This Policy sets out how Hovertravel uses and protects any personal data that you provide to Hovertravel or it collects (including personal data provided through the website www.hovertravel.co.uk (“Website”), where bookings are made or products are purchased or where personal data is uploaded to a manage my booking account (“Account”)). Hovertravel is committed to protecting your personal data and this Policy tells you about how Hovertravel may process your personal data and your privacy rights.
Hovertravel provides services to individuals in connection with booking travel arrangements and services (“Services”), and through providing Services to individuals it may collect and process personal data about individuals. In addition to this, the Website also collects certain personal data from visitors, as set out in this Policy.
Hovertravel is firmly committed to respecting and protecting the privacy of all personal data received or collected, in strict adherence to applicable data protection legislation. Hovertravel has established this Policy so that you can understand the care with which Hovertravel intend to treat your personal data.
How to contact us
Hovertravel has a Data Protection Officer who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy or regarding your personal data and how Hovertravel may use it, including any requests to exercise your legal rights, please contact the Data Information Manager at firstname.lastname@example.org or writing to our “Data Protection Officer” at the head office address noted above.
It is important that the personal data Hovertravel holds about you is accurate and current. Please keep Hovertravel informed if your personal data changes during your relationship with us.
For the purpose of applicable data protection legislation where personal data is provided directly to Hovertravel through use of the Website, your Account, bookings, the purchase of products, email exchange, meeting with you or other means where Hovertravel is determining the way in which that personal data is processed, then Hovertravel will be a data controller of such information.
Personal data and Basis for Collection
Personal data means any data or information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
Where Hovertravel is acting as a data controller, Hovertravel may collect, use, store and transfer different kinds of personal data about you which Hovertravel has grouped together as follows:
- Identity Data includes first name, last name, username or similar identifier, title, date of birth, gender, and passport or national identity card information;
- Contact Data includes postal address, user name, email address and telephone numbers;
- Financial Data includes credit / debit card details or other payment information;
- Transaction Data includes details about payments to and from you and other details of travel services you have purchased from Hovertravel, including one off purchases or purchase of season tickets;
- Technical Data includes internet protocol address, browser type and versions, time zone setting and location, browser plug-in types and versions and platform and other technology on the devices you use to access our Website;
- Profile Data includes purchases or bookings made by you, your interests, preferences, feedback and survey responses;
- Usage Data includes information about how you use our Services or submit an enquiry or query through our Website;
- Marketing and Communications Data includes your preferences in receiving marketing from Hovertravel and its third parties and your communication preferences;
- Individual Data additional information collected from you in relation to the Services Hovertravel provide, this may include your photograph;
- Medical Data includes information about any health matters that Hovertravel need to know about in order to provide its Services, including disabilities or medical conditions which may require access and assistance adjustments. This will also include information about accidents that occur during any journey.
Hovertravel do not process criminal convictions data.
If you fail to provide personal data
Where Hovertravel needs to collect personal data by law, or under the terms of a contract Hovertravel has with you (or a client whom Hovertravel acts for) and you fail to provide that data when requested, Hovertravel may not be able to perform the contract it has or is trying to enter. In this case, Hovertravel may have to cancel the Services but it will notify you (or where appropriate, its client) if this is the case at the time.
How is your personal data collected?
Hovertravel uses different methods to collect personal data from and about you including through:
- Direct interactions: you may give Hovertravel your contact information by filling in forms, through your Account, contacting or engaging with Hovertravel through social media, or by corresponding with Hovertravel by post, phone, email or otherwise. This includes personal data you provide when you purchases travel Services from Hovertravel (including the purchase of one-off tickets or season tickets for travel), when Hovertravel provide your travel arrangements; or
- Enquiries: when made through your Account, the Website or by email, including requests for a brochure or further information relating to the Services Hovertravel offer; or
- Participation: if you participate in a competition, survey or other offer that Hovertravel might make available to you; or
- Third parties or publicly available sources: Hovertravel may receive personal data about you from various third parties and public sources such as contact data from providers or from third party boking agents; or
- Automated technologies or interactions: as you interact with your Account, the Website, Hovertravel may automatically collect Technical Data about your equipment, browsing actions and patterns. Hovertravel collect this personal data by using cookies. Please see our Cookies Policy.
