Privacy Policy

EFFECTIVE DATE: 04/10/2019

This Privacy Policy governs and tells you the manner in which Hillwalk Tours Ltd. collects, uses, maintains and discloses information collected from persons who access and use the https://www.hillwalktours.com website and all products and services offered by Hillwalk Tours Ltd.

In collecting this information, Hillwalk Tours are acting as a data controller and, by law, we are required to provide you with information about us, about why and how we use your data, and about the rights you have over your data.

Throughout the policy you will see the terms “we”, “us” and “our” which refer to Hillwalk Tours, while other terms such as “you” and “your” refer to any person using our website, products or services.

Who are we?
Collection of Personal Data Information
Third party websites
Changes to this privacy policy
Your rights over your information
Your right to complain

1. Who are we?

We are Hillwalk Tours Limited. Our address is 6 Galway Technology Centre, Mervue Business Park, Wellpark Road, Galway, H91 A560, Ireland. You can contact us by post at the above address, by email at dataprotection@hillwalktours.com or by telephone on +353 91 763994.

We are not required to have a data protection officer, so any enquiries about our use of your personal data should be addressed to the contact details above.

2. Collection of Personal Data Information

We collect personal data information from you in a variety of ways; automatically through the use of web browser cookies, information that you provide directly to us via email communication, and information that you provide directly to us via forms on our website (i.e. newsletter sign up, booking form, contact us form, live chat dialog, gift card purchase etc…).

The following sections are further detail as to what personal data information we collect from you at each point, why we collect this information, what we do with this information, and how long we keep this information for.

2.1 Information Collected from Cookies

What personal data do we collect?
- Through accessing our website we automatically collect information using web browser cookies or, ‘cookies’, as it’s more commonly known. Cookies are small data files stored on your hard drive or in device memory that help us improve our website and your experience, and track usage of our website. We use third party software called Google Analytics which records this data from your cookie and are considered to be a third-party data processor, in terms of your information.
- Google Analytics collects and records data from your cookie in the following manner;
  - Log Information – Information is collected about your use on our website to include; the type of browser that you use, the time, duration and frequency of your access, website pages viewed.
  - Device information – Information is collected about the device you are using while accessing our website to include; the hardware model, operating system and version, unique device identifiers, and mobile network information.
  - Location & Demographics Information – Information is collected with regards to where you are accessing our website from, through the location of your device, and general demographics, to include; an approximate geographical location, age range and gender.
- Although Google Analytics records and collects this data none of this information personally identifies you to us. Google Analytics does record your devices IP address which could be used to personally identify you but Google do not grant us access to this.
Why do we collect this information?
- We collect this information in order to operate and maintain our website, along with improving the user experience of the website. We also use the information to manage the performance of our website and to monitor and analyse trends, usage, and activities in connection with our website.
How long do we keep your information for?
- We hold this information in our Google Analytics account for a period of 50 months from when you first access our website. After this period, information held about your website visit will be removed.
- If you do not wish to consent to the collection of this information, you can 1) stop using our website or 2) disable cookies on your internet browser which will stop the collection and recording of data from Google Analytics from tracking any part of your visit to our website.

2.2 Information Collected from our Newsletter Signup

What personal data do we collect?
- When you subscribe to our newsletter, we ask you for your name and email address. On occasions we may ask for additional personal data e.g. city, country etc…
Why do we collect this information?
- We collect this information in order to send you our newsletter, which contains information about our products, special offers, company news and other information, in a more personalised manner.
- We ask for your consent to do this through you submitting your information via our newsletter sign up forms or providing you with an option to opt-in to our newsletter. We will only send you our newsletter for as long as you continue to consent.
- If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
What do we do with your information?
- If you choose to join our regular newsletter mailings (which is sent via email), the information that you submit to us will be stored in our third party Mailchimp account which we use for our email marketing. We consider Mailchimp to be a third-party data processor, in terms of your information.
- The Mailchimp database is stored in the US and the platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles.
- Your information will remain on our newsletter list within the Mailchimp database for as long as we continue to use the Mailchimp platform for email marketing or until you specifically request removal from the list.
- While your email address remains within the Mailchimp database, you will receive occasional newsletter-style emails from us.
- We will not pass, share or sell your information to any other third parties. Your data will only be used for the purposes of our email marketing under your consent.
How long do we keep your information for?
- Your information is kept for as long as you continue to consent to receive our newsletter.
- If you no longer want to receive our newsletter or for us to use your information – the simplest way to do this is to withdraw your consent, which you can do at any time, either by clicking the unsubscribe link at the end of any newsletter or request removal via email.

