National Express Leisure Limited, (referred to in this Notice as “Touromo”, “we” or “us”), part of National Express Group of companies. Touromo helps you make unforgettable memories and experiences when you travel and holiday with us. We help you make your dreams come through and to help us do this we collect and look after your personal data and the personal data of any other person connected to your journey and account. We want you to feel safe and secure knowing we are committed to managing and keeping all the personal data we collect and process. We want you to know how we use this data to deliver our services when you book with us. We also want you to know how we use the data to offer you a better and more inclusive and inspiring experience.
Why is it important and who are the Data Controllers?
Your data is important to you and National Express Leisure Limited (NEL) brand name “Touromo”. As a Data Controller we obtain, use, share, store retain and secure all the personal data in the right way and in line with the law. It is important you help us keep your personal data up to date, accurate and adequate for the purposes in which you have shared this data. From time to time we will contact you to ask you to keep your records and accounts up to date and that includes your communication preferences for the services we deliver to you, marketing and market research.
We operate alongside other members of the National Express Group to deliver services and products to you. We all have obligations under the law to process and secure your personal data each are registered with the UK Data Protection Supervisory Authority, (Information Commissioner’s Office):
National Express Leisure Limited, (brand name “Touromo” Z3329913
Worthing Coaches, Z3329867
Morton’s Coaches, ZA303674
Solent Coaches, Z3002847
Coliseum Coaches, Z3329853
Woods Coaches, Z236837X
Stewarts Coaches, Z2383574
We alongside other data controllers obtain and share your personal data to deliver you a service directly or jointly. We may share personal data to improve and develop existing and new services, products or for statistical, monitoring and research purposes; we may share information with you about our products, services and offerings as part of our information brochures and when you opt-in to marketing.
We have a data privacy team who are here to help you with any questions you may have about how we process your personal data; you can contact our Data Protection Officer by contacting:
Telephone: Customer Contact Centre between 09:00 am and 17:00 pm Monday to Friday who will direct your call to the team.
Post: National Express Leisure, National Express House, Birmingham Coach Station, Mill Lane, Digbeth, Birmingham B5 6DD
Remember we are here to Help.
Who Does This Privacy Notice Apply to, and What is it About?
This privacy notice applies to you if you are or were a customer, prospective customer, passenger and or a person connected to the customer’s service or journey/travel. If there is a person connected to the customer account or service, (for example, makes bookings on your behalf and/or travels with you) please ensure they understand how we will process their personal data by sharing this privacy notice. It may also be a person who has accompanied you to any of our offices, depots and/or drop off points where we may have captured their personal data as part of our CCTV system.
We have produced this privacy notice so you understand:
- The types and categories of personal data we collect
- The purposes for which we obtain and use your personal data
- The legal basis which applies to the personal data allowing us to process it
- The sources of your personal data and likely recipients we may share your data with
- Your Rights under data protection and how to exercise them
- The choices you have, including how to access your account, update your personal data and service or marketing preferences
- What we do with your personal data;
- How to supply feedback, compliments and raise complaints about your data with our Data Protection Officer
- Detail about the Data Protection Regulator
We take your privacy very seriously and are committed to abiding by the Data Protection Laws which protect your privacy.
This privacy notice may change from time to time and the most up-to-date version will always be available on our website. It is your responsibility to read this privacy notice and check our website for the current version.
What personal data do we collect about you, and how?
We collect the following types/categories of personal data and this section supplies you with information about what Personal and Special Category Data we collect and process. We collect data about you and people that will be travelling with you in several ways. We have detailed below some examples of how we collect data and the type of data. We have many ways to interact with our customers, this may be via our websites, app, Wi-Fi portal, mobile, social media and any other media route. Subscribing to our services, setting up an account and making a booking, purchasing tickets, completing a survey and /or when you view our marketing information or opt-in to marketing and research these are all ways, we collect data.
Contact Details – name, home and billing addresses, postcode, email address, telephone and mobile numbers and country of residence.
Account Details – you can create an account with us and you can set your username and password. We will supply you with account and reference number and details of your journeys and bookings.
Payment and Banking Details – Card number, security code, expiry date, issue number of your payment card, and where applicable bank account details, such as name of bank, sort code, bank account number.
Full debit card and credit card information is not recorded by us and is passed directly to the payment card industry compliant third-party payment provider in accordance with good industry practice.
Your profile – Age and Date of Birth.
Booking History – Details of past and current bookings, via our website and your account and/or via our contact centre or through other third-party coaches and travel agents. Reference number to allow us to manage, plan, track and monitor bookings .
