THOMAS COOK respects your privacy.
WHO DOES THIS POLICY APPLY TO?
THOMAS COOK is understood to mean THOMAS COOK Belgium, being the following brand names which trade in Belgium: THOMAS COOK, NECKERMANN and PEGASE, hereafter referred to as ‘THOMAS COOK’. You can purchase THOMAS COOK travel services through THOMAS COOK’s travel agencies in Belgium, on the THOMAS COOK website, our call centre, or from third-party travel agencies. Accordingly, personal data are collected during your visits to those websites, call centres, travel agencies, apps or social media.
For THOMAS COOK, this concerns the following e-commerce websites:
In addition, THOMAS COOK has also the following informative websites:
Those websites include so-called social media buttons. The managers of these services use these to collect your personal data.
THOMAS COOK is active on the following social media: Facebook, Instagram, Twitter/Google+, Linkedin, Swarm, Foursquare, YouTube.
Depending on the type of holiday, TCRB NV (Flights and exotic holidays, cruises, flight only) or TCI AG (car hire, city trip, winter sports) will be responsible for processing the data you provide.
THOMAS COOK RETAIL BELGIUM nv, with registered office at B-9052 Gent, Tramstraat 67 C, VAT BE 412 677 887.
THOMAS COOK INTERNATIONAL AG, a company incorporated under Swiss law, headquarters in Switzerland, Postrasse 4, CH-8808 Pfafikkon, VAT CHE 278 995 865, with a branch in Liège, Boulevard de la Sauvennierre 54, KBO 0533 973 122.
Depending on your booking with THOMAS COOK, your data will be processed by one of the above companies.
In the case of a reservation/booking/purchase or submitting of your personal data, we will transfer, save or process your data as described in the following.
WHAT PERSONAL DATA ARE BEING COLLECTED AND HOW DO WE STORE THESE?
We collect personal data about you as (primary) booker and about any other person you include on your reservation. Read on to find out more.
Personal data you give to us:
- When you make a booking, or when you request a quote, we will ask you for your name, address, e-mail address, gender, telephone number, date of birth, and personal travel preferences as well as those from the people you are travelling with. We need to collect this information in order to arrange the travel and other services you are requesting.
- If you enter a competition organised by THOMAS COOK, or fill out a survey, or if you report a problem with any of our services, we will collect your name and relevant contact information.
- If you contact us, we may keep a record of your name, e-mail or other correspondence, and if you call us by telephone we may monitor and/or record phone conversations for training and customer-service purposes.
- When using our services, you make a holiday/travel search on our website or when you visit our travel agencies and you enter personal data, but do not make a booking, we could keep the data for a limited time.
To help us keep your data up to date, accurate and complete, please ensure you tell us if anything needs to be changed.
Personal data we collect:
Based on how you have used our services in the past and your activity on our website, social-media channels, or any contact you made with our contact centre or visits to our travel agencies, we collect the following data:
- Details of services we have provided to you, including your previous trips, such as holidays and other purchases and matters related to those arrangements, such as any complaints.
- We collect details of your visits to our sites and apps, such as e.g. traffic data, location data and weblogs, as is required for our own purposes or the resources you access. We use third-party technology services, such as 'Google Analytics’ or ‘Hotjar’ to administer those services. We have a working arrangement with Google, which provides a legal platform for the use of personal data. Furthermore, Google is not allowed to use the data of Analytics for other Google services. We have ensured your IP address is anonymised.
- We may collect information about your computer, tablet or mobile phone, including, where available, your IP address, operating system and browser type and this is done for so-called system administration purposes, marketing purposes and to report aggregate information to our advertisers. This information is statistical data about our users' browsing behaviour. These visitors cannot be identified and are anonymous.
- Videos taken by surveillance cameras at our offices.
Personal data obtained from other sources:
We may also receive your personal data from third-party sources who collect information about you on our behalf. This includes the following:
- If you tell a third party that you would like to receive marketing communications from THOMAS COOK, they will securely transfer your contact details and marketing preferences to us.
