Privacy Policy

INTRODUCTION

Welcome to the S T Worldwide Limited privacy policy. In this privacy policy, the words “Strawberry Tours”, “we” or “us” apply to S T Worldwide Limited and any subsidiaries.

We respect your privacy and are committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you book a tour with us.

This website is not intended for children and we do not knowingly collect data relating to children.

Please read this privacy policy together with any other privacy or fair processing policy we 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.

CONTROLLER

This privacy policy is issued by S T Worldwide Limited so when we mention ”Strawberry Tours”, “we”, “us” or “our” in this privacy policy, we are referring to S T Worldwide Limited, which is the data controller and responsible for this website.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions, including any requests to exercise your legal rights, please contact the data privacy manager.

CONTACT DETAILS OF OUR DATA PRIVACY MANAGER

Our data privacy manager may be contacted by email on info@strawberrytours.com.

You have the right to make a complaint at any time to the data protection regulator of the country in which you live. We have set out in the table below contact details for some of the relevant data protection regulators.

CountryNational Data Protection RegulatorWebsite Address
UKThe Information Commissioner’s Office (ICO)www.ico.org.uk
SpainAgencia de Protección de Datoswww.agpd.es
PortugalComissão Nacional de Protecção de Dados (CNPD)www.cnpd.pt

We would, however, appreciate the chance to deal with your concerns before you approach your national data protection regulator so please contact us in the first instance.

THIRD-PARTY LINKS

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 policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data 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 as follows:

  • 1• Identity Data includes first name, maiden name, last name, username or similar identifier, title and gender
  • 2• Contact Data includes billing address, delivery address, email address and telephone numbers
  • 3• Financial Data includes bank account and payment card details
  • 4• Transaction Data includes details about payments to and from you and other details of services you have purchased from us
  • 5• 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
  • 6• Profile Data includes purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • 7• Marketing Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

If 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 (for example, to book you on a tour) we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

  • 1• Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
    • 1• book on a tour through us
    • 2• request marketing to be sent to you
    • 3• give us feedback or contact us

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:

  • 1• To enable us to provide the service that you have booked from us
  • 2• 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
  • 3• Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before 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 below.

Purpose/ActivityType of data Lawful basis for processing including basis of legitimate interest
To process your order, e.g.:
(a) Manage payments
(b) Collect money owed to us
(a) Identity
(b) Contact
(c) Financial
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover money due to us)
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy policy
(b) Asking you to leave a review or take a survey
(a) Identity
(b) Contact
(c) Marketing
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our services)
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)(a) Identity
(b) Contact
(c) Technical
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing
(f) Technical
Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences(a) Technical
(b) Usage
Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions to you about goods or services that may be of interest to you(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing
Necessary for our legitimate interests (to develop our services and grow our business)

MARKETING

We try to provide you with choices regarding certain personal data uses, particularly in relation to marketing and advertising.

PROMOTIONAL OFFERS FROM US

We may use your Identity, Contact or 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).

You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

OPTING OUT

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us 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 service purchase, service experience or other transactions.

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 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 share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.

  • 1• Third parties who will be providing services on our behalf, such as organisers of tours booked through this website and the guides who will be leading these tours
  • 2• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

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.

6. INTERNATIONAL TRANSFERS

S T Worldwide Limited is based in Hong Kong and any data provided to us will therefore be transferred outside the European Economic Area (EEA).

We may also share your personal data with third party tour providers based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • 1• 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 European Commission; or
  • 2• Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe or
  • 3• Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the protection used in transferring your personal data outside the EEA.

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 reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

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, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for accounting purposes.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

9. YOUR LEGAL RIGHTS

  • 1• The right to request access to your personal data
    You are able to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • 2• The right to request correction of your personal data
    You may 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.
  • 3• The right to 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. 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.
  • 4• The right to object to processing of your personal data
    You may object to processing of your personal data where we are relying on a legitimate interest and you feel that this 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.
  • 5• The right to request restriction of processing your personal data
    This enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • • If you want us to establish the data’s accuracy.
    • • Where our use of the data is unlawful but you do not want us to erase it.
    • • 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.
    • • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • 6• The right to request transfer of your personal data
    If you request the transfer of your personal data to you or to a third party, we will provide 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.
  • 7• The right to withdraw consent
    You may 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.

If you wish to exercise any of the rights set out above, please contact us.

NO FEE USUALLY REQUIRED

You will not normally have to pay a fee to exercise these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request information from you to help us confirm your identity and ensure your right 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 could 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.