- Telephone interaction: Hovertravel may take your details during telephone calls in relation to your Identity Data, Transaction Data, Contact Data, Financial Data, Profile Data and Marketing Data.
- Live Chat functionality: Hovertravel have a live chat functionality on the Website, to help you with queries relating to our Services. This will collect your internet protocol address, location, operating system and browser used and allow Hovertravel to contact and interact with you for the purposes of seeking to resolve your query. It also records details of the pages on the Hovertravel website that you visit and the page you were redirected from to visit the Website.
- Photographs/recordings: Hovertravel may take photographs of you because: (i) Hovertravel may need to include your photograph on an identity card issued to you for confirming the purchase of a season ticket and for the purposes of ensuring that the correct person is using the season ticket following purchase by you; and/or (ii) for monitoring of security at the Hovertravel Terminal, including the on-boarding and off-boarding of passengers. This may include the use of CCTV, to monitor the safety and wellbeing of passengers, see our CCTV section below for more information.
CCTV Fair Processing
We currently use CCTV to view and record individuals inside buildings and around the perimeter and entrances of the Hovertravel’s terminals, and on-board Hovertravel’s craft (“Sites”). As a result of the CCTV at our Sites, we will process personal information of employees, directors, officers, consultants, contractors, workers, customers, passengers and other members of the public, including visitors.
Hovertravel uses CCTV to:
- to prevent crime, anti-social behaviour and protect buildings and assets from damage, disruption, vandalism and other crime;
- for the personal safety of staff, customers, passengers and other members of the public and to act as a deterrent against crime;
- to prevent staff from being at risk from unsafe working practices; and
- preventing or reducing the risk of uncontrolled or unauthorised access within the Sites.
CCTV is located at various locations throughout the Sites, with appropriate signage displayed. The CCTV continuously records footage 24 hours a day at each location. Footage is recorded on a 30 day loop.
CCTV locations are chosen to minimise viewing of spaces not relevant to the legitimate purpose of the monitoring. As far as practically possible, CCTV will not focus on private property and are not hidden from public view.
Hovertravel monitors its CCTV footage internally and does not appoint an external provider to undertake such monitoring.
In appropriate circumstances, Hovertravel may:
- allow law enforcement agencies to view or remove CCTV footage where this is required in the detection or prosecution of crime; or
- share CCTV footage with insurers if there is a notifiable event.
Footage is only transferred (in a secure manner) to hard copies following an incident or request made with the approval of Data Protection Officer. In such this will be logged accordingly.
You may make a request for disclosure of you personal information and this may include CCTV images as set out in the ‘Your Rights’ section below.
How Hovertravel uses your personal data
Hovertravel will only use your personal data when the law permits it, i.e., if Hovertravel has a legal basis for doing so, as outlined in this Policy. If Hovertravel needs to use your personal data for an unrelated purpose, Hovertravel will notify you and will explain the legal basis which allows Hovertravel to do this.
Please note that Hovertravel may process your personal data without your knowledge or consent, where this is required or permitted by law. Where Hovertravel act as the data controller, Hovertravel have set out below in the table a description of all the ways Hovertravel plan to use your personal data, and which of the legal bases Hovertravel rely on to do so. Hovertravel have also identified what our legitimate interests are, where appropriate.
