Privacy Policy

Background

The TUI website is owned and managed by Lucid Group Communications Ltd (Lucid Group). This privacy policy sets out how and why Lucid Group collects and uses your personal data and our legal bases for its use, to ensure you remain informed and in control of your information. Please read this policy carefully to understand how we collect, use and store your personal data. If you have any questions about how Lucid Group processes your information, please contact us using the details in the ‘How to contact Lucid Group’ section below.

Changes to this privacy policy

Lucid Group may change this privacy policy from time to time by updating this page in order to reflect changes in the law and / or Lucid Group’s privacy practices. You will be notified about changes in the privacy policy updates via email if you are a registered user of the TUI website.

How to contact Lucid Group

The Lucid Group Data Protection Officer can be contacted at jan@lucid-group.co.uk or at Lucid Group Communications Ltd, Burleighfield House, London Road, Loudwater, Bucks, HP10 9RF, UK.

Types of personal data we collect

Personal data is defined as information from which an individual may be identified. The personal data we collect about you on this website is the following:

  • Your first name and surname
  • Your email address

Source of your personal information

The personal information we collect and is given to us directly by you. Use of the password protected area of the website is provided by invitation only.

Uses of your personal data

Lucid Group and our partners, agents and suppliers use your personal data, including any of the personal information listed under ‘Types of personal data we collect’, for the following purposes which include, but are not limited to:

  • Enabling you to interact with the facilities and services provided on the website
  • Allowing you to sign up for the TUI newsletter
  • Contacting you about the TUI website, TUI events or sending you messages from the TUI secretariat
  • Ensuring you can get in touch with the TUI secretariat regarding the TUI initiative
  • Sharing of information with AbbVie Inc, the website sponsor
  • Exercising or fulfilling the legal rights and responsibilities of Lucid Group
  • Adherence to rules, guidance and best practice guidelines issued by governmental and regulatory bodies
  • Compliance with legal and regulatory obligations, requirements and guidance

Legal bases for using your personal information

Lucid Group are required under law to ensure we have valid grounds for processing your data. The legal grounds that are most relevant to our use of your personal information are:

  • Consent
  • Legitimate interests

Lucid Group may also be required to use your personal data to comply with our legal obligations.

Consent

This legal ground for processing applies to your submission of personal data when using this website

Legitimate interests

This legal ground for processing includes, but is not limited to, these circumstances:

  • The sponsor of the website (AbbVie Inc) requires Lucid Group to maintain records relating to your interaction with the website
  • For the management and audit of our business operations
  • To carry out monitoring of activity and use of services on the website
  • To administer Lucid Group’s good governance requirements, such as internal reporting and compliance requirements

Withdrawal of your consent

Under circumstances in which we are relying on your consent to process your personal data, you have the right to withdraw this at any time by contacting us using the details provided in ‘How to contact Lucid Group’.

Sharing your personal data

Lucid Group may share information with the following third parties for the purposes listed above:

  • Companies in the Lucid Group
  • AbbVie Inc, the sponsor of the website
  • WPA Pinfold Ltd, the developer and host of the website
  • Members of the TUI Steering Committee
  • Other third-party suppliers involved in the website hosting and maintenance
  • Governmental and regulatory bodies such as HMRC, the Financial Conduct Authority, the Prudential Regulation Authority, the Ombudsman, the Information Commissioner’s Office and under the Financial Services Compensation Scheme
  • Other organisations and businesses who provide services to Lucid Group such as back up and server hosting providers, IT software and maintenance providers, document storage providers and suppliers of other back office functions

Data storage and transfer of your personal data

Lucid Group Communications Ltd is based in the UK. Our data is stored in the UK and the USA, and may be transferred to other countries outside the European Economic Area. When your data is transferred we will ensure that appropriate data protection safeguards are in place unless an exceptional circumstance arises. If you require more information about these safeguards, please contact the Lucid Data Protection Officer.

WPA Pinfold Ltd is based in the UK, and may also store your data for the purposes of supplying these to Lucid Group only. WPA Pinfold Ltd is responsible for ensuring the appropriate data protection safeguards are in place.

Retention of your personal data

We will not retain your personal information for longer than necessary and will delete it once it is no longer required for the purposes set out in the Policy. Whilst different periods apply for different types of data, the longest we will normally hold any individual’s personal data is for 7 years after your last time of website access.

Your data protection rights

Presuming that these rights are not overridden by our legal obligations, or where our legitimate interests are not overridden by your rights and interests as an individual, the following data protection rights apply to the personal data which Lucid Group stores:

  • Right to be informed: you have the right to be told how your personal information is / will be used. This policy is intended to be a clear and transparent description of how your personal data may be used
  • Right of access: you can contact us to request a copy of the information we hold relating to you. We will normally comply with your request within 30 days once we are satisfied you have rights to view the requested records
  • Right of erasure (right to be forgotten): you have the right to have your personally identifiable data deleted
  • Right of rectification: if you believe the records which Lucid Group keep are inaccurate you have the right to ask for these to be updated

If you wish to exercise any of the above rights, please contact our Data Protection Officer at jan@lucid-group.co.ukor at Lucid Group Communications Ltd, Burleighfield House, London Road, Loudwater, Bucks, HP10 9RF, UK

Complaints

If you are unhappy about the way your personal data has been handled by Lucid Group you have the right to lodge a complaint with either our Data Protection Officer or directly with the ICO (Information Commissioner’s Office in the UK). Further information including contact details are available at https://ico.org.uk.

Cookie Policy

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.

We use Google Analytics cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to user needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

The cookies in use to deliver Google Analytics service are described in the table below.

 

 

Opt-out

In order to provide website visitors with more choice on how data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to stop data being sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not affect usage of the website in any other way. A link to further information on the Google Analytics Opt-out Browser Add-on is provided below for your convenience.
http://tools.google.com/dlpage/gaoptout?hl=None

For more information on the usage of cookies by Google Analytics please see the Google website. A link to the privacy advice for this product is provided below for your convenience.
http://www.google.com/analytics/learn/privacy.html

Disabling Cookies

If you would like to restrict the use of cookies you can control this in your Internet browser. Links to advice on how to do this for the most popular Internet browsers are provided below for convenience and will be available for the Internet browser of your choice either online or via the software help (normally available via key F1).

Microsoft Edge
https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies
Internet Explorer
http://windows.microsoft.com/en-GB/windows7/Block-enable-or-allow-cookies
Google Chrome
https://support.google.com/chrome/bin/answer.py?hl=en-GB&answer=95647&p=cpn_cookies
Mozilla Firefox
http://support.mozilla.org/en-US/kb/Blocking%20cookies
Apple Safari
http://docs.info.apple.com/article.html?artnum=32467