CCTV – Images will be captured and stored for a specific time period where we have placed CCTV in our buildings and on our vehicles.
Voice & Call Recordings – We will record calls to our contact centre and agents for monitoring and quality. We do have audio recordings on the entrance, exit and driver location for health and safety and for prevention and detection of crime or offences.
Official Identity Documentation – Passport details, including number and expiry date, where we require this for departures outside the UK. We will ask for identity confirmation if we receive a request from a person to obtain a copy of their data, or any of the rights detailed below.
Social Preferences – we may collect information about your interests, activities and preferred options of travel and holiday experiences.
Feedback and complaints – we record any feedback and complaints and respond to both in accordance with our policies.
Location – We may in some of our apps and portals collect location data and in some of our apps we can collect tracking data from a device. This data aids us deliver you a seamless service.
Special Category Data
This data could include relevant medical data, any special dietary, religious or disability/accessibility requests, as part of collecting passport information we may collect other biographic data such as gender and nationality.
Health – A condition which will need to be recorded for travel purposes to allow us and ongoing operators to meet any specific medical, religious, or other needs relevant to the booking.
Other Sources of Personal and Sensitive Data
We may use data from other sources, such as specialist companies that supply information, retail partners and public registers. Your insurance company, their agents and medical staff may exchange relevant personal and special category data with us in circumstances where we, they need to act on your behalf or in the interest of other customers or in an emergency.
We may obtain and use personal data from other sources, such as specialist companies that supply information, insurance, travel partners, public registers, (e.g., telephone or email preference service). Sources of data will include and are not limited to our IT service and cloud providers, and members of the National Express Group.
If you use social media to communicate with us, e.g., Facebook, Google+, Twitter, Instagram etc., you are agreeing to share your data to be used for these purposes. Note we may not respond to you using social media and will use personal communication channels with you for the protection and privacy of your information.
How We Collect Your Personal Data:
- By making first contact, be this via our website, email, letter, telephone call to one of our agents or contact centre.
- By creating an account with us.
- Searching for products and/or services and/or purchasing or requesting to purchase products and/or services from our website or Apps.
- Purchasing or requesting to purchase products and/or services through any of our other sales channels, including our apps and third-party ticket agents.
- Submitting your personal data on our website or apps, for example, via the ‘Request a Brochure’ page.
- Providing your personal data to us when communicating with us in any manner, for example, when you:
- speak to one of our representatives in person at a travel shop or on-board one of our passengers’ carrying vehicles; and
- contact us by letter, email, text message, telephone call or on social media.
- Consenting to receive certain information from us, such as marketing emails and other promotional material about seat sales, offers, exclusive deals and travel ideas.
- Entering one of our competitions or participating in post journey, market research and other surveys that we organise or conduct.
- By us making visual and/or audio recordings at our owned or occupied sites, and/or on the passenger carrying vehicles used to provide our travel services;
- Recording telephone conversations with our customer contact centre representatives.
- Gathering statistical data from our systems and platforms.
We may also receive your personal data if you use any of the other websites operated by other National Express Group companies or from third parties, such as companies that market and sell our products and/or services on our behalf or from any person who has bought our products and services for you or contacted us on your behalf.
In addition, we will collect the following information:
Browsing our websites or use our mobile Apps:
Each time you visit our website or use our apps we may automatically collect the following information:
Technical data, including:
- IP address.
- browser type and version.
- time zone setting and location.
- operating system and platform.
Transaction data, including:
- the full Uniform Resource Locators (URLs) clickstream to, through and from our website or apps (including date and time).
- tickets and/or journeys you viewed or searched for.
- time on page, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
- Travel preferences, browsing behaviour so we can see what is being accessed and viewed the most.
- When adverts are viewed and accessed or used.
- Social preferences, interests and activities.
Taking part in marketing, promotions, competitions, surveys or questionnaires about our services:
From time to time we may send you relevant offers and news about our and members of our Group products and services where we believe they will be of interest to you. We will only do this if you have opted in to receiving marketing material communications. Forms in which we may use can include email, post, telephone or by sms-text messaging.
- Contact information as above
- Entry and result records of competitions
- Preferences for marketing to be kept informed on promotions, new products, services etc. We record your positive opt-in or out and what you have indicated as your marketing preference, (email, post, phone, mobile, or by sms-text messaging).
Remember you can opt-out by unsubscribing but you may miss out on great offers.
