Seek Dharma Limited trading as Seek Dharma, Looking FC and Spirited Stories (‘Seek Dharma’’ or ‘our’, ‘us’ or ‘we’) is committed to protecting and respecting your informational privacy.
The purpose of this Privacy Notice is to explain to you how, when and why we use your personal information. This Privacy Notice also explains your rights in relation to our use of your information as well as other specific information about us. This information is provided to you in accordance with the Data Protection Act 2018; the UK GDPR and the Privacy and Electronic Communications Regulations 2003 as well as other applicable regulatory requirements (‘UK data protection laws’). This Privacy Notice is for your benefit, so we ask you to read this document carefully and if you have any questions, please contact us at firstname.lastname@example.org.
Your personal information is described and referred to in this Privacy Notice as your ‘personal information’ or your ‘personal data’.
This Privacy Notice also explains how others, including other organisations we work with may or will use your personal data in the course of our business operations. This includes, where necessary, third party service providers such as payment gateways (to facilitate payments); our affiliates and partners; as well as service providers local to your chosen holiday or travel destination.
This Privacy Notice applies to:
- The use of our websites at https://www.seekdharma.com; https://spiritedstories.travel/ & https://www.lookingfc.com/ and any others that we operate.
- Subscriptions to our newsletter, participation in surveys, contests or other similar promotions;
- Our social media channels and user generated content;
- Our customers, or prospective customers of our products and services;
- Anyone interested in applying to work for Seek Dharma.
WHO WE ARE AND WHAT WE DO
We are a United Kingdom based independent travel and tour operator registered with ABTA (Y6752). We specialise in creating and facilitating travel experiences for our customers to worldwide destinations.
IDENTITY OF DATA CONTROLLER
Seek Dharma Limited is a company registered in England and Wales under company number 13127983 (and whose registered office is at Second Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, United Kingdom). Seek Dharma Limited is registered with the Information Commissioner’s Office (the ‘ICO’) as a data controller with registration reference ZB343665.
The ICO is the United Kingdom’s independent statutory regulatory authority in relation to data protection and information rights.
If you have any enquiries, concerns or complaints about our data processing activities, please contact us at email@example.com or write to us at Seek Dharma Limited, Second Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, United Kingdom.
The ICO also provides a helpline and complaints service and can be contacted at: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or at www.ico.org.uk or by telephone on 0303 1231113.
SECURING YOUR PERSONAL INFORMATION AND YOUR RESPONSIBILITIES
We take the security of your personal information very seriously and we use appropriate security measures to protect your informational privacy in the course of our business operations.
Although it is our responsibility to ensure compliance with UK data protection laws we also ask you to act responsibly with your own or your family and/or groups’ personal data; so please:
- Make sure you read this Privacy Notice and make sure that you and any other individuals you represent fully understand its contents. If you have any questions about it please contact us at firstname.lastname@example.org;
- If you believe or are concerned that your informational privacy has been breached by using our website or in any dealings you have with us, please contact us immediately;
- Although we use appropriate security measures to protect your informational privacy and follow industry best practice, you must understand that unfortunately, any form of data transmission which is based upon or which uses the Internet (including unencrypted emails) can never be guaranteed as completely secure.
Please also see the section below ‘How is your Information Protected?’
WHAT INFORMATION DO WE COLLECT ABOUT YOU
VISITORS TO OUR WEBSITE
By accessing and using our website or completing an online contact form; subscribing to our newsletter; participating in our surveys or our competitions, we shall collect personal information about you and you agree to the collection, use, storage and transfer of your information by us under the terms of this Privacy Notice, including our terms and conditions of business [click here for SEEK DHARMA Ltd, here for Looking FC or click here for Spirited Stories].
If you contact Seek Dharma, we may keep a record of any communication you make dependant on the nature and purpose of the communication with us, subject to the terms of our data retention policy.
1.1 HOW DO WE USE THE INFORMATION WE COLLECT ABOUT YOU?
- To contact you about any website based enquiry you make to us or for your views on our services;
- If you agree, to keep you informed about our products and services that we offer and about our news and promotions;
- To manage, maintain and improve the performance of our website and to provide targeted information to you about our products and services.
1.2 HOW LONG DO WE HOLD YOUR PERSONAL INFORMATION?
In relation to purely website visitor activity, we only retain your information for up to 24 months; however, if you make a website based enquiry or subscribe to our newsletter; participate in our surveys or our competitions via our website, then we retain your information for as long as you indicate that you are happy for us to do so.
2 CUSTOMERS AND PROSPECTIVE CUSTOMERS
We shall collect personal information about you if you: make an enquiry about any of our travel experiences; ask us for a quote; make a booking with us; make any claims (including Insurance claims) or make a complaint; or, if you use our support and administrative services or ask for further information from us.
