1. IMPORTANT INFORMATION AND WHO WE ARE

This privacy statement gives you information about how Travelfusion collects and uses your personal data through your use of our website and the Services, your registration and use of our platform as a travel agent or business representative, your interactions with our B2B content distribution and payment services, including processing of booking data on behalf of passengers.

This website is not intended for children and we do not knowingly collect data relating to children.

Where we act as a Controller

Travelfusion Limited is the data controller and responsible for your personal data where you use this website as an agent.

If you have any questions about this privacy policy, including any requests to exercise your legal rights (Your legal rights), please contact us using the information set out in the Contact details section (Contacts).

2. THE TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU

Personal data means any information about an individual (a “data subject”) from which that person can be identified, either directly or indirectly when combined with other information.

Categories of Personal Data we Process

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

• Your interactions with us. You may give us your personal data by filling in online forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
  • create an account on our website;
  • subscribe to our services;
  • make bookings through our platform; or
  • contact us for support or enquiries and correspond with us by email, phone or other means.
• Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies, server logs and analytical tools and security monitoring systems. Please see our Cookie Policy for further details.

4. HOW WE USE YOUR PERSONAL DATA

Legal basis

Under UK data protection law, we must have a legal basis for collecting and using your personal data. We rely on the following legal bases:

• Performance of a contract with you: Where processing is necessary to perform our contract with you or your organisation, or to take steps before entering into a contract.
• Legitimate interests: Where processing is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We rely on the following legal bases:
  • Operating and improving our B2B platform;
  • Preventing fraud and ensuring platform security;
  • Conducting business analytics to enhance our services;
  • Managing our business relationships; and
  • Ensuring network and information security.
• Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to, including tax and accounting obligations and anti-money laundering requirements. We will identify the relevant legal obligation when we rely on this legal basis.
• Consent: Where you have given clear, specific consent for us to process your personal data for particular purposes. You can withdraw consent at any time.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Automated Decision-Making

We do not currently engage in solely automated decision-making that produces legal effects or similarly significant effects on individuals. If this changes, we will update this privacy statement and inform affected individuals.

5. COOKIES

We use cookies and similar technologies to enhance your experience on our platform. For more information about the cookies we use and how to change your cookie preferences, please see our Cookie Policy.

6. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data where necessary with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above:

• other companies within the Travelfusion Limited group for business administration and service provision;
• business providers and service providers, including:
  • travel suppliers: Airlines, hotels, car rental companies, and other travel service providers to complete bookings;
  • payment processors: To process payments and prevent fraud;
  • technology providers: Cloud hosting services, IT support, and software providers; and
  • professional advisers: Lawyers, accountants, auditors, and other professional service providers (airlines, train and/or hotel providers) and customers (online travel agents) of our business as necessary to finalise the booking transaction;
• regulatory and legal requirements, including regulatory authorities and government agencies where required by law, law enforcement agencies in connection with legal proceedings and courts and tribunals where necessary for legal proceedings.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We 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.

7. INTERNATIONAL TRANSFERS

We share your personal data within the Travelfusion Limited group of companies (the Travelfusion Group). This will involve employees within the Travelfusion Group accessing your data outside the UK. This is deemed to be a transfer of your personal data.

Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same level of data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring that the following safeguards are implemented:

• Standard Contractual Clauses: We use the International Data Transfer Agreement approved for use in the UK. To obtain a copy of these contractual safeguards, please contact us using the Contact details set out in Contacts).
• Additional Safeguards: Technical and organisational measures to protect data during transfer and processing.

Transfers to Third Parties

We may transfer your personal data to corporate suppliers (airlines, train and/or hotel providers) and customers (online travel agents) of our business as necessary to finalise the booking transaction for passengers. This may involve transferring personal data outside the UK to countries which have laws that do not provide the same level of data protection as the UK law.

Whenever we transfer your personal data out of the UK to corporate suppliers and/or customers, we ensure protection through the following safeguards:

• Adequacy decisions: We will only transfer your personal data to countries that have been deemed by the UK to provide an adequate level of protection for personal data, namely, the European Economic Area, Andorra, Argentina, Canada (commercial organisations only), Faroe Islands, Guernsey, Isle of Man, Israel, Japan (private-sector organisations only), Jersey, New Zealand, Switzerland and Uruguay.
• Standard Contractual Clauses: For transfers to countries without adequacy decisions, we use UK-approved standard contractual clauses (International Data Transfer Agreement). To obtain a copy of these contractual safeguards, please contact us using the Contact details set out in Contacts).

8. DATA SECURITY

We have 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, we 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.

We have put in place procedures to detect and investigate any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

9. DATA RETENTION

How long will you use my personal data for?

Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our suppliers and customers (including Contact, Identity, Financial and Booking Data) for six years after they cease being suppliers and customers for tax reporting purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

10. YOUR LEGAL RIGHTS

Under UK data protection law, you have the following rights in relation to your personal data:

• Request access to your personal data (commonly known as a "subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
• You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes. Please note, we do not currently use your personal data for direct marketing purposes.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data (see the table in section 4 for details of when we rely on your consent as the legal basis for using your data, if any). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us using the Contact details below (Contacts).

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. Contact details

If you have any questions about this privacy policy or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

• Email address: privacy@travelfusion.com
• Postal address: Attn: Legal Department, Travelfusion Limited, Level 10, 70 St. Mary’s Axe, London EC3A 8BE, England

12. Complaints

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

13. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated on 31 August 2025.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

14. Third-party links

This website may include links to third-party websites, plug-ins and applications, including Google Analytics. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.