- If you book one of our holidays through a third-party travel agent, certain personal data will be passed to us in order to provide the services you have booked.
- If you complete any of our customer feedback questionnaires or surveys.
WHERE ARE YOUR DATA STORED AND WITH WHOM ARE THEY SHARED?
Your personal data are held in our own systems and in systems belonging to third parties, which we call upon to be able to offer our services to you. If you would like to learn more about this, read on here...
When you provide us with your personal data, some of your personal details will need to be passed to third-parties such as airlines, hotels or insurance companies, in order to ensure they can provide the services so that your needs will be met. Some of those third-parties may be based outside the European Economic Area (“EEA”). Organisations based outside the EEA may not be subject to the same level of rule of law concerning data protection that exists within Belgium and the EEA.
For some international travel, we may be required to disclose some of your personal data to government bodies or other authorities in Belgium or abroad, such as border control, security and anti-terrorism.
We may disclose your personal data if necessary to any member of our international group, which includes the above-mentioned THOMAS COOK associates. In order to facilitate the surveillance and prevention of fraudulent bookings or payments, we will hand over your personal data to the police and relevant judicial institutions.
We will only transfer your data outside the EEA if:
- (a) Your personal data is subject to one or more applicable safety measures. This can be in the form of model contract in a format approved by the authorities; and
- (b) The transfer is necessary in order to execute the contract we have with you.
HOW DO WE USE YOUR DATA WHEN PROVIDING SERVICES TO YOU?
We process your information because we need to fulfil the contract we have with you of because we have a legitimate reason for doing so, or to comply with legal obligations.
The following activities are carried out by us in order to provide you our services:
- Managing your booking, internal communicating relating to it and external communication with our suppliers, to ensure the services you have requested are arranged;
- To communicate with you regarding your reservation or purchase, including sending booking confirmation and travel documents;
We may use and process your personal data for activities which are justified in our line of business:
- To improve customer experience:
- (i) To allow you to participate in ‘interactive features’ of our sites and apps when you choose to do so. When using the THOMAS COOK MY HOLIDAY APP, you can choose not to use interactive features by changing your settings;
- (ii) To ensure that content from our sites, apps and booking systems is presented in the most effective way for you and your computer;
- (iii) To notify you of changes to our service;
- To protect our business against financial loss:
- i. For managing payments and if need be debt collection;
- ii. For payment card and booking verification (including the use of GOOGLE reCAPTCHA) to ensure only genuine customer bookings are made.
- iii. For preventing and detecting fraudulent or criminal activity;
- iv. For security purposes (security cameras).
- To promote our business, improve our products and services;
- i. To contact you with ‘targeted advertising’ delivered online through social media and other platforms operated by other companies, unless you object after your prior approval. You may receive advertising based on information about you that we have provided to that platform, or because, at our request, the platform has identified you as having similar attributes to the individuals whose details it received from us. To find out more, please refer to the relevant page;
We use this information in two ways:
- We identify links between your attributes and behaviour, and market to others with the same attributes, in our direct marketing campaigns and through targeted advertising delivered through our sites, apps or third-party platforms including social-media channels.
- We personalise our interactions with you to make them more relevant to your interests. Those interactions include your visits to our sites and the content that appears on them.
- To contact you if you make an enquiry with us on our website but do not complete a reservation.
- For internal research/analysis to improve the quality of our services, the products we offer and new products we are developing by:
- i. Inviting customers to take part in surveys;
- ii. Using aggregated customer data to make informed decisions on the traditions and wishes of our customers.
- In the event that we merge, split, sell or buy a business sector, we may disclose your personal data to the prospective seller or buyer, and we will implement a confidentiality agreement.
HOW AND WHEN DO WE USE YOUR DATA FOR MARKETING?
