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

• Company Name: The Turquoise Collection Ltd. (Tour Operator registered in England under company number 06541977)

• Registered & Main Trading Address: Suites S3-S4 Stevens House, 17 Station Road West, Stowmarket, Suffolk, IP14 1EF.

• VAT Number: 2250 2043 53

• Email: enquiries@theturquoisecollection.com

• Telephone: +44 1449 770811

• 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 UK General Data Protection Regulation (UK GDPR) as 'any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier'.

In simpler terms, personal data covers obvious information such as your name and contact details, as well as less obvious information such as identification numbers, electronic location data, and online identifiers.

The UK data protection framework is established under the UK GDPR, the Data Protection Act 2018 (DPA 2018), and the Data (Use and Access) Act 2025 (DUAA 2025).

4. What Are My Rights?

Under UK data protection law, you have the following rights, which we will always work to uphold:

• The right to be informed about our collection and use of your personal data.

• The right to access the personal data we hold about you (see Part 10).

• The right to rectification if any personal data held by us is inaccurate or incomplete.

• The right to erasure (the right to be forgotten).

• The right to restrict or object to the processing of your personal data.

• The right to data portability for data provided directly to us with consent or under contract.

• Rights regarding automated decision-making and profiling. Where automated processing occurs, you have the right to request human intervention, express your point of view, and contest decisions. (Note: We do not currently conduct automated decision-making with legal or significant effects).

• The right to submit an internal complaint: You have the statutory right to lodge a privacy complaint directly with us. We are legally required to acknowledge your complaint within 30 days and investigate without undue delay (see Part 11).

Escalation: If you remain unsatisfied with our internal response, you retain the right to escalate your complaint to the Information Commission.

5. What Personal Data Do You Collect?

We collect personal information depending on your relationship with us:

• Booking & Enquiry Data: Name, date of birth, address, email address, telephone number, passport details, payment details, travel preferences, and specific booking requirements.

• Property Owners: Name, address, contact details, bank details for rental disbursements, and property management attributes.

• Special Category (Sensitive) Data: Medical conditions, disability details, or allergies explicitly provided by you to arrange assistance (e.g., wheelchair handling or dietary requests).

• Third-Party Data: If you supply details for other members of your travelling party, you confirm that you have their permission to share their information under these terms.

6. How Do You Use My Personal Data?

We rely on contract performance, legal obligations, explicit consent, or legitimate interests to process your data. Uses include:

• Fulfilling travel bookings, property management, and customer queries.

• Submitting mandatory overseas guest registrations (e.g., Turkish GIYKIMBIL/KBS regulatory registration).

• Direct marketing where you have consented or where legally permitted (you may opt out at any time).

• Recognised Legitimate Interests: Under the Data (Use and Access) Act 2025, we process data for statutory recognised legitimate interests-such as network/IT security, travel safeguarding/emergency response, and crime prevention-without requiring a separate Legitimate Interest Assessment (LIA).

7. How Long Will You Keep My Personal Data?

• Passport Details: Permanently deleted at the end of the calendar year in which your booking concludes.

• Financial & Tax Records: Retained for 6 years to satisfy HMRC statutory duties.

• Loyalty Scheme Records: Retained indefinitely for repeat clients to apply loyalty discounts, unless deletion is formally requested.

• Marketing Records: Retained until you opt out or unsubscribe.

• Photoshoot Bookings: Retained for 12 months post-session.

• Call Recordings: Retained for 90 days.

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

Your personal data is stored securely within computerised systems hosted by third-party CRM, CMS, and reservation software providers, cloud telephony operators, and email marketing platforms. Card payments are processed through secure, PCI-DSS compliant payment platforms.

International Data Transfers:

Because we operate international travel, data must be transferred to local service providers (airlines, property management teams, transfer operators) outside the UK/EEA. Safeguards for international transfers include:

• UK Adequacy Regulations.

• The UK Extension to the EU-U.S. Data Privacy Framework.

• Standard Data Protection Clauses via the UK International Data Transfer Agreement (IDTA) or the UK Addendum to EU Standard Contractual Clauses.

9. Do You Share My Personal Data?

We share your data strictly as necessary with the following categories of third-party processors and suppliers to fulfil our contractual obligations:

• Third-party CRM, CMS, and reservation system providers

• Secure payment processing platforms

• Cloud communications and telephony services

• Property owners, property management companies, and local maintenance teams

• Travel providers (airlines, local transfer operators, and car hire companies)

• Local excursion operators and photographers

• Law enforcement, legal bodies, or regulatory authorities where legally required

10. How Can I Access My Personal Data? (Subject Access Requests)

You can request details and copies of your personal data held by us:

• Scope: Searches conducted in response to a Subject Access Request (DSAR) will be reasonable and proportionate.

• Response Time & "Stop the Clock": We respond within 1 calendar month. If we require identity verification or reasonable clarification of your request, the 1-month response window pauses ("stops the clock") until that necessary information is provided.

• Fees: DSARs are provided free of charge unless deemed vexatious or excessive, in which case a reasonable administrative fee or refusal notice will apply.

11. Contact Us & Complaint Resolution

For any data protection inquiries or to submit a formal request or complaint, please contact us:

• Email: enquiries@theturquoisecollection.com

• Telephone: +44 1449 770811

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

Internal Complaint SLA: Upon receipt of a formal data protection complaint, we will send an official acknowledgment within 30 days and provide a substantive outcome following a prompt investigation.

12. Changes to this Privacy Policy

We reserve the right to amend this notice to reflect updates in operations or statutory law (including amendments under the Data (Use and Access) Act 2025). Updates are published directly on our website.

13. How Do You Use Cookies?

• Essential Cookies: Strictly necessary cookies operate automatically to deliver essential site functions.

• Non-Essential Cookies (Analytics & Marketing): Analytics and marketing cookies (such as Google Analytics) are loaded only after you grant explicit opt-in consent via our cookie banner. Continued site browsing without accepting does not constitute consent.

14. Links to Other Websites

This policy applies solely to The Turquoise Collection. We are not responsible for the privacy practices of external third-party sites linked from our platform.