The type of personal information we may collect from you is:
- Personal details (your name, age, gender, nationality and place of residence);
- Contact details including your email address and telephone numbers;
- Emergency contact information;
- International Student Identity Card (‘ISIC’) information (where applicable);
- Financial details (credit/debit card and bank details);
- Travel documents (passport and visa information, travel insurance);
- Care needs (special needs, medical conditions, dietary requirements);
- Trip destination information (including, travel itinerary, accommodation preferences);
- Information about your social preferences and interests.
If you are a group organiser or any other lawfully authorised individual (e.g. a parent or legal guardian) and you are providing personal information to us on behalf of any person under the age of eighteen, please also see the section below on ‘Consent‘, ‘Processing Special Category Data‘ and ‘Children’s Privacy‘.
2.1 HOW DO WE USE THE INFORMATION WE COLLECT ABOUT YOU?
- To process and manage your enquiry, quote, booking, claim or administrative service;
- To share your personal data with our third party suppliers including, our affiliates, business partners;
- For account management, including payment, debt management and refunds including third party payment gateways (such as Stripe) and secure online payment sites;
- For claims management and insurance purposes;
- For record-keeping purposes;
- To contact you and respond to your enquiries and complaints;
- To notify you about important changes or developments relating to your booking;
- If you agree, to keep you informed about our products and services that we offer and about news and promotions;
2.2 HOW LONG DO WE HOLD YOUR PERSONAL INFORMATION?
We retain our customer data for as long as it is necessary to fulfil the legal purposes it was first collected for, which we assess by reference to the following criteria: as required in order to satisfy the obligations we have for any legal, accounting, regulatory or reporting purposes; or, as necessary to resolve complaints or disputes. We keep our data retention policy under regular review and where possible aim to delete personal data relating to individual customers after a maximum period of fifteen years from the date of the last booking.
3 SOCIAL MEDIA CHANNELS AND USER GENERATED CONTENT
We may collect your personal information and social networking contact details if you provide and/or post feedback reviews or provide information about your experiences on a past, current or future trips with us. We shall only use such content and any related images you have submitted to our social media channels or website, if you have given your consent. If you give your consent for us to process this information, then we may include it in our direct marketing activities such as:
- Print materials;
- Website, social media posts and content feeds;
- Email communications;
- Images of our trips.
Please also note, that when you travel with us, photographs or video footage may be taken either by Seek Dharma or one of our third party suppliers for the purposes of marketing or as outlined in our booking conditions. If you do not wish to appear in any photographs or video footage please inform your tour leader or the photographer.
We shall retain your information for as long as you indicate that you are happy for us to do so.
4 ANYONE INTERESTED IN APPLYING TO WORK FOR SEEK DHARMA LIMITED
If you secure employment with Seek Dharma we shall provide you with an Employee Handbook containing data protection clauses on receipt of your contract. The two Privacy Notices should be read together.
We shall collect personal information about you if you make an enquiry about offering your services to us as a member of our staff.
If you wish to apply for a job with us, then the type of personal information that we may collect from you is:
- Your name and contact details;
- Your current and up to date CV;
- Residency, domicile and nationality information;
- Copies of relevant qualifications and licences;
- Background checks (e.g. DBS certificates and also see below the section on Criminal Offence Data);
Work permit and Visa applications;
- Details of any relevant medical conditions including dietary requirements;
4.1 HOW DO WE USE THE INFORMATION WE COLLECT ABOUT YOU?
- To arrange an interview or make you an offer of employment;
- To communicate with you about the recruitment process.
- To assess your skills, qualifications and suitability for the role;
- To contact the providers of your references;
- To generate contractual agreements and other legal documents to support your engagement;
- To contact next of kin in an emergency;
- To monitor and record your performance during agreed periods of service with us;
- To record training undertaken;
- To record and monitor any work place accidents.
4.2 HOW LONG DO WE HOLD YOUR PERSONAL INFORMATION?
We retain our recruitment and staff personal data for as long as it is necessary to fulfil the purposes it was collected for, which we assess by reference to the following criteria: as required to satisfy any legal, accounting, regulatory or reporting obligations, or as necessary to resolve disputes. We keep our data retention under regular review and where possible aim to delete personal data relating to individual members of staff after a maximum period of ten years following their cessation of service with Seek Dharma.
BASIS OF OUR LAWFUL PROCESSING
The obligations imposed on us by data protection law means that we can only use your personal data if we have a lawful reason to do so. In this section we explain the lawful reasons we have for using your personal data:
OUR CONTRACT WITH YOU
We use your personal data because it is necessary for the purposes of: (i) the formation, performance or termination of our agreement with you in relation to the sale, supply and support services (including Insurance claims) of our products and services in accordance with our terms and conditions of business (https://www.seekdharma.com/booking-conditions/) and for our contractual arrangements with our members of staff; or, (ii) because we have asked you or you have asked us to take specific steps before entering into such an agreement.
