes; and

      3. to enable us to receive services which help us operate the Service.

    2. Your personal information may also be disclosed:

      1. if we sell any businesses or assets

      2. with a view to preventing fraud or reducing credit risk; and

      3. if we are obliged to do so to comply with law, regulations or a court order; if it is necessary to enforce any of our terms and conditions or any other agreements to which we are a party; if it is necessary to protect our rights, property or the safety of our customers or Website users.

    3. You consent to the disclosure of your personal information to such overseas entities.

  1. MANAGEMENT OF DATA

    1. We will only use information collected about you in accordance with the Data Protection Act 1998 and the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

    2. By submitting your information you agree to our use of data about you as described in this privacy policy.

    3. If you believe we have information about you that you do not want us to have or that you think is incorrect, please contact us.

    4. Although we will do our best to protect your personal data from misuse, interference and loss and from unauthorised access, modification or disclosure, we cannot guarantee the security of data transmitted to the Service. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

  1. COOKIES AND OTHER TRACKING TECHNOLOGY

    1. We use ‘cookies’ and similar technologies on the Service. Cookies are small computer files which the Service may store and/or access in your internet browser, enabling information to be transmitted to and from your internet browser and the Service. Cookies may also be stored in your internet browser by or on behalf of third parties, such as Google, Facebook, or providers of advertising services.

    2. Cookies enable us to record anonymous information about you, including: the type of internet browser you use to access the Service, your computer operating system, the websites you visited before visiting the Service, the areas of the Service you visit and your IP address (which can provide information about your approximate geographic location). Cookies cannot be used to disclose your individual identity.

    3. We use cookies in order to:

      1. learn about how the Service is being used and which types of individuals are using the Service

      2. record and report user profile, behaviour, location, audience, demographic and interest data

      3. record which other websites have referred users to the Service

      4. optimise the Service and improve our services

      5. make it easier for you to fill in forms on the Service and remember the information you have submitted to the form

      6. enable the Service to remember your preferences

      7. enable aspects of the Service to be customised; and

      8. provide relevant advertising.

    4. We will retain information received from our use of cookies for up to one year.

    5. For more information about cookies, please visit allaboutcookies.org. If you do not wish for us to use cookies when you use the Service, please adjust your Internet browser settings to decline cookies (your computer’s help file should tell you how to do this). If you choose to decline cookies, some parts of the Service may not work properly. By using the Service, you agree to our use of cookies as described above.

    6. If you want to learn about how to opt out of Google Analytics, please see visit https://tools.google.com/dlpage/gaoptout/ or your Google Ads Settings.

  1. MARKETING

    1. We give you a choice of whether or not you want us or other companies to contact you about offers, events, products and services that may interested you.

    2. We might send you marketing emails and/or push notifications about products or services which are similar to or related to the Service, or contact you by email with information about the Service. We will not send you any other marketing emails or pass your information on to third parties unless you give your consent or you have given it already.

    3. If you provide information about a friend/colleague of yours as part of a referral of that friend/colleague to us, we will send your friend/colleague a single email about the Service and we will store their personal information to the minimum extent necessary. When you provide us with your friend's/colleague’s information, you are confirming that you have their consent to this use of their information. We will tell your friend/colleague that you provided their details when we contact them.

  1. CHILDREN’S PRIVACY

    1. We request that, for all persons under 18 years of age, a parent or legal guardian consent to that person’s use of the Service and explain this privacy policy to them.

    2. All persons under the age of 13 must obtain the consent of their parent or legal guardian before using the Service or submitting any information to us.

    3. If a minor has provided us with personal information without the consent of his or her parent or legal guardian, such information may be removed by contacting us.

  1. DATA RETENTION

We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected.

  1. GENERAL

    1. If you follow a link from the Service to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to them.

    2. We may make changes to this privacy policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email or by putting a notice on the Service.

    3. All questions, comments or enquiries should be directed to us. We will try to respond to you within 48 hours. In accordance with applicable data protection law, you have a right to access, rectify and remove any of your data which are inaccurate, incomplete or outdated. You may exercise this right by contacting hello@hulah.com or write to Data Protection Officer, Yonder Travel Limited’s address below. We reserve the right to charge a reasonable fee at our standard rate for any requests for copies of personal data held by us.

YONDER TRAVEL LIMITED

Updated 1st April 2017

v.1.0