Home > Privacy Policy salessupport@claritybt.com WHO WE ARE WHAT WE DO NEWS CONTACT LOGIN Privacy policy Introduction Welcome to Clarity’s Privacy Notice. This Notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone or via our booking systems) and tell you about your privacy rights and how the law protects you. We are committed to respecting and protecting your privacy whilst remaining compliant with the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA). In line with this objective we operate an Information Security Management System which is certified against ISO 27001:2013 and a Personal Information Management System aligned with the BS 10012:2017 standard. This Privacy Notice is provided in a layered format so that you can easily click through to the specific areas set out below. Alternatively, you can download a pdf version of the Notice here. If there is any terminology used in the Notice that you are unfamiliar with or that you don’t fully understand, please refer to the Glossary set out at the end. 1. IMPORTANT INFORMATION AND WHO WE ARE Purpose of this Privacy Notice This Privacy Notice aims to give you information on how Clarity collects and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone or via our booking channels) when you make bookings of travel services, when you take part in a competition, complete a survey, or if you report a problem with our website, etc. This website is not intended for children. It is important that you read this Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Notice supplements the other notices and is not intended to override them. Controller Mawasem Limited, trading as Clarity, is the Controller and responsible for your personal data (collectively referred to as “Clarity”, "we", "us" or "our" in this Privacy Notice). We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Notice. If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below. Contact details Our full details are: Full name of legal entity: Mawasem Limited trading as Clarity Name or title of DPO: Lois Haynes Email address: DPO@claritybt.com Postal address: Clarity, c/o IT Compliance, 4th Floor, Churchgate House, 56 Oxford Street, Manchester M1 6EU 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 (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. Changes to the Privacy Notice and your duty to inform us of changes We keep our Privacy Notice under regular review. This version was last updated on October 14th 2020 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us. Third-party links This website may include links to third-party websites, plug-ins and applications. 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 notice of every website you visit. 2. THE DATA WE COLLECT ABOUT YOU 3. HOW YOUR PERSONAL DATA IS COLLECTED 4. HOW WE USE YOUR PERSONAL DATA 5. HOW WE DISCLOSE YOUR PERSONAL DATA 6. WHEN WE TRANSFER YOUR DATA OVERSEAS 7. HOW WE SECURE YOUR DATA 8. HOW LONG WE RETAIN YOUR DATA FOR 9. YOUR LEGAL RIGHTS 10. GLOSSARY LAWFUL BASIS • Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights 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). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. • Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. • Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to. THIRD PARTIES • Internal Third Parties Other companies in the Mawasem Limited Group acting as joint controllers or processors and who are based in the United Kingdom and provide IT and system administration services and undertake leadership reporting. • External Third Parties i. Suppliers of travel services acting as processors based in the country to which you are travelling and who provide the travel services that make up any booking of travel services that you make with us. ii. Service providers acting as processors based in the European Union who provide IT and system administration services. iii. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the European Union who provide consultancy, banking, legal, insurance and accounting services. iv. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the United Kingdom who require reporting of processing activities in certain circumstances. Clarity maintains an online register of technology and service providers whom we define as Other or ‘sub-’ processors of personal information according to data protection legislation. This can be found here. YOUR LEGAL RIGHTS You have the right to: • Request access to your personal data (commonly known as a "data 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. 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) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it. • 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. 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. Find out how brighter business travel can boost your bottom line. GET IN TOUCH WHO WE ARE MEET THE TEAM CAREERS WHAT WE DO OUR TECHNOLOGY GO2BOOK GO2TRACK GO2INSIGHT FLIGHTS RAIL TRAVEL HOTELS TRAVEL EXTRAS BRIGHTER EVENTS SPORTS TRAVEL EXPERIENCES DESTINATION SPORT EXPERIENCES MORE TRAVEL ADVICE: CORONAVIRUS (COVID-19) TRAVEL ADVICE: BREXIT AND NAVIGATING EUROPE TERMS & CONDITIONS TERMS OF USE PRIVACY POLICY COOKIE POLICY MODERN SLAVERY STATEMENT TAX STRATEGY GENDER PAY REPORTING We are a SAP Concur partner, the leader in travel expense management. 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