In summary, processing your personal data is contractually necessary for:
- The sale and supply of our products and services to you;
- Managing your booking, delivery of our services, receiving and making payments and refunds;
- Making bookings with third parties on your behalf such as airlines, hotels and other intermediaries;
- Communicating with third party providers such as our affiliates and partners and local service agencies;
- Account management, including providing and administering your holiday booking;
- Administrative tasks relating to our contract with you, including providing customer service messages and notifications relating to processing payments, managing claims;
- Where you are a member of staff, for the formation, performance and termination of our agreement with you.
OUR LEGAL OBLIGATIONS
In some cases, processing your personal data is necessary for us to do in order to fulfil a legal obligation that we are required to comply with. This may include adhering to the requirements imposed by UK legislation or other mandatory obligations imposed by the public law agencies of your holiday destination relating to e.g. border control, security and anti-terrorism controls as well as Income Tax Acts, VAT Acts, Companies Acts; the regulatory requirements imposed by HMRC and the ICO; anti-money laundering measures; the prevention and detection of fraud; responding to a request from the English courts or the police; defending legal rights; our insurance obligations and ICO record keeping obligations.
Where you have given us your explicit consent for us to process your personal data for any of the following purposes:
- Processing any special category data strictly necessary for the processing and performance of your holiday booking1
- When you visit or use our website;
- Sending you notifications, text messages and emails about our products and services, events and promotions;
Please note that if you are a parent of legal guardian, group organizer or any other lawfully authorised individual and you are providing personal information to us on behalf of any person under the age of eighteen, then you warrant and agree that:
- You are have the explicit consent of all individuals in your party, to provide the necessary categories of personal information to us, and;
- That all members of your party are aware of our Privacy Notice and that their information is to be passed to us for processing.
(Please also see the sections below on ‘Processing Special Category Data‘ and ‘Keeping You Informed‘).
OUR LEGITIMATE INTERESTS
Where processing your personal data is necessary for our own legitimate interests or the legitimate interests of a third party, provided that those interests are not outweighed by your individual rights and interests.
Our legitimate interests are:
- Delivering, developing, and improving our products and services;
- Our direct marketing activities, including determining whether our marketing activities are effective;
- Recording and monitoring telephone calls for training purposes and to improve the quality of our services;
- Improving customer facing services, including managing complaints;
- Producing management information including carrying out internal auditing and the administration of our business;
- Preventing crime and detecting fraud.
We do not make your personal details available to third party companies for marketing purposes. We do not rent or trade marketing lists with other organisations or businesses. You can withdraw your consent to our marketing emails at any time either by clicking on the ‘Unsubscribe’ link in our notifications, messages or emails (where applicable) or by replying to our email with the words ‘please unsubscribe’ or calling Customer Services on +44 161 524 5667
PROCESSING SPECIAL CATEGORY DATA
Where we collect, process and store any of your special category data, we only do so with your explicit consent or because:
- Processing is necessary in the event of emergency, to protect your vital interests if you become physically or legally incapable of giving consent;
- It is necessary for reasons of public interest in the area of public health such as protecting against serious cross-border threats to health;
- It is necessary for the establishment, exercise or defence of legal claims either when we are faced with any legal claims made against us or where we pursue legal claims ourselves;
- It is necessary for the purposes of carrying out our obligations and exercising specific rights in the field of employment, social security and social protection law; including preventive or occupational medicine, the working capacity of an employee, medical diagnosis or treatment;
CRIMINAL OFFENCE DATA
Candidate applications which we progress for certain roles with Seek Dharma require us to conduct Disclosure and Barring Service (‘DBS’) checks in order to meet the safeguarding and due diligence criteria policies which the business has assessed and adopted in order to meet our legal obligations.
We are lawfully entitled to carry out a DBS check for the following purposes:
- Protecting the public against dishonesty;
- Legal claims.
We have in place an appropriate policy document and safeguards which we are required by law to maintain when processing such data.
CHILDREN’S PERSONAL DATA
Children’s personal data (which we consider to be the personal information of a person under the age of 18) is processed in accordance with the standards and published guidance of the ICO and in accordance with the terms of this Privacy Notice and our terms and conditions of business. For the avoidance of doubt, we do not send marketing communications to children nor do we use automated decision-making about children.
WHERE IS THE DATA STORED?
All data collected by Seek Dharma is stored within the European Economic Area (EEA). In some instances, we may choose to engage other companies to store or process your personal data on our behalf. In every case, where we chose to do that, we will ensure that any company that we engage is subject to the same standards of data security and provides you with the same level of personal data protection as we provide to you.
This means that where we may transfer or store your information outside the UK or EEA (European Economic Area), we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Notice (please also see the section ‘Sharing and transferring your personal data with or to third parties‘ below).
