Privacy Policy

The Turquoise Collection understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our customers and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

1. Information About Us

The Turquoise Collection Ltd.

Tour Operator registered in England under company number ​06541977.

Registered address: Suite S3-S4 Stevens House, 17 Station Road West IP14 1EF.

Main trading address: Suites S3-S4 Stevens House, 17 Station Road West IP14 1EF.

VAT number: 2250 2043 53.

Email address: enquiries@theturquoisecollection.com.

Telephone number: +44 1449 770811.

Postal Address: Suites S3-S4 Stevens House, 17 Station Road West IP14 1EF.

ATOL licence number: 11051

2.  What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

3. What is Personal Data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the "GDPR") as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The GDPR is retained in domestic law now the UK has left the European Union, but the UK has the independence to keep the framework under review. The 'UK GDPR' sits alongside an amended version of The Data Protection Act 2018 (DPA). 

The personal data that we use is set out in Part 5, below.

4. What Are My Rights?

Under the UK GDPR and The Data Protection Act 2018 (DPA), you have the following rights, which we will always work to uphold:

a)            The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b)            The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c)            The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d)            The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 11 to find out more.

e)            The right to restrict (i.e. prevent) the processing of your personal data.

f)             The right to object to us using your personal data for a particular purpose or purposes.

g)            The right to data portability. This means that, if you have provided personal data to us directly, we am using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask usfor a copy of that personal data to re-use with another service or business in many cases.

h)            Rights relating to automated decision-making and profiling. (We do not use your personal data in this way).

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

Further information about your rights can also be obtained from the Information Commissioner's Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner's Office.

5. What Personal Data Do You Collect?

We may collect some or all of the following personal data (this may vary according to your relationship with us):

If you choose to make a booking through us or enquire about a potential booking we will collect details that you provide in relation to that booking or enquiry. Information held is likely to include some or all of the following:

• Name;
• Date of birth;
• Address;
• Email address;
• Telephone number;
• Passport details
• Payment information;
• Information about your preferences and interests;
• Information about how many times you have booked with us
• Information about your booking and any additional information we may need to help meet your specific requirements.

If you are a property owner and choose to let your holiday accommodation with us we will collect details such as:

• Name;
• Address;
• Email address;
• Telephone number;
• Bank details for rental income payments;
• Details regarding the accommodation you wish to let.

Sensitive personal data:

Certain categories of personal information, such as race, ethnicity, religion, health, or sexuality are special categories of data requiring additional protection under the law and are referred to as "sensitive personal data". 

On occasion we may gather data for health and safety purposes including any accident report or claim log or any information you provide about allergies or other medical conditions or disabilities. For example, you may request wheelchair assistance. We may pass this information on to the airline you are travelling with if you have booked flights with us and also notify our overseas representatives.

Personal data you provide about someone else:

If you provide personal data to us about someone else you must ensure that you are entitled to disclose that personal data to us and that, without our taking any further steps, we may collect, use and disclose that personal data as described in this Privacy Policy. You must ensure the individual concerned is aware of the various matters detailed in this Privacy Policy, as those matters relate to that individual, including our identity, how to contact us, the way in which we collect and use personal data and our personal data disclosure practices, that individual's right to obtain access to the personal data and make complaints about the handling of the personal data, and the consequences if the personal data is not provided.

6. How Do You Use My Personal Data?

Under the UK GDPR and The Data Protection Act 2018 (DPA) we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:

• Providing and managing your enquiry or booking.
• For providing property owners and property managers the necessary information they require for their tax submission and occupancy declaration (GIYKIMBIL/KBS registration) for their Turkish rental property. This is a requirement of the Turkish Authorities.
• Supplying our products and services to you. Your personal details are required in order for us to enter into a contract with you.
• Personalising and tailoring our products and services for you.
• Communicating with you. This may include responding to emails or calls from you.
• Supplying you with information by email and/or post that you have opted-in to (you may unsubscribe or opt-out at any time by advising us in writing, by telephone or using an unsubscribe link at the bottom of an email).
• To enable us to advertise your holiday accommodation, transfer payments due to you and to provide related support services (if you are letting your holiday accommodation through us);
• For statistical purposes when we evaluate our range of services;
• To tell you about other products and services we think may be of interest to you (see below).
• For the development, delivery and improvement of our products and services, marketing, customer relationships and experiences in the provision of products and services to our customers. 

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and/or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the UK GDPR and The Data Protection Act 2018 (DPA) and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.