To find out more about our marketing communications, including how and why we may contact you, and how you can opt out of our marketing communication, please read more here…
If you have made an enquiry or purchase at one of our sites, via our travel agents or the contact centre, your personal data may be used by us in the ways allowed by law to contact you by post, electronically (e-mail or text message) and/or by phone in order to provide you with information and offers relating to products or services that you can reserve/purchase from THOMAS COOK. We will do this only if you asked for this explicitly.
If you have not made an enquiry or purchase, we will send information and offers by e-mail or text message only if you explicitly agree to receive such marketing either directly through us, or through a third party.
The types of products and services that can be purchased through THOMAS COOK are shown in the table below. You will receive marketing communications only about those services we think are relevant to you:
- Flights and exotic holidays, cruises, travel arrangements flights only: THOMAS COOK BELGIUM nv (via THOMAS COOK RETAIL BELGIUM nv)
- Driving holiday, winter sports and city trips: THOMAS COOK INTERNATIONAL ag (direct or via THOMAS COOK RETAIL BELGIUM nv)
- We will not pass your contact details to any third party that is not a business partner of providing THOMAS COOK services unless you have explicitly agreed to it.
HOW DO WE PROCESS YOUR PERSONAL DATA TO PERSONALISE YOUR MARKETING?
To try to ensure that our marketing communications and advertising are relevant to you, we work with third parties to offer you a better experience. You can find out how we do this by reading more here…
Using new technologies, and with the help of our advertising agencies and marketing activation platforms (including Dentsu Aegis Network and Converto Inc), we may use your personal data in the following ways:
- to try to ensure that any marketing communications we send are offering products or services that are likely to be of interest to you.
- to personalise our digital marketing (for example, our banners) and links to our marketing partners' websites. This digital marketing may include marketing related information relating to THOMAS COOK or marketing related information relating to third parties to whom we provide advertising services.
Our business partners and advertising networks (including Google Double Click for Publishers) may also provide you with adverts on our Sites. We allow third parties to collect information about your online activities using cookies and other technologies. Those third parties may include other Thomas Cook companies, our suppliers and business partners who collect information when you view an advert. We also collect information about your online activities using cookies and other technologies when you use websites other than our Sites to provide advertising services to third parties. This technology enables us to display an advert to you relating to a third party on other websites, based on your page visits and other behaviour whilst on our Sites.
Information collected by these third parties may be used to make predictions of your preferences or interests, and to display adverts on our Sites or across the internet appropriate to those perceived interests. Please see our cookies policy for more information.
WHAT SHOULD YOU DO IF YOU DON’T WANT TO RECEVE MARKETING COMMUNICATION:
We understand you might no longer wish to hear from us, and we will respect that. It is easy for you to unsubscribe or to ‘opt out’; please read more here…
You have the right, at any time, to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by selecting the ‘No marketing’ option. You can also, at any time, send an ‘unsubscribe request’ to: Database Manager Thomas Cook België Department of Marketing, Tramstraat 63-67 B-9052 Gent or by e-mail to: Privacy@ThomasCook.be
Please note that when you want to unsubscribe from marketing concerning holiday and travel services, this opt-out will apply only to the products and services from the THOMAS COOK company making the marketing communication for which you were subscribed and that you possible need to to the same for any other THOMAS COOK associates you may have subscribed to.
YOUR RIGHTS IN RELATION TO ANY PERSONAL DATA WE HOLD ABOUT YOU:
Of course you have rights in relation to the personal data which we hold about you. To find our more, please read here…
Your right to access your personal data
You have the right to make a ‘Data Subject Request’. This is a request to access the personal data we hold about you. You can do this free of charge. In such a case, we may ask for proof of identity as well as information about your interactions with us so that we can locate your personal data. This may include information about your previous reservation(s) or other purchases. You also have the right to make a request for us to correct the information we hold about you.
