PRIVACY STATEMENT

Introduction

This document refers to personal data, this is defined as information concerning any living person (a natural person who hereafter will be called the Data Subject) that is not already in the public domain.

The General Data Protection Regulation (GDPR) seeks to protect and enhance the rights of data subjects. GDPR together with The Privacy and Electronic Communications Regulations (PECR) covers the safeguarding of personal data, protection against the unlawful processing of personal data and the unrestricted movement of personal data within the EU. It should be noted that GDPR does not apply to information already in the public domain such as Companies House data.

OTT Group Limited (OTT) is committed to ensuring that your privacy is protected and is pleased to provide the following GDPR information:

Who we are

OTT is a leading provider of B2B product training and B2B marketing services for the travel industry.

Personal Data

OTT uses the information collected about you from email enquiries including forms, surveys and phone calls, to provide quotations, make telephone contact and to email you course information which the trainer believes may be of interest to you and/or your business. In making initial contact you consent to OTT maintaining a marketing dialogue with you until you either opt out (which you can do at any stage) or we decide to desist in promoting our services.

Some personal data may also be collected when you visit the OTT website, including but not limited to personally identifying information like Internet Protocol (IP) addresses. OTT may from time to time use such information to identify its visitors. OTT may also collect statistics about the behaviour of visitors to its website. Information concerning the firm’s cookie policy can be found further below.

Other information held about you could include any sales transactions including any third-party information we have obtained about you from public sources and our own suppliers such as credit referencing agencies.

What we collect

We may collect the following information: name, job title, contact information including email address, demographic information such as preferences and interests, and other information relevant to customer surveys and/or offers. OTT will only collect the information needed so that it can provide you with training services such as courses.

OTT will also share your personal profile details comprising your full name, country/city/state of residence, date registered with OTT, preffered language, employment status, company name, agency ID, job title, courses completed and sectors of interest with OTT’s third party travel industry providers but it does not share emails. Third party travel industry providers can email you through the OTT platform but they cannot download your email address outside of the OTT platform.

What OTT does with the information it gathers

OTT requires this information to understand your needs and provide you with a quality training service, and also for the following reasons: internal record keeping, to periodically send promotional emails about new products, special offers or other information which OTT and/or third party travel industry providers believe you may find interesting using the email address which you have provided.

Occasionally OTT may also use your information to contact you for market research purposes. OTT may contact you by email, phone or post. OTT will also make your information available to its training providers for reporting purposes. Third party travel industry providers can also contact you through the OTT platform. Please also see legitimate interests. 

Legal basis for processing any personal data

To meet OTT’s contractual obligations to those engaging in courses and to also respond to marketing enquiries.

Legitimate interests pursued by OTT

OTT may use your personal information to send you promotional information to promote training courses including skills training and product training and to send you information about third party travel industry providers such as airlines, resorts, hotels, destinations and attractions, which it believes you may find interesting. As part of reporting, OTT will make your personal profile data and the name of the course you started and/or passed available to these third party travel providers. OTT will not share your email address with these third parties but will allow them to contact you through our OTT platform which is managed in the UK by OTT’s email service provider.  

Consent

You can withdraw your consent at any time by emailing accounts@ott.travel or by writing to us, see last section for full contact details.

Website

Information collected from the website include:

Details about the services you have contracted.

Information provided at the time of subscribing to the service and thereafter.

If you contact us, we may keep a record of that correspondence or communication.

Transaction details.

Other details of your visits to the OTT website including, but not limited to, traffic data, location data, weblogs and other communication data and the resources that you access from the site.

OTT may collect information about computers in your organisation which are used to access the site, including where available the IP address, operating system and browser type, for system administration. This is statistical data about our users' browsing actions and patterns, and does not identify any individual.

Website Cookies - These are small files that are downloaded onto a device when the user of that device accesses a website. Cookies allow a website to recognise a user's device.

The OTT site uses cookies in order to make it easier to use the www.onlinetraveltraining.com website pages and to help us to analyse the profile of visitors and users in order to improve the www.onlinetraveltraining.com experience. It will not use cookies to collect personally identifiable information about you. However, if you wish to restrict or block the cookies which are set by www.onlinetraveltraining.com, or indeed any other website, you can do this through your browser settings. The Help function within your browser should tell you how to do this.

The www.onlinetraveltraining.com website uses the following types of cookies:

Session cookies: these are used by the website to store information about user activities so users can easily move from one webpage to another. These cookies act as a sort of "bookmark" in that they track your movement from page to page of the website so that you do not have to provide the same information you have previously given on other, earlier pages of the website. These are known as "session" cookies because they only remain in the cookie file of your browser until you close the browser.

