Front9 Privacy Policy
We are committed to protecting your privacy. We appreciate that you do not want personal information you provide to us distributed indiscriminately so we have detailed in our Privacy Policy and Cookie Policy how we collect information, what we do with it, how it is protected and what controls you have over this
Who are we?
Front9 Travel is a trading name of Gruber 59 Limited. The website www.front9travel.com is operated by Gruber 59 Limited (we, us and our). For the purposes of the Data Protection Act 1998 and the General Data Protection Regulation we are the data controller.
Gruber 59 Limited operates under the following brands: Front 9 Travel, Sporting Highlights
This privacy policy covers how we handle consumer data within Gruber 59 Limited and on our websites.
What personal information will Gruber 59 Limited collect about me?
This privacy policy tells you:
The information we collect;
Why we collect it;
How long we store it;
Our legal basis for processing your personal data;
Who, if anyone, we disclose your personal data to;
Your rights and how you can see, update or delete your personal data.
To make it easy to understand what data we collect about you we have grouped this policy into how you and others get information from us/ interact with us:
Our digital services, including our websites;
Services we use to communicate such as social media;
Contacting us directly via email, phone and letter.
When you use our digital services
Website analytics
We use website log files, cookies and digital analytics (Google) to gather information about how people use this site www.front9travel.com.
We do not collect or store your personal information (e.g. your name or address) in our website analytics. However, we can recognise that behaviours belong to a single person. The information collected helps us investigate whether each website meets its users' needs as well as to evaluate how each website can be improved. We store information about what pages you visit, how long you are on the site, how you got here and what you clicked on.
Website log files collect your IP address, when you visited the site and the pages you visited. IP address is a numeric code assigned to a device based on your geographical location. For example, if you are in Birmingham your IP address will be the same as other users accessing the internet from Birmingham.
Cookies are small text files which are saved onto your computer by websites that you visit. Our use of cookies is integral to some of the services offered on our websites and we use others to personalise your website experience and to help us shape and grow our web-based services in the future. You can read more about how we use cookies in our Cookies Policy.
Digital analytics & DoubleClick
Digital analytics tools such as Google Analytics and DoubleClick may be used to record anonymous user's interaction with our websites. This data may then be used to retarget users through advertising on other websites, therefore an individual's behaviour on one of our websites may result in them being retargeted with advertising related to the pages they visited or actions they took on the site.
You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt out of our use of Analytics by visiting the Google Analytics opt-out page.
Remarketing / Remarketing Lists for Search Ads (RSLA)
Third party vendors, including Google, use cookies to serve ads based on a User's prior visits to Gruber 59 Limited websites.
We may also use cookies to serve ads based on a user's prior visits to our websites, as well as to develop remarketing lists for customised campaigns (Remarketing Lists for Search Ads).
Users may opt out of Gruber 59 Limited’s use of cookies by visiting the Google advertising opt-out page. In addition, you may also opt out of third party vendor's use of cookies by visiting the Network Advertising Initiative opt out page.
When you provide personal data
Enquiring about a holiday
You can request information or a holiday quotation by telephone, email or by completing a form online. We will collect your name, and contact details such as your email address, postal address and telephone number, as well as the details of your general or specific requirements. Our legal basis for processing is contract and we will retain the details for 4 years after your enquiry.
Our team will then use this information to help find you a holiday, to communicate options to you and for future marketing communications. You may ask us to stop providing details of holidays or offers at any point and the data will be deleted within a month
Booking a holiday
When you make a booking, we will collect information, including your name, email address, postal address and telephone number, and the names of other passengers on the booking. We may also need your credit/debit card details, passport number, and date of birth, and details of any special needs, health, medical, mobility or dietary requirements, etc. We process this data as part of our contract with you and we retain it in our secure database for 4 years after your last communication with us.
You are under no obligation to provide any such information. However, if you should choose to withhold requested information, we may not be able to process your booking or provide you with certain services.
When you provide us with the personal information of third parties, such as other passengers included in a booking you make, you must have the consent of each of those third parties to provide their personal information to us for the purposes set out in this Privacy Policy. By providing such information, you confirm that you have such consent.
We must pass your information to other relevant suppliers of your holiday arrangements such as airline and transport operators and accommodation providers. Your personal information may also be passed to travel agents, tour operators, government and security agencies and to the public authorities of any country in your itinerary, including immigration and customs authorities.
We will only pass on information relevant to the service. We will work with any suppliers to ensure that any data passed to them is adequately protected and adheres to the levels of privacy and data security practised by us.
Our team will also use the information to communicate the details your holiday with you and for future marketing communications. You can ask us to stop providing details of holidays or offers at any point and your details will be deleted from any marketing lists within a month.
Customer satisfaction surveys
We ask guests to complete a survey at the end of their holiday. This survey requests your contact details including your name, email address and postal address, plus your feedback on various aspects of your holiday. We use the information to measure the effectiveness of our service, and in responding to customer complaints.
We also use non-personal information for business, research and marketing purposes, for example:
Internal reports on the quality of our service and that of our suppliers;
Reports shared with our partner airline and transport operators, accommodation providers and tour operators;
Marketing literature using aggregated scores and quotes drawn from feedback about our services.
Our legal basis for processing is contract and we will retain the personal information securely for 4 years after you complete the form.