2.3 Information Collected from Enquiries

What personal data do we collect?
- When you make an enquiry with us using our ‘contact us’ form on our website, we ask you for your first name, last name, country of origin, contact telephone number and email address information.
- If you make an enquiry with us directly i.e. email to email without the use of our online form, we collect the information you have voluntarily provided which can include your email address, first name, last name, country of origin and telephone number.
Why do we collect this information?
- We collect this information in order to process your enquiry with us and fulfil our service in a personalised manner, which can include us sending emails to your email address in regards to your enquiry or contacting you via your telephone number with regards to your enquiry.
- We ask for your consent to do this through you submitting your information via our contact us form or through your own voluntary consent when sending an enquiry to us directly.
- Hillwalk Tours will never ask you for any sensitive information.
What do we do with your information?
- Your information is stored in our secure and encrypted CRM/Booking system, which is based within the European Union, in order to process and fulfil your enquiry.
- We will not pass, share or sell your information to any other third parties. Your data will only be used for the purposes of processing and fulfilling our service under your consent.
How long do we keep your information for?
- Through submitting your enquiry via the form on our website or through sending us an enquiry directly to us, you consent that your information can be retained in our CRM/Booking system for as long as you continue to consent for your information to be stored there. By allowing us to store your information, it not only helps us fulfil and process your initial enquiry, but also helps us provide you with a better service in future if you enquire about our products or services again.
- If you no longer want your information to be stored in our CRM/Booking system – the simplest way to do this is to withdraw your consent, which you can do at any time, by requesting its removal via email.

2.4 Information Collected from our Live Chat

What personal data do we collect?
- When you communicate with us via our Live Chat form, we ask you for your name and email address.
Why do we collect this information?
- We collect this information in order to fulfil your live chat enquiry/request in a more personalised manner and to suitably apply any information/requests from the live chat to any of our services purchased by you.
- We ask for your consent to do this through you submitting your information via our live chat form.
What do we do with your information?
- If you choose to use our live chat facility when it is online, the information that you submit to us will be stored in our third party LiveChatInc account which we use to communicate with you to fulfil your enquiry/request. Additional data such as your geographical location, IP address, device used and browser used are recorded by LiveChatInc to ensure we provide the best service possible to you during your Live Chat session with us. We consider LiveChatInc to be a third-party data processor, in terms of your information.
- The LiveChatInc database is stored in the US and the platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles.
- If you choose to use our live chat facility when it is offline, the information that you submit to us will be stored in our third party LiveChatInc account and a ticket created which is then forwarded to and stored in our secure CRM/Booking system which is based within the European Union, in order to process and fulfil your Live Chat ticket. Your name and email address, along with the content of your enquiry/request is the only data stored in both the LiveChatInc and our CRM/Booking System.
- So as to best fulfil any services purchased by you, your information submitted by Live Chat will remain within the LiveChatInc & our own CRM/Booking System database for as long as we continue to use those platforms or until you specifically request your data to be removed from our systems. Apart from communication in relation to your live chat enquiry/request, we will never use your information for marketing purposes.
- We will not pass, share or sell your information to any other third parties. Your data will only be used for the purposes of our Live Chat under your consent.
How long do we keep your information for?
- Your information is kept for as long as you continue to consent to receive our newsletter.
- If you no longer want to receive our newsletter or for us to use your information – the simplest way to do this is to withdraw your consent, which you can do at any time, either by clicking the unsubscribe link at the end of any newsletter or request removal via email.

