Privacy Policy

This policy explains how Truth & Lucky ("we", "us", "our") collects and uses your personal information when arranging your travel. We are the data controller for the information you provide. We are committed to protecting your privacy and handling your data in line with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

Information we collect

To research, book and deliver your travel arrangements we typically collect:

• Name, address, email and phone number
• Passport details, nationality, date of birth and, where required, visa information
• Travel preferences (dietary requirements, room preferences, accessibility needs)
• Health or mobility information where relevant to your trip or insurance
• Payment details for booking and deposits
• Details of fellow travellers you ask us to book on your behalf

How we use your information

• To research, quote, book and administer your travel arrangements
• To communicate with you about your booking before, during and after travel
• To meet our legal, regulatory and financial record-keeping obligations
• Occasionally, to send you marketing about our services where you have agreed to receive it

Most of the communication you receive from us will be service-related, in connection with a trip we are arranging for you. We may, from time to time, send marketing emails about travel ideas or offers. We will only do this where you have consented, and you can opt out at any time using the link in any marketing email or by emailing us directly.

Legal basis for processing

• Contract: to take steps before, and to perform, the booking you ask us to arrange.
• Legal obligation: to comply with accounting, tax and travel-industry record requirements.
• Consent: for marketing communications and for processing any health or other sensitive information.
• Legitimate interests: to run our business, maintain client records, and improve our service.

Where your information is held

Your booking information is held within a secure booking and client management system provided to us by Protected Trust Services (PTS), who act as our data processor. PTS provides financial protection for the bookings we arrange and operates the regulated trust account through which client monies are handled. They process your data on our instructions and under appropriate contractual safeguards.

Who we share your information with

To deliver your trip, we share necessary details with:

• Airlines, hotels, villa owners, cruise lines, tour operators, ground handlers and transfer providers
• Travel insurance providers, where arranged through us
• Protected Trust Services, our booking, financial-protection and trust-account provider
• Our professional advisers (accountants, lawyers) and regulators where required

We never sell your personal information. Many of our suppliers are based outside the UK; where data is transferred overseas we rely on the safeguards permitted under UK data protection law.

How long we keep your information

We keep booking and financial records for at least seven years to meet our legal and tax obligations. Marketing preferences are retained until you ask us to remove them. Other records are kept for as long as you remain a client and for a reasonable period afterwards.

Your rights

Under UK GDPR you have the right to:

• Access the personal information we hold about you
• Ask us to correct inaccurate information
• Ask us to delete your information, where we are not required to keep it
• Object to, or ask us to restrict, certain processing
• Withdraw consent at any time, where consent applies
• Receive a portable copy of information you provided

To exercise any of these rights, email hello@truthandlucky.com.

Security

We use appropriate technical and organisational measures to protect your information, including secure systems operated by Protected Trust Services. No system is ever entirely free of risk, but we work to ensure your data is handled carefully and only shared where necessary to deliver your trip.

Complaints

If you have a concern about how we handle your information, please contact us first so we can put it right. You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk.

Contact

Truth & Lucky
hello@truthandlucky.com