Note that Hovertravel may process your personal data for more than one lawful ground depending on the specific purpose for which Hovertravel are using your data. Please contact Hovertravel if you need details about the specific legal ground Hovertravel are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer and verify your identity (where required) and/or to provide you with travel arrangements and our Services
Performance of a contract with your consent (for use of Medical Data)
To manage the relationship with you which will include:
review or take a survey
Performance of a contract with you Necessary to comply with a legal obligation Necessary for Our legitimate interests (to keep Our records updated and to study how customers use Our services)
To process and deliver the Services including:
Performance of a contract
To respond to queries, complaints and enquiries
Legitimate interests (to improve and manage Services)
To undertake marketing to you
Consent, unless Hovertravel’s legitimate interests apply and this does not adversely affect your rights as a data subject
To administer and protect Hovertravel’s business and this Website (including troubleshooting data analysis, testing, system maintenance, support, reporting and hosting of data)
To record details of accidents on board or at the terminals
To investigate and resolve actual and potential claims and complaints against us
Necessary for our legitimate interests (to ensure complaints are fairly addressed)
How your personal data may be shared
Where Hovertravel act as the data controller, personal data processed by Hovertravel may be shared as follows:
- with any member of the Hovertravel Group, which means Hovertravel’s subsidiaries, Hovertravel’s ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006 in respect of support or services they provide to Hovertravel (including but not limited to the provision of the live chat functionality);
- where Hovertravel is under a duty to disclose your personal data to comply with any legal obligation, or to enforce or apply Hovertravel’s or terms and conditions and other agreements;
- to protect the rights, property, or safety of Hovertravel, Hovertravel’s clients, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and for compliance with laws;
- with the authorities or other regulatory or official purpose, as may be appropriate for regulatory purposes;
- with third parties to whom Hovertravel may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, Hovertravel 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 Policy;
- Hovertravel’s professional advisors including lawyers, accountants, insurers and bank, where required as part of the professional services provided to Hovertravel.
- Service providers acting as processors of Hovertravel such as IT and administrations service providers.
Third party travel service providers
- To fulfil your booking arrangements, appropriate personal data will be passed on to the relevant suppliers of your arrangements / any third party supplier / any other third party (including banks and/or credit card issuers) who need to process your personal data so that your holiday can be provided. This may include third parties to whom Hovertravel transfer your booking to such as Wightlink Limited. The information may also be provided to government / public authorities such as customs or immigration if required by them, or as required by law.
- Hovertravel will generally use other companies to help provide your travel services, including transport providers, attractions, hotels, ground handlers and guides, as well as when Hovertravel mail brochures and send marketing material. Hovertravel only provide third parties with the personal data they require in order to deliver their services and their use is limited to the services they provide.
- If Hovertravel cannot pass your personal data to the relevant suppliers, Hovertravel will be unable to fulfil your booking.
Hovertravel require all third parties to respect the security of your personal data and to treat it in accordance with the law. Hovertravel 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.
Many of Hovertravel’s external third parties are based outside the of the UK and European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the UK and EEA.
Whenever Hovertravel transfer your personal data to countries outside of the UK and EEA to other people or companies it will be for one of the legal bases for processing your personal data as indicated above. Where Hovertravel do so, Hovertravel will take all steps to ensure that any country to which the personal data has been transferred it puts in place suitable protection mechanisms to protect personal data, including (if applicable) use of Standard Contractual Clauses.
Marketing and opting out
Hovertravel strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. Hovertravel may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what it thinks you may want or need, or what may be of interest to you. This is how Hovertravel decide which products, services and offers may be relevant for you. You will only receive marketing communications from Hovertravel if you have either requested information from us, or you have previously purchased travel arrangements (and have not opted out from receiving Hovertravel marketing communications).
You can opt-out of receiving marketing communications from Hovertravel or update your preferences at any time by contacting email@example.com and by providing your full name, address and postcode and the email address which you would have originally used. Alternatively you can click on the unsubscribe link located in the footer of all marketing communications from Hovertravel.
Hovertravel has 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, Hovertravel 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.
Hovertravel 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 Hovertravel are legally required to do so.
Other than in relation to government / public authorities (over whom Hovertravel have no control), Hovertravel take appropriate steps to ensure that anyone to whom Hovertravel pass your personal data for any reason agrees to keep it secure, only uses it for the purposes of providing their services and does not collect any personal data from you in the course performing their services.