7. How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

• Passport data is deleted at the end of the year in which the booking was completed.
• 6 years to comply with HMRC requirements.
• If you have previously booked with us we will keep your data indefinitely so we can apply our loyalty scheme benefits for any future bookings.
• If you have opted in to our email marketing, your data will be kept until the point you opt out or unsubscribe.
• For photoshoot bookings your data will be kept for 12 months following the date of your photoshoot.
• Recorded phone calls are deleted after 90 days.

Where your information is no longer required, we will ensure it is either disposed of or deleted in a secure manner or anonymised, for example by aggregation with other data so that it can be used in a non-identifiable way for business planning.

8. How and Where Do You Store or Transfer My Personal Data?

The Turquoise Collection acts as the data controller. We share your personal data with companies known as data processors who handle your data on our behalf. These are I-Pro Software Ltd, Trust Payments, BT Cloud phone.

We are committed to keeping your personal data safe and secure. Your information is stored in our computerised CRM and reservation database system, which is hosted by I-Pro Software Ltd. Constant Contact with marketing communications.

Card payments are made through a secured site hosted by Trust Payments and is compliant with the Payment Card Industry Data Security Standard (PCI).

We also share your data with third parties who help us fulfil your booking requirements, namely airlines, car hire and transfer companies, boat operators, photographers and property owners or their appointed representatives.

In some countries, the law requires passport details to be logged with the local authorities. In these instances, we may share them directly with the property owner, property manager or their appointed representative to pass on to the local authorities.

If you have raised a complaint, we may share your data with legal bodies.

Where we share your data with external third parties, as detailed below in Part 9 that are based outside of the EEA. The following safeguards are applied to such transfers:

We use specific contracts with external third parties for the transfer of personal data to third countries. These contracts ensure the same levels of personal data protection that would apply under the UK GDPR and The Data Protection Act 2018 (DPA). 

Please contact us using the details below in Part 11 for further information about the particular data protection mechanism used by us when transferring your personal data to a third country.

The security of your personal data is essential to us and to protect your data, we take a number of important measures, including the following:

• Email encryption.
• Password protected documents
• Limited access

9. Do You Share My Personal Data?

We may sometimes contract with the following third parties to supply products and/or services to you on our behalf. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.

• Payment processors for credit/debit cards
• Property management companies
• Property maintenance companies
• Hotel management
• Owners
• Airlines
• Transfer companies
• Car hire companies and other suppliers;
• Photographers

If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party's obligations under the law, as described above in Part 8.

If any personal data is transferred outside of the EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the UK GDPR and The Data Protection Act 2018 (DPA), as explained above in Part 8.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we areinvolved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

10. How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a "subject access request".

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is 'manifestly unfounded or excessive' (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 30 days and normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

11. How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:

Email address: enquiries@theturquoisecollection.com.

Telephone number: +44 1449 770811.

Postal Address: Suites S3-S4 Stevens House, 17 Station Road West, Stowmarket, Suffolk, IP14 1EF.

12. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be made available on our website www.theturquoisecollection.com.

13. How Do You Use Cookies?

We use Cookies to improve your experience on Our Site, to recommend content that may be of interest to you and for website traffic analysis and reporting. 

You can indicate your acceptance to our use of cookies in accordance with this policy by clicking 'Accept' in the appropriate place on the banner that appears on Our Site or by continuing to use Our Site after the banner has been shown. However, please note that if you do not click 'Accept' but continue to browse Our Site, you will be deemed to have accepted our use of cookies (and what we use them for) in accordance with this Privacy Policy.

By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. 

First-party Cookies are those placed directly by us and are used only by us to facilitate and improve your experience of Our Site and to provide and improve our products and services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using Our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on OurSite for website traffic analysis and reporting, marketing and to identify trusted web traffic. For more details, please refer to the table below. 

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling usto better understand how Our Site is used. This, in turn, enables usto improve Our Site and the products and services offered through it.

The analytics services used by Our Site uses Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable us to continually improve Our Site, making it a better and more useful experience for you.

All Cookies used by and on Our Site are used in accordance with current Cookie Law.

Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be "strictly necessary". These Cookies are shown in the tables below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

and the following third-party Cookies may be placed on your computer or device:

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently and may include but is not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

 14. Links to other websites

This Privacy Policy only applies to The Turquoise Collection. If you link to another website from this website, you should remember to read and understand that website's privacy policy as well. We do not control unconnected third-party websites and are not responsible for any use of your personal data that is made by unconnected third party websites.