PRIVACY POLICY

Total Management UK Ltd, Total Management US, LLC and our affiliated group entities (“Total Management”) are committed to protecting and respecting your privacy, whilst offering the best service and experience. We follow strict security procedures on the holding and usage of personal data. This privacy notice will inform you as to how we (acting as controller) look after your personal data and tell you about your privacy rights and how the law protects to you.

This privacy notice aims to give you information on how Total Management collects and processes your personal data through your use of this website, our services, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition, as well as when you apply for a job with us. This website is not intended for children.

It is important that you read this privacy notice so that you are fully aware of how and why we are using your personal data.

We will comply with applicable data protection laws and principles, which means that your personal data will be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only as long as necessary for the purposes we have told you about.
• Kept securely.

We use different methods to collect personal data for instance you may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when corresponding with Total Management or place a request for services with Total Management and includes circumstances in which you:

• Apply for our products or services;
• Complete booking transaction;
• Subscribe to our service or publications;
• Request marketing to be sent to you;
• Enter a competition, promotion or survey;
• Give us some feedback; or
• Apply for a job.

 

Use of Cookies

We use cookies and other similar technologies to distinguish you from other users of our website. This helps us to provide you with a better experience when you use the website and allows us to improve it. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or mobile device. For example, cookies can be used to collect information about your use of the website during your current session and over time (including the webpages you view and the files you download), your operating system and browser type, your internet service provider, your domain name and IP address, the website that you visited before our website, and the link that you use to leave our website. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies. You can also disable cookies on the website using the cookie options banner that pops up when landing on our website. However, if you choose to block or delete cookies, certain features of the website may not operate correctly. For more information see www.allaboutcookies.org.

We use Google Analytics to help collect and analyse certain information about you (such as your interests).

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 personal data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our website, we encourage you to read the privacy notice of every website you visit.Third parties or publicly available sources

We may receive personal data about you from various third parties and public sources as set out below:

• Technical data from analytics providers, such as Google.
• Identity and contact data from publicly availably sources (such as Companies House).

Personal data (also known as personal information), means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

• Identity Data: includes first name, maiden name, last name, username or similar identifier, marital status, title, passport details, date of birth and gender.
• Contact Data: includes billing address, delivery address, email address and telephone numbers.
• Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
• Financial Data: includes bank account and payment card details.
• Transaction Data: includes details about payments to and from you and other details of products and services you have purchased from us and other relevant transactional information.
• Technical and Usage Data: includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to interact with or access information and how you use our website, products and services.
• Job Application Data: includes employment history (previous jobs, dates, roles), education, skills and qualifications (certifications, technical abilities), work experience summaries, cover letter content, CV details and interview notes.

 

We may collect certain special categories of personal data about you (such as dietary requirements and medical conditions if required for the purpose of the services as well as information such as your religion if for example you specific a meal preference that indicates a particular religion). We do not collect any information about criminal convictions and offences.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract, we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal, business or regulatory obligation.
• When you consent to it.

 

We do not rely upon consent as a legal basis for processing personal data other than in relation to sending third party direct marketing communications to you via email or other means. We have set out below the ways in which we use your personal data:

• To manage your booking.
• To contact you with information and detail about your booking.
• To personalize your customer experience.
• To improve our service.
• To send you marketing material.
• To ensure security and protect business interests.
• To process job applications.
• To use data analytics.
• To company with legal obligations.

 

We do not use your personal data to carry out any automated decision making.

Marketing Material and Practice

We will keep you up to date with our latest offers, partnerships, sales, promotions, competitions that we think might be of interest/relevance to you. We will only contact you in this way if:

• You have signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.
• You have requested information from us or entered a competition or registered for a promotion and provided your details and you have not told us that you do not want to hear from us.
• You have made a booking with us and have not told us that you do not want to hear from us.