Hovertravel has put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where Hovertravel are legally required to do so.
Personal Data Retention
Hovertravel will keep your information for as long as Hovertravel need it for the purpose it is being processed for. For example, where you make travel arrangements Hovertravel will keep the information related to your booking, so Hovertravel can fulfil the specific travel arrangements you have made and after that, Hovertravel will keep the information for a period which enables Hovertravel to handle or respond to any complaints, queries or concerns relating to the booking. The information may also be retained so that Hovertravel can continue to improve your experience.
Hovertravel will actively review the information it holds and delete it securely, or in some cases anonymise it, when there is no longer a legal, business or customer need for it to be retained.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:
- The right to be informed: this is information on for what purpose Hovertravel are processing it and what personal data Hovertravel are processing.
- The right of access: you have the right to be provided with copies of the personal data of you that Hovertravel are processing as well as confirmation of the processing Hovertravel are doing. You can do this by sending a “subject access request” to the contact details noted above for our consideration.
- The right to rectification: if you think the personal data that Hovertravel hold on you is wrong you can tell Hovertravel and Hovertravel will fix it.
- The right to erasure: (also known as the right to be forgotten) – if you want Hovertravel to permanently delete the personal data Hovertravel hold for you then you can ask Hovertravel to do so.
- The right to restrict processing: if you do not like how Hovertravel are using your personal data then you can let Hovertravel know and Hovertravel will stop processing it in that way.
- The right to data portability: if you want Hovertravel to pass on your personal data to someone else then please let Hovertravel know. This transfer should not affect the integrity or otherwise damage your personal data.
- The right to withdraw your consent: you can withdraw your consent for Hovertravel to process your personal data (if Hovertravel have relied on your consent to process your personal data) at any time by contacting Hovertravel. If Hovertravel have relied only on your consent as the basis to process your personal data then Hovertravel will stop processing your personal data at the point you withdraw your consent. Please note that if Hovertravel can also rely on other bases to process your personal data aside from consent then Hovertravel may do so even if you have withdrawn your consent.
- Rights in relation to automated decision making and profiling: if Hovertravel use either automated decision making or profiling then you have a right to know. Also, Hovertravel needs your consent if either of these are used to make a decision that affects you. As with all consent, you can withdraw it at any time.
To exercise any of the above rights please email your request to: firstname.lastname@example.org.
Where you exercise your right to erasure or where information is deleted in accordance with Hovertravel’s retention policy, please note that after the deletion of your personal data, it cannot be recovered, so if you require a copy of this personal data, please request this during the period Hovertravel retains the data.
Where you exercise your right to request access to the information Hovertravel processes about you, you will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, Hovertravel may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
Alternatively, Hovertravel may refuse to comply with your request in these circumstances. Hovertravel will try to respond to all legitimate access requests within one month. Occasionally it may take Hovertravel longer than a month if your request is particularly complex or you have made a number of requests. In this case, Hovertravel will notify you and keep you updated.
If you believe that any of your personal data which Hovertravel are processing is inaccurate or incorrect please contact Hovertravel by emailing email@example.com.
The Website is not intended for children and Hovertravel will not knowingly collect any personal data from persons under the age of 18. Where, as part of the Services being provided and travel arrangements being put in place, Hovertravel collects information about children to perform such services Hovertravel will treat such information securely.
If you would like to make a complaint in relation to how Hovertravel may have stored, used or processed your personal data, you have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). Hovertravel would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact Hovertravel in the first instance.
Remember the Risks Whenever You Use the Internet
Hovertravel is committed to ensuring that your information is secure and has in place reasonable and proportionate safeguards and procedures to protect your personal data. Whilst Hovertravel does its best to protect your personal data, Hovertravel cannot guarantee the security of any information that you transmit to Hovertravel and you are solely responsible for maintaining the secrecy of any passwords or, other account information.
Hovertravel reserves the right to update this Policy from time to time. This Policy was last updated on 22nd December 2021.