Privacy Policy

Acorn Travel Group Ltd. is committed to protecting and respecting your privacy.

1. OUR APPROACH TO PRIVACY

1.1 This Privacy Policy sets out how we collect, store, process, transfer, share and use data that identifies or is associated with you ("personal information") when you:

1.1.1 make use of our websites at https://www.acorntravelgroup.com/, https://www.acornadventure.co.uk/, https://www.theschooltravelcompany.com/ and https://acornfamilyholidays.co.uk/ or variations thereof (the “Website”);

1.1.2 make a booking with us;

1.1.3 use our services; or

1.1.4 otherwise interact with us.

1.2 For the purposes of relevant data protection laws (including each of the EU and UK General Data Protection Regulation (EU/UK GDPR), the Acorn entity with whom you contract will be the primary controller of your personal data (for example, if you are a visitor to our website and sign up to purchase one of our trips, the Acorn entity operating the relevant website or trip; or you are a supplier or travel agent, the Acorn entity to whom you provide services).

1.3 It also explains your rights in relation to your personal information and how to contact us or the relevant regulator in the event you have a complaint. We want to make sure you can make informed decisions, so please take a few moments to read the sections below and learn how we may use your personal information.

2. ABOUT US

2.1 References to “Acorn”, “Acorn Group”, “we”, “our” and “us” means Acorn Travel Group Ltd. (trading as Acorn Adventure, Acorn Family Holidays and The School Travel Company) and each of our affiliates forming part of our group, including School Trips Ltd.

2.2 Acorn Group Travel Ltd., a private limited company incorporated in England and Wales (company no. 07691077) is the data controller of the personal information we hold about you. Our registered and postal address is 22 Worcester Street, Stourbridge, DY8 1AN, England.

2.3 We are registered as a data controller with the Information Commissioner’s Office under data protection registration number ZA191948.

2.4 You should read this Privacy Policy in conjunction with our Cookies Policy and the Website Terms and Conditions of Use.

3. PERSONAL INFORMATION WE COLLECT ABOUT YOU AND HOW WE USE IT

3.1 When you submit an enquiry through a contact form on our Website or contact us over the telephone via one of our agents, you may need to provide certain information such as your name, address, email, phone number and (if you make a booking), payment information as well as sensitive categories of data.

3.2 We use your personal information and financial and other information you provide to make the booking requested by you. Where necessary, we will use your personal information to access your bookings so that we can view, manage and make any changes to your booking, and give you notice of any cancellations or changes. Where there have been cancellations, we use your information to process and manage refund requests.

3.3 We will also need to monitor the status of (and handle correspondence in connection with) your bookings, for example, to deal with, monitor and send on to you communications from relevant third parties relating to any rescheduling or other changes.

3.4 The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information.

3.5 More generally, we:

3.5.1 collect personal information that you voluntarily submit to us, such as your name and contact details, when you register with us, use our Website, or otherwise interact with us in the course of our business activities.

3.5.2 collect personal information about you from third parties, such as public databases (where permitted by law) and our advertising and marketing partners.

3.5.3 collect personal information that you voluntarily submit to us and/or generated as part of our business activities, which may also be disclosed to third parties in connection with your booking; and

3.5.4 may also collect certain personal information automatically, including in relation to how you access and use the Website, technical information regarding the device you use to access the Website and the way in which you interact with our newsletters (such as whether you open these).

3.6 We also automatically record telephone calls when you contact our customer services team by phone for the following reasons:

• as a record of what was agreed or included;

• quality control: to make sure our customer service staff are responding appropriately and following our processes;

• analytics: to understand the nature and volume of calls to better manage Customer Services, and to be alerted to any serious or repeated issues;

• staff training; and

• to protect us of there is a legal dispute.

We keep the call recordings only for a limited period, and on our own internal systems, and then automatically delete them, unless we’ve got a legitimate interest in keeping them for a longer period and that is not overridden by your rights.

3.7 We use the information we collect about you to correspond with you, perform our agreements with you, comply with our regulatory responsibilities (such as Know Your Client and anti-money laundering requirements), carry out marketing activities and our day-to-day business activities and operations.

3.8 We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.

3.9 We will indicate to you where the provision of certain personal information is required in order for us to provide you certain services. If you choose not to provide such personal information, we may not be able to provide the services you have requested.

4. SENSITIVE PERSONAL DATA

4.1 You may provide us with (or another person on your behalf may provide us with) sensitive personal information about:

• your health (including with respect to any mental or physical health condition that may be relevant for your booking or query);

• your sexual orientation (such as to enquire about a particular destination);

• your religion (by disclosing any religious dietary requirements you may have).

4.2 By providing us with this information you are agreeing to our use of it to provide what you have requested. This includes providing information to service providers where needed, such as to arrange assistance at the airport.