Your right to ask us to limit or cease processing your data we hold about you:
- You may object to the processing of your personal data if we are no longer within the law to use it, to remove your data should we be keeping it for too long, or limit the processing to particular circumstances;
- We may not be able to fulfil your request in the case of further necessary use, for example: for legal purposes, accountancy or audit regulations;
- If you ask us to stop processing your personal data in relation to a booked trip or any other agreement with us, this may mean we, or our suppliers, will be unable to provide certain services you have requested;
- When we have erased our data, the lawfulness of any processes before the erasure will not be influenced.
Transferring your personal data in a structured way
Where we rely on your consent for processing your personal data, or need to process it in connection with your contract, as set out in the section entitled ‘How do we use your data when providing our services to you’, you may ask us to provide you with a copy of those data in a structured data file.
You can ask us to send your personal data directly to another service-provider, and we will do so if this is technically possible. We shall not provide you with a copy of your personal data if it contains the personal data of other individuals, or if we have some other legal reason to withhold those data.
How to contact us?
Database Manager Thomas Cook België Department of Marketing, Tramstraat 63-67 B-9052 Gent
Alternatively, by e-mail to: Privacy@ThomasCook.be
Once you have made your request and provided us with the information we need to begin a search for the data about you that we are storing, we will have 30 days to respond. If you have any further questions about the processing of your personal data related to matters of privacy protection, you can contact our Group Functionaries: Ella Belsham, p.a. Thomas Cook, Tramstraat 63-67, B-9052 Gent.
How to file a complaint
Database Manager Thomas Cook België Department Marketing Tramstraat 63-67 B-9052 Gent
Or by e-mail to: Privacy@ThomasCook.be
You also have the right to lodge a complaint with the data protection authorities, the COMMISSION FOR PROTECTION OF PERSONAL INFORMATION, Drukpersstraat 35, B-1000 Brussels, with the following e-mail address: firstname.lastname@example.org
HOW LONG DO WE RETAIN YOUR PERSONAL DATA
If you want to find out more about how long we retain your data, please read more here…
Should you make a reservation or other purchase with us, your personal data will be retained to ensure we provide the best possible customer service to you. We retain your personal data only for as long as necessary for the purpose they were collected originally. Afterwards, these data will be removed or archived unless and to the extent necessary for us to process them to comply with any legal obligations which apply to us, or for any legal and justified purpose, such as required by law or for audits
HOW IS YOUR DATA SECURED
We take want to ensure maximum data protection. To find out our approach to this issue, please read more here…
Transmission of data over the Internet is not completely secure and, while we will do our best to protect your personal data, any transmission is at your own risk. Once we have received your data, we will take all reasonable steps to keep your personal data secure and to try to prevent any unauthorised access. All information you provide to us is stored on secure servers. Any payment transactions will be encrypted using Secure Sockets Layer (SSL) technology. In case we have given you a password, or where you have chosen one yourself, enabling you to access certain parts of our websites, you are responsible for keeping that password confidential. Please do not share your password with anyone. This is the password that will give you access to the ‘My Account’ portal at which you are able to specify, change and manage the personal settings yourself.
Keep your booking reference confidential! When you book a holiday with us, you will receive a unique booking code which will appear in the e-mail confirmation and documentation sent by us. This is strictly confidential information and must be kept as such. If you share the personal reservation code with others, they will be able to consult your reservation details using the given reference.
WHAT HAPPENS WHEN YOU FOLLOW A LINK FROM OUR WEBISTE TO A THIRD PARTY WEBSITE?
Our sites include links to other websites that have privacy policies of their own. To learn more about this, please read here…
Our websites contain links to and windows from websites of our suppliers, advertisers and other third parties. You can tell when a third party is involved in supplying a product or service you have requested because their name will appear with ours. If you follow a link, or likewise, to any of those other websites, please note that those websites have their own privacy policies, and that THOMAS COOK does not have any responsibility for these policies. Please check their policies before you submit any personal data to those websites.