GDPR Compliance

Last updated: January 2024

Our Commitment to GDPR

lush-spark is committed to ensuring compliance with the General Data Protection Regulation (GDPR) and protecting the rights of individuals whose personal data we process. This page provides information about how we handle your data in accordance with GDPR requirements.

Data Controller

lush-spark acts as the data controller for personal information collected through our website and travel services. This means we determine the purposes and means of processing your personal data.

Contact details:
lush-spark
47 Kensington High Street
London W8 5ED
United Kingdom
[email protected]

Lawful Basis for Processing

We process personal data under the following lawful bases:

• Contract: Processing necessary for the performance of a contract with you (e.g., arranging your travel bookings)
• Legitimate Interests: Processing necessary for our legitimate business interests, where not overridden by your rights
• Legal Obligation: Processing necessary to comply with legal requirements
• Consent: Where you have given clear consent for specific purposes

Your Rights Under GDPR

Under GDPR, you have the following rights regarding your personal data:

Right of Access

You have the right to request copies of your personal data. We may charge a small fee for this service if the request is manifestly unfounded or excessive.

Right to Rectification

You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.

Right to Erasure

You have the right to request that we erase your personal data, under certain conditions. This right is not absolute and may be subject to legal obligations we need to fulfill.

Right to Restrict Processing

You have the right to request that we restrict the processing of your personal data, under certain conditions.

Right to Object to Processing

You have the right to object to our processing of your personal data, under certain conditions.

Right to Data Portability

You have the right to request that we transfer the data we have collected to another organisation, or directly to you, under certain conditions.

Exercising Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within one month. If your request is complex or you have made numerous requests, we may extend this period by a further two months, but we will inform you of any such extension within the first month.

Data Transfers

When you book travel outside the European Economic Area (EEA), we may need to transfer your personal data to travel suppliers in those destinations. In such cases, we ensure appropriate safeguards are in place to protect your data, including:

• Standard contractual clauses approved by the European Commission
• Working only with suppliers who maintain adequate data protection standards
• Transferring only the minimum data necessary for your booking

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected. Booking records are typically retained for seven years to comply with legal and accounting requirements. Marketing preferences are retained until you withdraw consent.

Data Security

We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including:

• Encryption of data in transit and at rest
• Regular security assessments
• Staff training on data protection
• Access controls limiting data access to authorised personnel

Data Breach Notification

In the event of a personal data breach that poses a high risk to your rights and freedoms, we will notify you without undue delay. We will also notify the Information Commissioner's Office (ICO) within 72 hours of becoming aware of any breach, where required.

Complaints

If you are unhappy with how we have handled your personal data, you have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (ICO):

Information Commissioner's Office
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
www.ico.org.uk

Updates to This Information

We may update this GDPR information from time to time. Any changes will be posted on this page with an updated revision date.