4.3 Where another person has provided that information to us on your behalf, it is their responsibility to get your consent to do so.

5. ANONYMOUS DATA

5.1 We may anonymise and aggregate any of the personal information we collect about you (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving our Website and developing new products and features. We may also share such anonymised information with others.

6. DATA RETENTION

6.1 We will store the personal information we collect about you for no longer than necessary for the purposes set out in Annex 1 in accordance with our legal obligations and legitimate business interests.

6.2 To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, as well as the applicable legal, regulatory, tax, accounting or other requirements.

7. RECIPIENTS OF PERSONAL INFORMATION

7.1 We may share your personal information with the following categories of recipients (as required in accordance with the uses set out in Annex 1):

7.1.1 Business partners and suppliers: we may share your personal information (such as contact details), and sensitive personal data (such as in relation to a health condition or dietary requirements) with our business partners and the suppliers providing the relevant services, where this is necessary in the normal course of our business or to provide you with your booking.

7.1.2 Our service providers: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment processing, banking, payment gateway, marketing, courier, web hosting, fraud monitoring and/or prevention, online advertising and analytics services.

7.1.3 Issuing banks: we share certain of your personal data with our issuing banks in order that they can monitor our compliance with our regulatory obligations.

7.1.4 Professional advisors: we may share your personal information with our lawyers, accountants, insurers and other professional advisors to the extent we need to (for example, to defend ourselves against legal claims).

7.1.5 Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties (including a new owner) in connection with a business or corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.

7.1.6 Law enforcement, regulators, governmental and other relevant authorities: We may need to share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of our users or others. As required by law.

7.1.7 Other group companies: we may disclose your personal information to companies within our group of companies where they provide services on our behalf or where such sharing is otherwise necessary in accordance with the uses set out in Annex 1.

8. MARKETING AND ADVERTISING

8.1 From time to time, we may contact you with information about the Website. We may also send you information regarding our other products and services, updates, offers, discounts and similar marketing (including related products and services of our partners) which we believe you may be interested in. We may also ask for your feedback on our products and services.

8.2 Most marketing messages we send will be by email. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you.

8.3 We will only send you marketing messages if you have given us your consent to do so, unless consent is not required under applicable law or if you are an existing customer and have not opted out of receiving marketing. Where you provide consent, you can withdraw your consent at any time, but without affecting the lawfulness of our processing based on consent before its withdrawal. In any case, you have the right to opt out of receiving electronic marketing communications from us by:

• clicking on the ‘unsubscribe’ link at the bottom of our marketing communication

• replying to an email marketing message with a request to be unsubscribed

• by contacting our Customer Service Team (contact details are provided at the end of this Privacy Policy)

8.4 When you do any of the above, we will update your details so you don’t receive any more marketing messages. While we update your details as quickly as possible, please allow for up to 2 business days for this to take effect.

8.5 Please note that unsubscribing from marketing messages will not stop service communications such as updates (such as to this Privacy Policy).

9. STORING AND TRANSFERRING YOUR PERSONAL INFORMATION

9.1 Security. We implement appropriate technical and organisational measures, including encryption, to protect your personal information against accidental or unlawful destruction, loss, change or damage. All personal information we collect will be stored on our secure servers. We will never send you unsolicited emails or contact you by phone requesting your bank account details or national identification numbers.

9.2 International Transfers of your Personal Information. Due to the nature of our business, the personal information we collect may be transferred to and stored in countries outside of the UK where our third-party service providers have operations, or to overseas suppliers where your booking is for a country outside the UK. These international transfers of your personal information will be made pursuant to appropriate safeguards in accordance with data protection legislation. If you wish to enquire further about the safeguards used, please contact us using the details set out at the end of this Privacy Policy.

10. YOUR RIGHTS IN RESPECT OF YOUR PERSONAL INFORMATION

10.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

10.1.1 Right of access. You have the right to obtain access to your personal information.

10.1.2 ight of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

10.1.3 Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

10.1.4 Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

10.1.5 Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

10.1.6 Right to object. You have a right to object to any processing based on our legitimate interests in certain circumstances. You can also object to our direct marketing activities for any reason by clicking the “unsubscribe” link set out in any marketing communication you receive.

10.1.7 Right to withdraw consent. If you have provided consent to any processing of your personal information, you have a right to withdraw that consent.

10.1.8 Right to complain. We would ask that you contact us to seek to resolve the concern or complaint in the first instance. If you have any concerns or complaints about how we are collecting or processing your personal information, you have the right to lodge a complaint with the supervisory authority responsible for data protection in the country you live in or the place of the alleged infringement. You can find a list of the supervisory authorities within the EU here: https://www.edpb.europa.eu/about-edpb/about-edpb/members_en#member-at. In the UK, the relevant supervisory authority is the Information Commissioner’s Office and their details are available at www.ico.org.uk.