Persistent cookies: these cookies are used to store user preferences in order to improve your experience of future visits to the website. For example, these cookies can remember log-in details or language preferences so that you do not have to continually re-enter these details on each visit to the Website. These cookies will remain in the cookie file of your browser after you have closed your browser, and will be activated again when you next visit the website. However, following 90 days of website inactivity these cookies will expire and will therefore be removed from your browser's cookie file.

You can always remove or block cookies (such as by using the settings in your browser), but it may affect your ability to use www.onlinetraveltraining.com.

For more information about cookies, including how to adjust your internet browser settings to reject cookies, you can visit the following website: http://www.allaboutcookies.org/

Credit cards

Where payment is submitted via the website 'checkout' pages, the processing of credit and debit cards is undertaken by Global Iris on behalf of OTT, through a secure hosted connection. No card data is stored by OTT for these purposes, or shared with any third parties. A copy of Global Iris’s full privacy policy can be found via: https://resourcecentre.globaliris.com/privacypolicy

Disclosure

OTT will share some of your personal profile details comprising your full name, country/city/state of residence, date registered with OTT, preferred language, employment status, company name, agency ID, job title, courses completed and sectors of interest with OTT’s third party travel partners. This information is shared as part of our reporting functionality and to support marketing. For the purposes of GDPR, these third party travel providers will be categorised as a data processor. OTT requires these parties to agree to process this information based on our written instructions and requirements, consistent with this Privacy Statement and GDPR. Some of these partners may be based outside the EEA. OTT’s third party travel providers can download these basic details, however email address details are not shared. Third party travel industry providers can download these basic details, however email address details are not shared. Third party travel industry providers are still able to send you marketing content but only through the OTT platform.

OTT’s third party travel providers can download your basic details, however email address details are not

OTT may be required to disclose your Personal Information to meet legal obligations, regulations or valid governmental request. The trainer may also enforce its Terms and Conditions, including investigating potential violations of its Terms and Conditions to detect, prevent or mitigate fraud or security or technical issues; or to protect against imminent harm to the rights, property or safety of OTT, its clients, intellectual property and/or the wider community.

Security

OTT is committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Retention Policy

OTT will process personal data during the duration of any contract and will continue to store only the personal data needed for six years after the contract has expired to meet any legal obligations. After six years any personal data not needed will be deleted. 

Data storage

Data is held within the EEA using different (multiple) servers. OTT does not store personal data outside the EEA. 

Your rights as a data subject

At any point whilst OTT is in possession of or processing your personal data, all data subjects have the following rights: 

• Right of access – you have the right to request a copy of the information that we hold about you.
• Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
• Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records.
• Right to restriction of processing – where certain conditions apply you have a right to restrict the processing.
• Right of portability – you have the right to have the data we hold about you transferred to another organisation.
• Right to object – you have the right to object to certain types of processing such as direct marketing.
• Right to object to automated processing, including profiling – you also have the right not to be subject to the legal effects of automated processing or profiling. 

In the event that OTT refuses your request under rights of access, we will provide you with a reason as to why, which you have the right to legally challenge. 

OTT at your request can confirm what information it holds about you and how it is processed. 

You can request the following information:

• Identity and the contact details of the person or organisation (OTT) that has determined how and why to process your data.
• Contact details of the data protection officer, where applicable.
• The purpose of the processing as well as the legal basis for processing.
• If the processing is based on the legitimate interests of OTT, information about those interests.
• The categories of personal data collected, stored and processed.
• Recipient(s) or categories of recipients that the data is/will be disclosed to.
• How long the data will be stored.
• Details of your rights to correct, erase, restrict or object to such processing.
• Information about your right to withdraw consent at any time.
• How to lodge a complaint with the supervisory authority (ICO).
• Whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether you are obliged to provide the personal data and the possible consequences of failing to provide such data.
• The source of personal data if it wasn’t collected directly from you.
• Any details and information of automated decision making, such as profiling, and any meaningful information about the logic involved, as well as the significance and expected consequences of such processing. 

To access what personal data is held, identification will be required

OTT will accept the following forms of ID when information on your personal data is requested: a copy of your driving licence, passport, birth certificate and a utility bill not older than three months. A minimum of one piece of photographic ID listed above and a supporting document is required. If OTT is dissatisfied with the quality, further information may be sought before personal data can be released. 

All requests should be made to accounts@ott.travel or writing to us at the address further below. 

Complaints

In the event that you wish to make a complaint about how your personal data is being processed by OTT or its partners, you have the right to complain to OTT’s managing director. If you do not get a response within 30 days you can complain to the ICO. 

The details for each of these contacts are: 

OTT Group Limited, attention of the Managing Director

3rd Floor, 52 Grosvenor Gardens,
London, SW1W 0AU
United Kingdom

Email: accounts@ott.travel 

ICO

Wycliffe House, Water Lane, Wilmslow, SK9 5AF

Email: https://ico.org.uk/global/contact-us/email/ 

OTT Group Ltd may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from April 10 2018.