2.5 Information Collected from our Booking Form

What personal data do we collect?
- When you make a booking with us on our website using our booking form, we ask you for your name, address, contact telephone number, email address, gender, date of birth and any allergies or dietary requirements information; and we ask for the first name, last name and age of any other participants on your tour/booking.
- We also ask you for your credit/debit card information to process payment via Paypal or Stripe but we never collect and store your card details.
Why do we collect this information?
- We collect this information in order to process your tour/booking with us which can include us sending emails to you in regards to your tour/booking, contacting you via your telephone number with regards to your tour/booking and posting your tour/booking information pack to your postal address provided.
- Your credit/debit card information is used to verify your card details and to process payment for the purchase of your tour/booking with us.
- We require this information to process your payment, complete your tour/booking and fulfil our contract with you.
What do we do with your information?
- Your information is stored in our secure CRM/Booking system which is based within the European Union, in order to process and fulfil your booking.
- We use both Paypal and Stripe, third party online payment systems, to process your credit/debit card details for payment for any bookings made on our website. Neither PayPal nor Stripe retain any financial information you may submit as part of the booking process. PayPal and Stripe monitor every transaction, 24/7, to prevent fraud, email phishing and identity theft. Every transaction is heavily guarded behind advanced encryption.
- If you purchase your tour/booking via bank transfer payment, information about you and your transaction will be stored in our relevant Allied Irish Bank (AIB) or Ulster Bank bank accounts, whichever you made payment to, in order to process your transactions. Every transaction within these bank accounts are heavily guarded behind advanced encryption.
- On occasions, we may use Waveapps to send you an invoice(s) requesting payment for your tour/booking, in which case your first name, last name and email address are used to process the invoice.
- PayPal, Stripe, AIB, Ulsterbank, Waveapps or Hillwalk Tours will never ask for any sensitive information.
- In order to process and fulfil your tour/booking, we share your first name, last name and telephone number, along with the first name and last name of other participants on your tour/booking, with our third party suppliers which we book on your behalf and which are being used as part of your tour/booking.
- We will not pass, share or sell your information to any other third parties not associated with your tour/booking. Your data will only be used for the purposes of processing and fulfilling your tour/booking under your consent.
How long do we keep your information for?
- Through acknowledging this privacy policy and submitting your tour/booking via the form on our website, you consent that your information can be retained in our CRM/Booking system for as long as you continue to consent for your information to be stored there. By allowing us to store your information, it not only helps us fulfil and process your initial tour/booking, but also helps us provide you with a better service in future if you enquire about our products or services again.
- If you no longer want your information to be stored in our CRM/Booking system – the simplest way to do this is to withdraw your consent, which you can do at any time, by requesting its removal via email.

2.6 Information Collected from Gift Card Purchase

What personal data do we collect?
- When purchasing a gift card from us, we ask you for your first name, last name and email address and the name of the recipient and their email address (optional) on the gift card form.
- We also ask you for your credit/debit card information to process payment via Paypal but we never collect and store your card details.
Why do we collect this information?
- We collect this information in order to process your gift card purchase with us and to fulfil the service satisfactorily which can include us sending emails to you or your chosen recipient in regards to the gift card.
- Your credit/debit card information is used to verify your card details and to process payment for the purchase of your gift card with us. We require this information to process your payment, complete your gift card purchase and fulfil our contract with you.
What do we do with your information?
- Your information is stored in our secure CMS system, Joomla, which is hosted on our Liquidweb web hosting account in order to process and fulfil your purchase. The Liquidweb database is stored in the US and the platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles.
- We use Paypal, a third party online payment system, to process your credit/debit card details for payment for any gift card purchases made on our website. PayPal does not retain any financial information that you may submit as part of the checkout process. PayPal monitor every transaction, 24/7, to prevent fraud, email phishing and identity theft. Every transaction is heavily guarded behind advanced encryption.
- PayPal or Hillwalk Tours will never ask for any sensitive information.
- We will not pass, share or sell your information to any other third parties not associated with your gift card purchase. Your data will only be used for the purposes of processing and fulfilling your purchase under contractual agreement.
How long do we keep your information for?
- Through acknowledging this privacy policy and submitting your purchase via the gift card checkout form on our website, you consent that your information can be retained in our systems for as long as you continue to consent for your information to be stored there. By allowing us to store your information, it not only helps us fulfil and process your purchase, but also helps us provide you with a better service in future if you enquire about our products or services again.
- If you no longer want your information to be stored on our systems – the simplest way to do this is to withdraw your consent, which you can do at any time, by requesting its removal via email.

