Summer Guide   

SG: +65 8197 1178

UAE: +971 56 338 7722

E: contact@holidaycourseguide.com

​​​​© 2019 All right reserved Summer Guide

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Data privacy and cookies

Summer Guides Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our website: www.holidaycourseguide.com  and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

 

Please read this Privacy & Cookies Policy carefully and ensure that you understand it. Your acceptance of the Cookies part of this Privacy & Cookies Policy will occur when you tick the consent box on our website and you acceptance of the privacy part of this Privacy & Cookies Policy is deemed to occur upon your first use of our website AND/OR You will be required to provide express consent by reading and accepting this Privacy & Cookies Policy when signing up for an Account or Subscription. If you do not accept and agree with this Privacy & Cookies Policy, you must stop using our website immediately. 

 

What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

What are your rights?

 

You have the following rights in relation to your personal data:

1. Right to access - the right to request (i) copies of the information we hold about you at any time, or (ii) that we modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this, unless your request is "manifestly unfounded or excessive." Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will tell you the reasons why.

2. Right to correct - the right to have your personal data rectified if it is inaccurate or incomplete.

3. Right to erase - the right to request that we delete or remove your personal data from our systems.

4. Right to restrict our use of your personal data - the right to "block" us from using your personal data or limit the way in which we can use it.

5. Right to data portability - the right to request that we move, copy or transfer your personal data.

6. Right to object - the right to object to our use of your personal data including where we use it for our legitimate interests.

 

To make inquiries exercise any of your rights set out above, or withdraw your consent to the processing of your personal data (where consent is our legal basis for processing your personal data), please contact us via this e-mail address: contact@holidaycourseguide.com

If you are not satisfied with the way a complaint you make in relation to your personal data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner's Office (ICO). The ICO's contact details can be found on their website at https://ico.org.uk/.

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 the period for which we hold it.

What kind of personal information does Summer Guide collect?

 

We can’t help you book the perfect Summer School course without information, so when you use our services there are certain pieces of information we ask for. This is pretty basic stuff – your name, preferred contact details, the names of anybody traveling with you, and your payment information. When you book a course, we also collect information for the schools that you are going to - such as your name, date of birth, and things like dietary requirements or allergies. We share this with the schools to help you have a great experience and make booking smooth You can decide to submit special requests for your upcoming Course (e.g. certain preferences). In addition to this, we also collect information from your computer, phone tablet or other devices you're using to access our services. This can include the IP address, the browser you're using, and your language settings. There are also situations when we receive information about you from others or automatically collect other information. For more information please contact us as set out below.

 

How does Summer Guide use your personal data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data which comprises consent, contract, legal obligation, and legitimate interests. More details on each lawful basis and examples of how we use your personal data under each basis are as follows:

 

Consent 

Where you have expressly provided your consent to receive communications from us such as newsletters, emails, marketing materials, news and events, new services, new products, and exclusive courses. Consenting to the use of non-essential cookies on our website is used to make your experience more seamless by, for example, but not limited to, remembering pages you have previously visited, products you have clicked on, automatically generated forms.

 

Contract 

Your personal data is necessary for us to administer the pre-purchase, purchase and contractual relationship between you and the Course Provider so that we may communicate with you about orders,  after-sales service, set up and manage accounts, complete purchases or payments, store and record your purchases and previous orders made via our website and keeping you updated with any changes in our terms and policies as well as offering you additional products, services, and benefits as a valued customer of ours.

 

Legitimate Interest 

Where you have provided your email address or other personal data to us, either online or offline, we may add you to our database for emails to contact you about new courses, news, and events, exclusive services. Certain personal data is also needed for legitimate purposes to prevent fraud, security breaches, legal violations, for us to help recommend products and services to you and to understand more about our customer and targeted customer base as well as to help our website to switch to the correct currency, language if applicable. We may also use the personal data collected under this lawful basis to help us analyze and administer, improve and update our website for a better experience, better products, and service we offer.

 

Legal Obligation

Certain personal data you provide us is necessary for us to fulfill our legal obligations as a business, for example, verifying parental responsibility, your age and appropriate use of our website, preventing fraud, security breaches and complying with our tax and accounting obligations where needed.

Personal data relating to children

 

Our website is not intended for use by anyone under the age of 18 but you may be required to provide certain personal data for your children in order to use and benefit from the services offered through our website. We will only ever collect personal data of children where we have a lawful basis which may be consent, contract, legitimate interest or legal obligation. Consent for the use of personal data of children under the age of 13 has to be provided by an adult who has parental responsibility for that child/children. We reserve the right to ask you for evidence that you have parental responsibility.  Any personal data relating to your children will be afforded the same rights as your personal data. Furthermore, We do not conduct any automatic user profiling with children’s personal data and our website is set up to have age-appropriate safeguards in place. Personal data of your children may be shared as set out below.

 

You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. 

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.


How does Summer Guide share your data with third parties?