10.2 How to exercise your rights

10.2.1 Please note that the above rights are not absolute and we may be entitled to refuse requests, wholly or partly, where exceptions under the applicable law apply.

10.2.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

10.2.3 Please quote your name and address. If you are submitting a request for access to your personal information, we would be grateful if could also provide brief details of what information you want a copy of (this helps us to more readily locate your data).

10.2.4 We will take all reasonable steps to confirm your identity before providing you with details of any personal information we may hold about you.

11. COOKIES AND SIMILAR TECHNOLOGIES

11.1 Our Website uses cookies and similar technologies to distinguish you from other users of our Website. Please refer to our Cookies Policy for more information as to the way in which we use cookies on our Service.

12. LINKS TO THIRD PARTY SITES

12.1 Our Website may, from time to time, contain links to and from third party websites, including those of our business partners, advertisers, news publications and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

13. CHANGES TO THIS POLICY

13.1 We may update this Privacy Policy from time to time and so you should review this page periodically. If there are any significant changes we will make these clear either through the Website or through another means of contact such as email. We will also update the "last modified" date at the end of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page.

14. NOTICE TO YOU

14.1 If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on our Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this Privacy Policy.

15. CONTACTING US

15.1 If you have any questions, comments and requests regarding this Privacy Policy, you can contact us:

15.1.1 By post: Acorn Adventure, 22 Worcester Street, Stourbridge, DY8 1AN, England.

15.1.2 By email: info@acorntravelgroup.com

This Privacy Policy was last modified on August 2024.

Category of personal data	Purpose of Processing	Lawful basis for processing
Identity, Contact	Managing our relationship with you (asking you to take a survey and informing you about changes to our policies, other terms, and other administrative information).	(a) This is necessary for the performance of our contract with you. (b) This is necessary for our legitimate interests to manage our relationship with our users and keep them updated.
Identity, Contact, Financial, Marketing and Communications	To process and deliver your booking, including: (a) Manage payments, fees and charges; and (b) Collect and recover money owed to us.	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us)
Identity, Contact, Marketing and Communications	To manage our relationship with you which will include: (a) responding to queries and complaints; (b) provide you with information and materials that you request from us; and (c) notifying you about changes to our terms or privacy policy.	(a) Performance of a contract with you. (b) Necessary to comply with a legal obligation. (c) Necessary for our legitimate interests to respond to your queries and provide any information and materials requested in order to maintain good customer relations.
Identity, Marketing and Communications (including marketing and notification preferences), Contact and Website History	To send you marketing and promotional content (including sending you newsletters and measuring the effectiveness of our marketing)	Consent   Where consent is not required under applicable law (for example, where you are an existing customer or have not opted out of receiving our marketing communications) such processing is necessary in our legitimate interests to promote, develop and grow our business.
Identity, Contact, Technical	To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).	(a) It is necessary for our legitimate interests to monitor our Website and services, to improve their performance and to ensure that they function properly and are secure. (b) Necessary to comply with a legal obligation
Identity, Contact, Technical	To protect the security of systems and data.	It is necessary for our legitimate interests to protect network, systems and data and to prevent and detect criminal activity (such as fraud) that could be damaging for you and/or us.
Identity, Contact, Technical, Usage, Marketing and Communications	To analyse your usage of the Website, including for the purposes of improving our Website and to ensure that content is presented in the most effective manner for you.	It is necessary for our legitimate interests to define types of users for our Website and services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy.
	To provide you with advertising aligned with your interests and to measure the effectiveness of such advertising.	Such processing is necessary in our legitimate interests to promote, develop and grow our business and to inform our marketing strategy.
Contact details (including name and phone number), telephone recordings	To record your calls with our customer services team to comply with applicable laws	Compliance with a legal obligation
Contact details (including name, email address and phone number)	Where you make an enquiry through our online platform, to pass your details on to our third-party supplier partners so that they can contact you in relation to your enquiry.	Performance of a contract
Contact details (including name, email address and phone number)	Where a business partner uploads a listing to our online platform, or otherwise uses the platform to advertise its services	Performance of a contract
Financial information, including card data (including card number, CVC etc.). Note that this information will be processed on our behalf by our payment processor – we do not have access to this information	To facilitate payment of your booking by debit or credit card	Performance of a contract
Financial information, including bank account details (including credit limit, account credentials, login preference and card preferences), contact details (including name and address), payment history and transaction data (including transaction history, purchase amounts etc.)	To provide you with our services	Performance of a contract
Sensitive personal information, including dietary requirements (which may disclose your religious beliefs), health conditions, data of birth, passport details, height, weight and gender.	To allow our third-party suppliers to provide you with your chosen arrangements and activities	Performance of a contract