KEEPING YOU INFORMED
If you are an existing customer and/or have bought or enquired about our products or services before, we may also use the information we collect to let you know about our other products and services which may be of interest to you and to keep you updated with information about promotional offers.
However, if you no longer want to receive material from us you can withdraw your consent at any time either by replying to our email with the words ‘please unsubscribe’ or calling Customer Services on +44 161 524 5667
SHARING AND TRANSFERRING YOUR PERSONAL DATA WITH OR TO THIRD PARTIES
Depending on the services that we provide to you, we may be required to share and/or transfer your personal data with or to other organisations and companies in order to provide our contracted services to you and/or to meet our legal obligations.
We will only provide your personal information to those third party organisations and companies in order to deliver the service you have instructed us to perform and that we have engaged the third party to provide or that we are required to do by law. These services may include but are not limited to meeting our contractual obligations owed to you; the discharge of our own legal obligations; answering your questions about our products or services; sending postal mail and e-mails to you and to others; and, where necessary to obtain professional advice.
Your personal data may be used to:
- Process booking confirmation;
- Request support or assistance in an emergency;
- Provide necessary health and safety documentation to third party providers;
- Settle invoices associated with our bookings;
- Contact any of our employees involved with the tour.
And your personal data may be shared with:
- Coach and other Transport Suppliers;
- Hotels and Local Agents;
- Insurance companies;
- Security or credit checking agencies;
- Public Authorities (Customs and Immigration Agencies);
- Venues and Attractions.
Where your chosen holiday is to any destination outside the European Economic Area (‘EEA’), we must make you aware that individual data protection safeguards, rights and freedoms may not be of an equivalent standard to those in the UK or within the EEA as a whole. In making a booking with us to a holiday destination outside the EEA, you agree to your personal information being transferred and shared with organisations and companies in non-EEA destinations as necessary to fulfil our contract with you or as required by domestic or local law.
We may have to disclose your personal information as a result of our legal obligations for example because border controls require us to do so or because a court or the police or other law enforcement agency has asked us for it; please also see the section above ‘Our legal obligations‘.
If you do not agree to us sharing or transferring your personal information in this way, then we will not be able to provide the holiday or tour to non-EEA destinations.
HOW IS YOUR INFORMATION PROTECTED?
We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Any processing of your information will only be carried out in an authorised manner and is subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. Please also see the section above on ‘Your Responsibilities‘.
If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
To obtain further information relating to the Cookies operating on our website, please view our Cookies Policy.
Our website contains links to other sites such as sponsors, our business partners and affiliates, accreditation companies and/or official regulating bodies. Seek Dharma is not responsible for the privacy practices or the content of any such linked websites.
YOUR INFORMATION RIGHTS
The UK GDPR, gives you a number of important Information Rights which in most cases you can exercise free of charge. However, your ability to exercise your Information Rights depends on various factors, and in some cases it will not be possible for us to agree to your request e.g. where legal exemptions apply or where the specific right you seek does not apply to the type of information we hold.
In summary, your Information rights are:
- The right to ask us to correct any mistakes contained in the information we hold about you;
- The right to require us to erase your personal data in certain situations;
- The right to data portability, which means the right to receive (or for a third party you have chosen to receive) an electronic copy of the personal data you have given to us;
- The absolute right to object at any time to processing your personal data where we only use it for direct marketing;
- The right to object to decisions being taken about you based solely on automated means which produce legal effects concerning you or are similarly significant in how they affect you;
- The right to object in certain other situations to our continued processing of your personal information;
- The right to otherwise restrict our processing of your personal information in certain circumstances.
For further information on each of these Information Rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, the link is here https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/
If you would like to exercise any of the Information rights set out above, please contact us at email@example.com or write to us at Seek Dharma Limited, Second Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, United Kingdom. Please provide us with enough information to identify you and let us know the information to which your request relates.
We always want to make sure that the personal information we hold about you is accurate and up to date. Therefore, if you think any information we hold about you is incorrect or incomplete, please email or write to us at the addresses given above as soon as possible so we can update our records.
APPLICABLE LAW AND DISPUTE RESOLUTION
This Privacy Notice, and any dispute, controversy, proceedings or claim of whatever nature arising out of or in any way relating to this Privacy Notice or its formation (including any non-contractual disputes or claims), shall be governed by and construed in accordance with English law and the exclusive jurisdiction of the English Courts.
CHANGES TO THIS PRIVACY NOTICE
We keep our Privacy Notice under regular review and if we change our Privacy Notice we will post those changes on this page so that you are always aware of what personal information we collect and how we use it. You should therefore refer to this policy regularly.
This Privacy Notice was last updated in July 2022.
1 Relating to racial or ethnic origin, religious or philosophical beliefs, genetic data, biometric data for the purposes of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life and sexual orientation.