 

You may opt-out from receiving marketing material from us at any time by either clicking the unsubscribe option in our emails, or by contacting info@total-management.com.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We require all third parties to respect the security of your personal data and to treat it in accordance with applicable data privacy laws. We do not allow our third-party service providers who process personal data on our behalf 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. We may have to share your personal data with the parties set out below:

• Third party suppliers we work with to provide your booking and other services i.e airlines, tour operators, transport companies, excursion providers, airport authorities, insurance companies, car hire, event venues.
• Other suppliers we work with in connection with our business. This might include marketing agencies, IT developers, services providers, software companies and credit card screening companies.
• Credit references and fraud prevention agencies and professional advisers (including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services).
• Tax authorities (e.g. HM Revenue & Customs in the UK), regulators and other authorities who require reporting of processing activities in certain circumstances.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we 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 privacy notice.

 

International Transfer

Where we share your personal data with other Total Management group companies and certain third-party service providers, this may involve transferring your personal data outside the country it was originally collected.  Those countries may not have similar data protection laws as the ones where the personal data was transferred from, so may not protect the personal data to the same standard. In those instances, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy notice. These steps include:

• Relying on decisions issued by the relevant authority (e.g. UK Secretary of State, European Commission or other relevant US governmental body) declaring that a recipient or country is adequately protective of personal data to a degree that allows us to safely transfer your personal data to that recipient or country.
• Entering into approved standard contractual clauses that govern the transfer of the personal data to that recipient or country.
• Relying on any international frameworks that allow recipients to certify that they can receive your personal data safely and process it in a manner that is protected to an equivalent standard as the country where the personal data was collected.

We have security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to your personal data to those employees, agents, contractors and other third parties who require the personal data for the purpose of a transaction or service on your behalf. Your personal data will remain confidential and only be used on our authority.

We have developed policies and procedures regarding personal data breaches and will notify you of any relevant personal data breach (where we are legally required to do so).

We will only retain your personal data for as long as necessary in accordance with our data retention timelines to fulfil the purposes of use, including; legal, human resources, accounting, or reporting requirements.

For the purpose of tax and accounting, we are required by law to retain information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after the final transaction. In some circumstances you can ask us to delete your personal data (see section 10 below for more details).

In some circumstances we may 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.

Under certain circumstances, you have rights under applicable data protection laws in relation to your personal data.

• Access: We will confirm to you whether or not we are processing and using personal data about you, at your request and, if so, provide you with access to and a copy of such personal data and the other details to which you are entitled.
• Rectification: We will correct any inaccurate personal data and complete any incomplete personal data (including by providing a supplementary statement) that we hold about you.
• Erasure: We will erase your personal data at your request without undue delay where there is no good reason for us to continue to use it.
• Restriction: We will restrict the processing of your personal data in certain circumstances, if you ask us to do so.
• Data portability: We will provide you or third parties on your behalf with a copy of any personal data that we hold about you which you have provided to us in a structured format.
• Objections: We will respect your general rights to object to the processing of your personal data in certain circumstances, including opting out of direct marketing.
• Withdrawing consent: Where we rely on consent to process your personal data, you may withdraw your consent at any time. If you withdraw your consent, our use of your personal data before you withdraw is still lawful.

 

If you wish to exercise any of the rights set out above, please contact us using the details at the bottom of this privacy notice. We try to respond to all legitimate requests within one month. Occasionally it may 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.

Applicable fees

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 may refuse to comply with your request in these circumstances. We implement security measures to confirm your identity when requesting personal data and may ask for specific information before we are able to release personal data.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

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.

You have the right to make a complaint at any time to the relevant supervisory authority (for example, this is the Information Commissioner’s Office (ICO) in the UK). We would, however, appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the below information.

 Contact details

Total Management UK Ltd

Email address: dataprotection@total-management.com

Postal address: Matrix Studios, 91 Peterborough Road, SW6 3BU

Telephone number: 02073846308

or

Total Management US, LLC

Email address: dataprotection@total-management.com

Postal address: One Liberty Plaza, New York City, New York, 10006

Telephone number: 212 915 9332