Your privacy is important to us and we committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website from the UK and tell you about your privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how Kandoo Adventures collects and processes your personal data through your use of this website, including any data you may provide through this website when you book a trip, sign up to our marketing or provide a review of a trip.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Expedition Adventures Limited t/a Kandoo Adventures is the controller and responsible for your personal data (collectively referred to as "Kandoo Adventures", "we", "us" or "our" in this privacy notice).
We have after reviewing the data that we hold, taken the decision that we do not require a data protection officer (DPO). We have however, appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (set out below), please contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: Expedition Adventures Limited, t/a Kandoo Adventures (company number 7149227)
Name or title of data privacy manager: Rachel Miller
Email address: , firstname.lastname@example.org
, Postal address: Unit 8, Eden Rural Enterprise Centre, Redhills Lane, Redhills, Penrith, Cumbria, United Kingdom, CA11 0DT
Telephone number: +44 (0) 1283 499980
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk
). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of changes
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 your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We may collect Special Categories of Personal Data about you. This may include special requirements such as those relating to any disability or medical condition which may affect the chosen trip arrangements and any dietary restrictions which may disclose your religious beliefs. If we need any other personal details, we will tell you before we obtain them from you. We collect this information to provide you with our services, cater to your needs or act in your interest, and we are only prepared to accept Special Categories of Personal Data on the condition that we have your positive consent.
If you fail to provide personal data
Where we need to collect personal data by law, in order to understand if you are eligible to participate in a trip or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. Some of our trips require Participants to complete a medical form – climbing at high altitude is unsuitable for those with certain medical conditions. Understanding your medical needs and general wellbeing and fitness is essential for your safety and therefore we may refuse to provide a trip to you on that basis.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in a Booking Form or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
• book our products or services;
• subscribe to our deal offers or mailing lists;
• request marketing to be sent to you; or
• give us some feedback on a trip.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below :
• Technical Data from the following parties:
(a) analytics providers such as Google based outside the EU;
(b) advertising networks such as Google Ads, Yahoo Ads, pay per click advertisers such as Bing inside or outside the EU; and
(c) search information providers such as Google, Yahoo and Bing based inside and outside the EU.
• Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Secure Trading Limited based in the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
• Where we need to perform the contract we are about to enter into or have entered into with you.
• Our staff, customers and suppliers may take photographs and video footage of trips in progress, including pictures of our customers. These pictures may be used for social media updates and in future marketing materials and are stored physically and digitally.
• We need to pass on your personal details to the companies and organisations who need to know them so that your trip can be provided (for example your hotel, other supplier, credit/debit card company or bank). Such companies and organisations are often outside the European Union.
• With your insurers, their agents and medical staff to exchange relevant information and sensitive personal data with us in circumstances where we/they need to act on your behalf or in the interest of passengers or in an emergency.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
See below to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us
if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing). We would also like to store and use your personal details for future marketing and trip review purposes (for example, sending details of new features, trips or special offers which we think may be of interest to you, including by email). All details you give us in connection with your booking (including those relating to any disability or medical condition or your religious beliefs) will be kept by us but we will use only names and contact details for marketing purposes (unless you have indicated that you do not wish us to do so).
We will get your express opt-in consent before we share your personal data with any company outside the Kandoo Adventures group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a previous booking or trip with us.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
• External Third Parties as set out in the Glossary.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In the event of our insolvency we, or any appointed insolvency practitioner, may disclose your personal information to the Civil Aviation Authority (“CAA”), and/or the Association of British Travel Agents (“ABTA”) so that they can assess the status of your booking and advise you on the appropriate course of action under any scheme of financial protection. The CAA’s General Privacy Notice is at https://www.caa.co.uk/Our-work/About-us/General-privacy-notice/
ABTA’s Privacy Notice is at https://www.abta.com/privacy-notice
6. International transfers
Many of our external third parties are based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. For example, your hotel, our representatives/guides in location and local airlines or transportation providers.
Where you have requested a booking for travel arrangements which are located or otherwise due to be fulfilled outside the UK, we will have to transfer your personal data to the suppliers fulfilling or providing those travel arrangements outside the UK in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. Where we are unable to rely on one of the safeguards outlined below when transferring data to those suppliers outside the UK, we will rely on the derogation under Article 49 of the UK GDPR in order to transfer your personal data to countries outside the UK (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so. You also acknowledge that where your personal data is transferred outside the UK, controls on data protection may not be as wide as the legal requirements within the UK.
• For all other transfers of data, whenever your personal data is transferred outside the UK or the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the UK Government or the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK Government which give personal data the same protection it has in Europe and the UK.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK. Please see contact details above.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about your legal rights.
If you wish to exercise any of the rights set out above, please contact us
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Protection of vital interests means to protect your health or safety for example in an emergency.
External Third Parties
• Service providers acting as processors based outside of the UK who provide accommodation, guidance and supervision, medical assistance and travel provision.
• Professional advisers including lawyers, bankers, accountants and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
• HM Revenue & Customs, regulators and other authorities acting as processors based in the UK and outside the UK who require reporting of processing activities in certain circumstances such as tax or for the purposes of obtaining consents or visas.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.