 

There are different parties integrated into the Summer Guide services in various ways for various reasons. The main purpose is to share your data relevant for your Course with the Course Provider to complete your Course Reservation. There are also other parties that can receive some of your data, which are parties we involve to provide you with the Summer Guide services. These include financial institutions, payment providers, marketing companies, web developers, our apps, advertisers, venue hosting the Courses, accommodation companies, subsidiaries of the Summer Guide corporate family and other affiliates, social media channels, analytical cookies, website pixels, and cookies or in some cases if we are required by applicable law, governmental or other authorities. We do not sell or rent your personal data.  

 

Personal data collected by us may be stored and processed in your region, or in any other country where Summer Guide Ltd or its affiliates, subsidiaries or service providers maintain facilities. Alternatively, different storage locations may be chosen to operate efficiently, to improve performance, and to create redundancies to protect the personal data in the event of an outage or other problem. All data stored outside of the United Kingdom or the EEA will be processed in accordance with this Privacy Policy.

We may store or transfer some or all of your personal data in countries that are not part of the EEA. These are known as “third countries” and may not have data protection laws that are as strong as those in the UK and/or the EEA. This means that we will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We may use specific contracts with external third parties that are approved by the European Commission for the transfer of personal data to third countries. These contracts require the same levels of personal data protection that would apply under the Data Protection Legislation. More information is available from the European Commission (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en).

The security of your personal data is essential to us and to protect your data, we take a number of important technical and organisational measures, including the following:

• limiting access to your personal data to those employees, agents,  consultants, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality and aware of any obligations relating to the use of your personal data by them; and

• procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so.

 

 

How does Summer Guide process communications that you and your booked Course Provider might send to Summer Guide? 

 

Summer Guide can help you and Course Providers exchange information and requests about their services and existing Course Reservations, directing the communications through Summer Guide. If you want to find out more about how Summer Guide receives and handles these communications, read on here.  

 

How does Summer Guide use mobile devices? 

 

We offer free apps that we also collect and process personal data through. This works very much the same way as our website, but they also allow you to use our locations services.  

 

How can you control the personal data you've given to Summer Guide? 

 

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Even if we delete your personal data, it may still exist on backup or archival media for legal, tax or regulatory purposes.

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the Data Protection Officer. 

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 14 calendar days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress... 

 

Who's responsible for the processing of personal data on the Summer Guide website and apps? 

 

Summer Guide Ltd located in Oxford, UK controls the processing of personal data on its websites and mobile apps.  

 

How can you contact us?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of [insert name of Data Protection Officer]):

Email address: contact@holidaycourseguide.com

Telephone number:

 Postal Address: 

 

 

What's a cookie? 

 

A cookie is a small amount of data that is placed in the browser of your computer or on your mobile device. So-called “first-party cookies” (not as much fun as they sound) are cookies served by the entity operating the domain through which the cookie is served. Summer Guide’s own cookies are therefore “first-party cookies." In case we allow others to service cookies through the Summer Guide websites and apps, these cookies are so-called “third-party cookies." 

In addition, there's a difference between session Cookies and permanent cookies. Session cookies only exist until you close your browser. Permanent cookies have a longer lifespan and aren't automatically deleted when you close your browser. We strive to serve cookies or allow the serving of Cookies with a maximum lifespan of 5 years. Only in exceptional circumstances, like for security purposes and where absolutely necessary, will a Cookie have a longer lifespan than that. 

Other tracking technologies are used which are similar to cookies. These can include web beacons (also known as pixel tags, web bugs, or gifs), tracking URLs, or software development kits (SDKs). A web beacon is a tiny graphic image of just one pixel that can be delivered to your computer as part of a web page request in an app, in an advertisement, or in an HTML email message. Pixels can be used to retrieve info from your device, like your device type or operating system, IP address, and time of visit. They're also used to serve and read cookies in your browser. Tracking URLs are used to understand from what referring website the Summer Guide websites or apps are used. SDKs are small pieces of code included in apps that function like cookies and web beacons. 

All these technologies together are referred to in this Cookie Statement as “cookies." 

 

How are cookies used? 

 

Cookies are used for different purposes. They allow you to be recognized as the same user across the different pages of a website, between websites, or when you use an app. The types of info that we collect through cookies include IP address; device ID; viewed pages; browser type; browsing info; operating system; internet service provider; timestamp; whether you have responded to an advertisement; the referring URL; and features used or activities engaged in within the website/apps. 

 

Our website and apps use cookies for different purposes: 

Technical Cookies: We try to give our visitors an advanced, user-friendly website and apps that adapt automatically to their needs and wishes. To achieve this we use technical cookies to show you our website, to make them function correctly, to create your user account, to sign you in, and to manage your bookings. These technical cookies are absolutely necessary for our website to function properly. 

Functional Cookies: We also use functional cookies to remember your preferences and help you use our website and apps efficiently and effectively. If you're using the Summer Guide websites or apps to search for a Course, for example, these cookies remember your preferred currency, language, your searches, and your previously viewed Course Providers. We might also use cookies to remember your registration info so that you don’t have to retype your login credentials each time you visit our site. Passwords will, however, always be encrypted. These functional cookies aren't strictly necessary for the functioning of our website or apps, but they add functionality and enhance your Summer Guide experience. 