If you consent to future marketing, we will continue to process your data on that basis. We store this in a secure database for 4 years after your last communication with us unless you withdraw consent. If you withdraw consent it will be deleted within a month.
Email newsletters
We produce regular email newsletters detailing product news, deals and offers. To provide these newsletters, we request contact details including your name, email address and postal address.
We only collect this data when we have your consent and retain it on a secure database. We store this data for 4 years after your last communication with us unless you withdraw consent. If you withdraw consent it will be deleted within a month.
Entering a competition
When you enter a competition, we may collect your name, email address and postal address. You are also given the option to consent to future marketing from us. We process this data as part of our contract with you and we retain it for 2 months after the competition has closed.
However, if you consent to future marketing we will continue to process your data on that basis. We may use this data and other data we hold about you to tailor the communications we send and improve our service to you and others. We store this in a secure database for 4 years after your last communication with us unless you withdraw consent. If you withdraw consent it will be deleted within a month.
Complaints
When you make a complaint to us, you can do so via an email, telephone or letter. The complaint is logged on an internal system. Once a complaint has been logged on our system, a customer service team member will review and respond to it.
We will use the personal information we collect to process the complaint and to check on the level of service we provide. We may share your details with partner airline and transport operators, accommodation providers, tour operators and our legal partners.
By giving us your personal data, you consent to us processing it. We retain personal data obtained from complaints securely for 4 years and then confidentially destroy it.
Interacting with us on social media
When you use a social media platform to interact with us in public or by private message, details about how your personal information is held, is described within the relevant social media policy, such as Facebook or Twitter.
You can sign up for email newsletters, request a brochure or enter our competitions via social media, please see the ‘request brochures’, ‘email newsletters’ and ‘enter a competition’ sections above and the terms presented in the service at the point of sign-up.
When you contact us directly
When you phone us
We will only collect personal information that you consent to provide to us in order to deliver a service.
When you email us
When you contact us via email, we will retain your email and our response to it for as long as the business issue remains. After this, the information will be confidentially destroyed.
When you write to us
When you contact us via post, we will retain your letter/postal address/personal information and our response to it for as long as the business issue remains. After this, the information will be confidentially destroyed.
When we contact you
We may email you regarding a contract or service or in response to a request, you have made. Your data will be stored for the purpose and time required to fulfil this.
If you book a holiday with us we will email you with information about your holiday and with emails promoting our products and offers. The legal basis for this is our contract with you. You can ask us to stop providing details of holidays or offers at any point and your details will be deleted from any marketing lists within a month.
If you have not booked a holiday with us, we will only send emails to you promoting our products and offers where we have your consent. However, if you subscribed to receive information via email before May 2018, you have not asked us to stop and you have engaged with the content recently we will continue to contact you. The legal basis for this is legitimate interest.
We store your data in a secure database for 4 years after your last communication with us, unless you withdraw consent. If you withdraw consent, we will delete your data within a month.
Post
Occasionally we send brochures or information about our products and offers by post.
If you book a holiday with us, the legal basis for this is our contract with you. You can ask us to stop sending details of holidays or offers at any point and your details will be deleted from our marketing lists within a month.
If you have not booked a holiday with us, we will only send marketing emails to you promoting our products and offers where we have your consent. However, if you subscribed to receive information before May 2018, you have not asked us to stop and we believe the information will be of interest to you, we will continue to contact you. The legal basis for this is legitimate interest.
We store your data in a secure database for 4 years after your last communication with us unless you withdraw consent. If you withdraw consent, we will delete your data within a month.
We use a third-party provider to print and send information by post. They store your personal data for 3 months after it has been sent.
Your rights
Under the General Data Protection Regulations, you have rights as an individual which you can exercise in relation to the information we hold about you. Read more about your individual rights on the Information Commissioner's Office website.
Access to personal information
We try to be as open as we can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making a 'right of access' request under the General Data Protection Regulations. If we do hold information about you, we will:
Give you a description of it;
Tell you why we are holding it;
Tell you who it could be disclosed to; and
Let you have a copy of the information in an intelligible form.
Opting out of marketing communications
You can withdraw your consent to us processing your information for Marketing purposes at any time. You can do this at the time you give us your information, by clicking on the “unsubscribe” link in an email we send you, by emailing us at info@front9travel.com or by writing to: Data Protection Manager, Front 9 Travel Limited, 20 Broadbridge Lane, Smallfield, Horley, Surrey RH6 9RE.
Links to other websites
This privacy policy does not cover the links within this site linking to other websites. We encourage you to read the privacy statements on the other websites you visit.
Changes to this privacy policy
We keep our privacy notice under regular review. This privacy notice was last updated on 18 May 2018.
Since this policy is under regular review, you may wish to check it each time you submit personal information. If you do not agree to these changes, please do not continue to use this website to submit personal information. If material changes are made to the Privacy Policy, for instance affecting how we would like to use your personal information, we will provide a more prominent notice.
You can access this policy at any time through the link at the bottom of our website and in any email newsletter we send you.
How to contact us
Any requests for information about how we store and process personal information we hold should be sent to info@front9travel.com or write to: Data Protection Manager, Front 9 Travel Limited, 20 Broadbridge Lane, Smallfield, Horley, Surrey RH6 9RE.