It is important to you and us that we receive feedback and your engagement on surveys, questionnaires or you contacting us with a question or complaint, as these are all important to National Express Leisure Limited. You can help us improve and develop existing and new services. You may also want to acknowledge a member of our team who has gone that extra mile to make your experience outstanding. Please contact email@example.com.
- Surveys and questionnaires are anonymous unless you choose to supply your identity as you would like us to contact you.
- Complaints and compliments will have personal data and may have sensitive data. It depends on the details and nature of what you share with us.
What are the Legal Grounds For Processing Your Personal Data?
The processing is necessary to perform a contract with you (i.e., the management of the contract and to communicate with you using your service communication preferences for the sale and purchase of your coach trip, flight or holiday), or to take steps requested by you before entering into such a contract.
The processing is in our or someone else’s legitimate interests, (i.e., statistical monitoring and performance reporting, marketing, and planning services, market research and for the planning and management of our business operations) and these interests are not overridden by your interests or rights in the protection of your personal data as we carry out a legitimate interest test
The processing has been commenced based on the recording of your consent, (i.e., marketing, competitions and advertising) to the processing of your data.
The processing is necessary to meet a legal obligation which applies to us; law enforcement; prevention and detection of crime; offences committed or alleged to have been committed; health and safety and for the protection of our work force from anti-social behaviour and/or abuse or attack; claims and management of legal, insurance or professional advice; or where required by a country to share official documentation for the pursuance immigration purposes
Sometimes we process data about you which the law considers to fall within special categories (see section “What personal data do we process?” for more details), in which case, we use one of the following grounds:
- Processing is necessary to protect your vital interests or those of another person where you are physically or legally incapable of giving consent (i.e., in the event of a medical emergency).
- Processing is necessary for the establishment, exercise or defence of legal claims.
- The processing is necessary for reasons of substantial public interest on the basis of UK, EU or domestic law; or you have freely given your consent to the processing.
- Processing is necessary as there is a legal obligation.
We can supply more detail on the category of data and the conditions applied to each. Please contact our Data Protection Officer.
What if we have obtained your consent to use your personal data?
Where we process your personal data on the basis of your consent, you may withdraw that consent at any time.
From time to time we may send you relevant offers and news about our products and services in a number of ways, including by email. We may also send you information about other companies’ products and services that we believe may be of interest to you.
- We will only do this if you have opted-in to receive these marketing communications.
When you book or register with us, we will ask if you would like to receive marketing communications.
Remember to keep your records and data up to date, as you do not want to miss any information or promotions. The choice is entirely yours for marketing and we will respect your decision.
You may still receive service-related communications from us. For example, confirming bookings you make with us and providing important information about the use of our products or services.
Where you have provided consent, (opted-in) for us to send you marketing communications, you may withdraw that consent at any time, either by updating your marketing preferences in your account with us (if you have one), by clicking on the “unsubscribe” link in any marketing communications we send you, or by requesting one of our call centre agents to change your permissions.
Who will we share your personal data with?
We may share your personal data with:
- Other National Express Group companies;
- Suppliers, sub-contractors, business partners and our brand ambassadors who help us to provide our products and services to you;
- Suppliers and contractors who help us with analytics, customer insights and market research
- Business partners in connection with the provision of their products
- Legal and professional advisors;
- Government bodies and regulatory authorities, including the Driver and Vehicle Standards Agency, the Police and other crime prevention and detection agencies, the UK Border Agency or other immigration authorities (where required) and the UK Information Commissioner’s Office;
- Traffic Commissioners, the courts and other dispute resolution arbitrators and mediators, other parties to legal proceedings and passenger transport watchdogs;
- Marketers, data management and advertising companies
- Analytics and search engine providers that assist us in the improvement and optimisation of our websites; and
- Other companies that take on any part of our business as a result of a restructure, merger or transfer of that part of our business.
Do we transfer your personal data outside of the UK?
There may be occasions where it is necessary to transfer your personal data to a country outside of the United Kingdom (“UK”). We will transfer data to a country which has adequate data privacy protection. If we are required to transfer data to a country that does not provide a similar level of protection for individuals’ rights in relation to their personal data as in the UK, we shall ensure adequate protections and standard contracts clauses and where applicable and international data transfer operations are in place, we will record our international data transfers and ensure all transfer are in line with UK and EU data protection law and regulation.
Where we transfer your personal data to other National Express Group companies and/or third parties who process your personal data on our behalf in countries outside the UK, we ensure a similar degree of protection is afforded to it by implementing one of the following safeguards:
- we transfer to a country that has been deemed to provide an adequate level of protection for personal data; or
- where the country has not been deemed to provide an adequate level of protection for personal data, we will have entered into contracts approved for use in the UK which give personal data the same protection as it has in the UK.