2.7 Information Collected from Surveys

What personal data do we collect?
- Where you have given us previous consent (e.g. via a newsletter signup) to be contacted by us, we may send you surveys from time to time as a result.
- In instances where you have received a survey from us, but have not given prior consent for your data to be processed by us, you will be asked for your consent before filling out the survey. By providing consent through the completion & submission of the survey, we may send you future surveys.
- There is no obligation for you to fill out or complete these surveys.
- The surveys may ask you for personal information such as your first name, last name, age, country or city of residence, email address, household size, household income, education levels, employment status, and further questions in relation to your lifestyle, behaviours, attitudes, and opinions.
Why do we collect this information?
- We collect this information in order to help us better understand customer behaviour and buying trends, along with helping us to further improve our products and services in the future.
What do we do with your information?
- Your survey information will be collected using Google Forms, unless otherwise stated. As a result, all information will thereby be stored in our secure Google Drive account. Google Drive storage, is a product of Google, and therefore is stored on secure & heavily guarded Google servers worldwide. Their platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles.
- In instances where we may use an alternative method of collecting information from surveys, we will ensure that your information is stored and processed on a platform that offers a high level of security.
- Information provided by you from our surveys will not be passed, shared or sold to any other third parties. Your data will only be used for the purposes of helping us better understand customer behaviour and buying trends in order to further improve our products and services to you.
How long do we keep your information for?
- Through acknowledging this privacy policy and by completing & submitting a survey, you consent that your information can be retained in our systems for as long as you continue to consent for your information to be stored there, or where our research has reached a natural conclusion resulting in your data no longer being required to be stored in our systems and thus permanently removed (whichever is earliest). By allowing us to store your information, it helps us to undertake further research into customer behaviours & buying trends over time which assists in the ongoing improvement of our products and services.
- If you no longer want your information to be stored on our systems – the simplest way to do this is to withdraw your consent, which you can do at any time, by requesting its removal via email.

2.8 Information Collected from Competitions

What personal data do we collect?
- When entering one of our competitions, we may ask you for your first name, last name, email address and postal address (if the prize requires posting).
Why do we collect this information?
- We collect this information in order to process & fulfil the transfer of the prize to the winner(s) of the competition.
What do we do with your information?
- Your competition information will be collected using Google Forms, unless otherwise stated. As a result, all information will thereby be stored in our secure Google Drive account. Google Drive storage, is a product of Google, and therefore is stored on secure & heavily guarded Google servers worldwide. Their platform complies with the EU-US Privacy Shield Framework and the Swiss-US privacy shield framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information transferred from the European Union to the United States, and therefore adheres to the Privacy Shield Principles.
- In instances where we may use an alternative method of collecting information for competitions, we will ensure that your information is stored and processed on a platform that offers a high level of security.
- Information provided by you for entering our competitions will not be passed, shared or sold to any other third parties. Your data will only be used for the purposes of helping us process and fulfil the transfer of the prize to the eventual winner(s) of the competition.
How long do we keep your information for?
- Through acknowledging this privacy policy and by entering a competition, you consent that your information can be retained in our systems for as long as you continue to consent for your information to be stored there, or where our competition has reached a natural conclusion resulting in your data no longer being required to be stored in our systems and thus permanently removed (whichever is earliest). By allowing us to store your information, it helps us process and fulfil the competition.
- If you no longer want your information to be stored on our systems – the simplest way to do this is to withdraw your consent, which you can do at any time, by requesting its removal via email.

3. Third party websites

You may find content on our website that links to other third party websites. We do not control the content or links that appear on these sites and are not responsible for the practices employed by websites linked to or from our website. In addition, these websites or services, including their content and links, may be constantly changing. These third party websites and services may have their own privacy policies and customer service policies. Through browsing and interacting on any of these third party websites means that you and your personal information is subject to that website’s own terms and policies.

4. Changes to this privacy policy

Hillwalk Tours Ltd. has the discretion to update this privacy policy at any time. When we do, we will post a notification on the main page of our website. We encourage you to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree that it is your responsibility to review this privacy policy periodically and become aware of modifications.

5. Your rights over your information

As a data subject, you have the following rights under data protection legislation:

the right of access to personal data relating to you.
the right to correct any mistakes in your personal data.
the right to ask us to stop contacting you with direct marketing.
rights in relation to automated decision taking.
the right to restrict or prevent your personal data being processed.
the right to have your personal data ported to another data controller.
the right to erasure.
the right to complain to the Data Protection Commissioner if you believe we have not handled your personal data in accordance with the data protection legislation.

We will respond to any rights that you exercise within a month of receiving your request, unless the request is particularly complex or cumbersome, in which case we will respond within three months (we will inform you within the first month if it will take longer than one month for us to respond).

Where a response is required from us within a particular time period pursuant to data protection legislation, we will respond within that time period.

To submit a request with regards to information held about you, you can do so by email, post or telephone, using the contact information provided under the ‘Who We Are’ section, at the start of this policy.

6. Your right to complain

If you have a complaint about our use of your information, you can contact the Office of the Data Protection Commissioner via their website, through email at info@dataprotection.ie or by writing to them at:
Office of the Data Protection Commissioner
Canal House
Station Road
Portarlington
Co. Laois
R32 AP23
Ireland

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