What is personal information?
Personal information is information or an opinion, in any form (whether true or not) about an individual whose identity is apparent or can reasonably be ascertained from the information or opinion.
How do we collect personal information?
Where practical we will collect personal information directly from you. Generally this will be collected by us when you deal with us either in person, by telephone, letter, facsimile, email or when you use our website(s), apps, links to or from our website(s)/apps, connect with us via social media and any other engagement we or our business partners have with you. We may request information about you when you purchase or make enquires about tickets or other products and services; when you enter competitions, register for promotions or when you request brochures or other information. We may also collect information when we invite you to complete surveys or provide us with feedback.
What personal information do we collect?
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to provide travel services and products to you. For example, we may collect details such as your name, mailing address, telephone number, email address, credit card number and expiry date, passport details, dietary requirements (if any) and health issues relevant to your travel arrangements. We also collect information that is required for use in the business activities of FCm Travel Solutions, including for example, financial details necessary in order to process various transactions and any other information you may elect to provide to us.
We will assume that you have consented to the collection of all information which is provided to us for use in accordance with this Policy, unless you tell us otherwise.
We are required by law to obtain your consent to the collection of sensitive information, as defined in the Data Protection Acts 1988 and 2003 (“the Acts”) (including information in relation to religion, race, or health conditions).
How do we use personal information?
We will use your personal information to provide you with travel and travel related products and services.
We may use and disclose your personal information for the purposes for which it was collected, or for a related or ancillary purpose such as any one or more of the following purposes:
- Identification of fraud or error;
- Regulatory reporting and compliance;
- Developing, improving and marketing our products and services;
- Servicing our relationship with you by, among other things, providing updates on promotions and services we think may interest you or to involve you in market research, having obtained your prior consent to your receiving such updates; and
- Internal accounting and administration.
It is our policy not to use or share the personal information about individuals in ways unrelated to the ones described above without also providing you an opportunity to opt out or otherwise prohibit such unrelated uses.
Is the information disclosed to third parties?
We may disclose your personal information:
- as permitted or required by law;
- to various regulatory bodies and law enforcement officials and agencies to protect against fraud and for related security purposes;
- to our third party service providers as well as to our related entities;
- to third parties such as airlines, hotels, car rental companies and other service providers for the purpose for which the information was collected or for a related purpose, for example to facilitate and process your travel arrangements.
Where we engage third party contractors to perform services for us those third party contractors may be required to handle your personal information. Under these circumstances those third party contractors must safeguard this information and must only use it for the purposes for which it was supplied, although we are not responsible for ensuring this.
Other than the above, we will not disclose your personal information without your consent unless disclosure is either necessary to prevent a threat to life or health, authorised or required by law, reasonably necessary to enforce the law or necessary to investigate a suspected unlawful activity.
Trans-Border data flows
The information (including personal information such as special needs, dietary or religious requirements) which you provide to us will be passed on only to the relevant suppliers of your travel arrangements or other persons necessary for the provision of your travel arrangements, such as public authorities, customs or immigration if required by them, or as required by law. Your information may also be passed on to security or credit checking companies. Under US law and in accordance with an International Agreement between the EU and the US the US Department of Homeland Security (DHS) will receive certain travel and reservation data (PNR) about passengers flying between the EU and the US. DHS has undertaken that it uses this information primarily for the purposes of preventing and combating terrorism and other transnational serious crimes. These and other data may also be used for checking against lists of passengers raising aviation security concerns. The PNR will be retained for at least three years and six months and may be shared with other authorities. Further information can be obtained from us or your airline. In addition to the US a number of other countries including Spain and Japan require that this information will provided to its Customs and Border Protection Authorities for the purposes of preventing and combating terrorism and other transnational serious crimes. If you travel outside the European Economic Area, controls on data protection may not be as strong as the legal requirements in this country. If we cannot pass this information to the relevant suppliers, whether in the EEA or not, we may be unable to proceed with your booking. In making this booking, you consent to this information being passed on to the relevant persons.
Retention of Information
We also make reasonable efforts, including carrying out periodic reviews of the data we retain, to ensure that we only retain personal information only for so long as is necessary for our services and to fulfil our contractual obligations or for employment matters in relation to our employees and job applicants or until we receive a request from you that the information be deleted.
Security of information
FCm Travel Solutions has implemented appropriate physical, electronic and managerial security procedures in order to protect personal information under our sole control from loss, misuse, alteration or destruction. We regularly review security and encryption technologies and will strive to protect information to the fullest extent possible. Access is restricted to employees who have a “need to know,” and those employees must use passwords to access the personal information.
Access and correction of personal information
Under the Acts you have a right of access to the personal information we hold about you. If you wish to exercise this right, please submit a Data Subject Access Request in writing to:
Data Protection Manager
FCm Travel Solutions
43-45 Middle Abbey Street
Requests by telephone, fax, or e-mail cannot be accepted.
In accordance with the Act(s), FCm Travel Solutions is not obliged to comply with your request unless sufficient security information is provided to establish the requestor's identity, and locate the appropriate information.
Please enclose the following with your request:
- A photocopy of your passport, or any other official document upon which your signature is present;
- Details of any purchases you have made from FCm Travel Solutions;
- Details of any specific documents you require that contain your personal details (if known).
You will receive an acknowledgement of your request quoting the date by which you will receive your information pack.
Further correspondence regarding your request should only be made in writing to the Data Protection Manager at the above address.
We may recover from you any additional reasonable costs of supplying you with access to this information.
We will take reasonable steps to ensure that personal information we receive from you is reliable for its intended use, accurate, complete, and current, including providing mechanisms by which you can amend or update your personal information. We will update your information whenever we get the opportunity to keep it current, accurate and complete.
Should you no longer wish to receive information on promotions and services we think may be of interest to you or participate in market research, kindly advise your Account Manager.
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At times we may share comments and feedback via our social media channels. Permission to use your information will always be requested prior to this occurring.
FCm Travel Solutions has partnered with reputable third parties to offer our site visitors a variety of products and services. This means that our website may contain links to, or framing of, external web sites. Although we only work with reputable third parties, our business partners may have different privacy policies and practices than us. We are not responsible for the privacy practices or the content of such sites and therefore, make no warranties and accept no liability in relation to material contained on these. We encourage you to read the privacy statements of any linked or framed web site before submitting any personal information.
Feedback / Complaints
We welcome your inquiries or comments about our Policy. Should you have any comments or complaints please contact your Account Manager or the Data Protection Manager at the address included above.
Changes to our Policy
From time to time it may be necessary for us to review and revise this Policy. We reserve the right to change our Policy at any time, should this occur the amendment would be posted on our website.