Please contact the National Express UK Data Protection Officer if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
For how long will we process your personal data?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including satisfying any legal, accounting or reporting requirements in respect of our relationship with you.
Where we process your personal data to fulfil:
- a legal obligation, we will process such personal data for so long as necessary to fulfil that obligation; or
- a contract with you, we will process such personal data until we fulfil that contract and for so long thereafter as may be necessary to keep a record of that contract, which will typically be for 6 years, and to deal with any complaints or claims relating to that contract, which will be until the final resolution of such complaints or claims (having regard to the nature of any potential claims and the limitation of liability periods that apply to them).
Where we process your personal data based on:
- our legitimate interest, we will process such personal data for so long as necessary to achieve that legitimate interest, which will typically be for 6 years after we collect your personal data or the last time we use your personal data (or longer in relation to any legal claims that might arise having regard to the nature of any potential claims and the limitation of liability periods that apply to them)
- your consent, for example, to send you marketing information, we will process such personal data until you withdraw that consent. Please bear in mind that it may take a short time to process any withdrawal of your consent. We aim to do this within 72 hours of receipt of your request, although you may still receive emails that are already in process around the time of your withdrawal.
We may also retain your personal data for longer if we cannot delete it for legal, regulatory or technical reasons.
What rights do you have in relation to your personal data?
You have a number of rights under the Data Protection Laws in relation to your personal data. These include the right, subject to exceptions, to:
Right to be informed – You have the right to be informed on the processing operations of your personal data. This is met by this and other privacy notices from us.
Right to access- Subject Access Request – You can request a copy of your personal data processed by us. In your request for information, please provide as much information as possible and supply a copy of your account or travel details and proof of identification with the request. Upon receipt of the request, we will provide you with a copy of the data that are the subject of the processing. Please note that your right to information may be limited under certain circumstances in accordance with statutory provisions. We will provide you with a copy of your data in line with the law with 28 days upon receipt of your request being valid.
Right to rectification – If you believe your personal data is not correct, you can update your account by logging on using your user name or password, you can contact our customer contact centre to assist and/or contact the Data Protection Officer asking for us to make a correction and/or advise us with new information to ensure your account and record details are not incomplete, you may request completion.
Right to erasure – You may request the erasure of your personal data, your right to erasure depends, among other things, on whether the data relating to you are still required by us to perform our statutory duties.
Right to restrict processing – You have the right to apply a restriction of the processing of the data relating to you as you believe it is incorrect, incomplete or out of date. We will consider your request and act in line with the law to correct, and update your data. Where we cannot restrict processing, we will inform you of the reasons why and that we have recorded your objection on your file.
Right to data portability – You have the right to receive the data that you have provided to us in a structured, commonly-used and machine-readable format, or to request the transmission to another controller. Please note the majority of your data pertains to your travel and account relations with us. Not all data can be ported across to a new data controller. We will keep you informed in our response when and why this would not apply.
Right to object – You have the right to object to the processing of your data at any time for reasons relating to your particular situation. You can object to receiving marketing and advertising at any time with effect for the future in these circumstances we will process your objection, however there may be other circumstances outside marketing and advertising where we will not be able to due to legal, contractual and business reasons but we will detail this in our response.
Rights in relation to automated decision making and profiling – You have a right to know where we are processing data by automated means with no human intervention. Where we are profiling by automated means again with no human intervention. Where we carry out this processing will be in the performance of the contract which we have entered or intend to enter into with you as the data subject.
If you wish to exercise any of these rights and/or request a portable copy of the data that you have provided and is processed on these bases, please contact the National Express UK Data Protection Officer.
If you have any questions or complaints about how we process your personal data, or otherwise about the matters set out in this privacy notice, please contact the National Express UK Data Protection Officer at:
- Address: Data Protection Officer, National Express, National Express House, Birmingham Coach Station, Mill Lane, Digbeth, Birmingham B5 6DD
- Email address: firstname.lastname@example.org
Telephone between 08:00am and 18:00pm Monday to Friday, and Saturday and Sunday 09:00 to 17:00 on 0345 034 0980
You also have the right to complain at any time to the UK Information Commissioner’s Office about how we use your personal data and can contact them on their helpline: 0303 123 1113 or website at https://ico.org.uk/.
Please note the Regulator would like to see that we and you have tried to resolve the complaint in the first instance.