Analytics Cookies: We use these cookies to gain insight into how our visitors use Summer Guide. This means we can find out what works and what doesn't, optimize and improve our websites or apps, understand the effectiveness of advertisements and communications, and ensure we continue to be interesting and relevant. The data we gather can include which web pages you've viewed, which referring/exit pages you've entered and left from, which platform type you've used, which emails you've opened and acted upon, and date and time stamp info. 

It also means we can use details about how you interacted with the site, like the number of clicks you make on a given page, your mouse movements and scrolling activity, the search words you use, and the text you enter into various fields. We use analytics cookies as part of our online advertising campaigns to learn how users interact with our website or apps after they've been shown an online advertisement. This may include advertisements on third-party websites. Analytics cookies may also be used to enable our business partners to learn if their customers use accommodation offers integrated into their websites. 

Commercial Cookies: We use third-party cookies as well as our own to display personalized advertisements on our websites and on other websites. This is called “retargeting,” and it's based on browsing activities like the destinations you've been searching for, the accommodations you've viewed, and the prices you've been shown. 

 

What are your choices? 

To learn more about cookies and how to manage or delete them, just visit allaboutcookies.org and the help section of your browser. In the settings for browsers like Internet Explorer, Safari, Firefox or Chrome, you can set which cookies to accept and which to reject. Where you find these settings depends on your browser – use the "Help" function in your browser to locate the settings you need. 

 

The law states that we can store Cookies on your device if they are strictly necessary for the operation of our website. For all other types of Cookies we need your permission. [You can at any time change or withdraw your consent from the Cookie Declaration on our website [home page ].[Our Cookie Declaration also lists all the Cookies present on our website]]

By using our website, you may also receive certain third-party Cookies on your computer or device: (a) Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in, (b) Statistic Cookies help web application owners to understand how visitors interact with web apps by collecting and reporting information anonymously or (c)  Marketing Cookies are used to track visitors across different websites or applications. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Third-party Cookies are used on our website for analytics and SEO such as Facebook Ads These Cookies are not integral to the functioning of our website and your use and experience of our website will not be impaired by refusing consent to them. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our website, it does enable us to continually improve our website, making it a better and more useful experience for you.

Before non-essential Cookies are placed on your computer or device, you will be shown a pop-up screen requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of some or all of those Cookies; however certain features of our website may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies or choose which third party Cookies you are consenting to. Certain features of our website depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them.

If you decide not to accept certain technical and/or functional cookies, you might not be able to use some functions on our website. We currently don't support “Do Not Track” browser settings. In case a common standard has been developed that defines what exactly will be meant by “Do Not Track” browser signals, we'll review Cookie Statement again. 

Advertising: When it comes to online advertising and marketing companies, we strive to work with companies that are members of the Network Advertising Initiative (NAI) and/or the Interactive Advertising Bureau (IAB). Members of NAI and IAB adhere to industry standards and codes of conduct. NAI and IAB members allow you to opt out of behavioral advertising. Visit www.networkadvertising.org to identify the NAI members that may have placed an advertising cookie file on your computer. 

To opt out of an NAI member's behavioral advertising program, just check the box that corresponds to the company you want to opt out from. You can also visit www.youronlinechoices.com or www.youradchoices.com to learn how to opt out of customized advertisements. Your mobile device may allow you to limit the sharing of information for retargeting purposes through its settings. Be aware that opting out of an online advertising network doesn't mean that you will no longer receive or be subject to online advertising or marketing analysis. It just means the network you opted out of won't deliver ads customized to your web preferences and browsing patterns anymore. 

Analytics: In order to control the collection of data for analytical purposes through Google Analytics from certain browser types, visit the Google Analytics Opt-out Browser Add-on (for desktop only). 

If you have any questions, suggestions, or comments about this Cookie Statement, please contact us. Our Data Privacy and Cookie Statement may also be amended from time to time – so visit this page regularly to stay up to date. 

 

General

You may not transfer any of your rights under this Privacy & Cookies Policy to any other person. Subject to our website terms and conditions, anyone under the age of 18 should not use our website but in the event someone under the age of 18 uses our website and accepts this Privacy & Cookies Policy without parental responsibility consent or on another unauthorised basis, We shall not be liable for any breach of the Data Protection Legislation relating to the personal data We collect as a result of such use. We may transfer our rights under this Privacy & Cookies Policy where we reasonably believe your rights will not be affected.

If any court or competent authority finds that any provision of this Privacy & Cookies Policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this Privacy & Cookies Policy will not be affected.

Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

This Privacy & Cookies Policy will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

 

Changes to this Privacy & Cookies Policy

We may change this Privacy & Cookies Policy  from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our website and you will be deemed to have accepted the terms of the Privacy & Cookies Policy on your first use of our website following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy & Cookies Policy was last updated on 2 October 2019.