TSN24 Ltd T/A Media Flights
The purpose of this notice is to be transparent about how and why we use your personal data and to ensure that you are aware of your rights under UK data protection legislation (UK General Data Protection Regulation (UK GDPR), Data Protection Act 2018).
We are TSN24 Ltd trading as Media Flights and we are the data controller. Our correspondence address is The Light Box, 111 Power Road, London W4 5PY. You can contact us at firstname.lastname@example.org or on 020 3637 8977
The purpose for processing your data and our basis for doing so.
We process personal data so we can provide our specialist services to our clients and this includes providing air and rail reservations, private flight services and associated activities. We also use your personal data for invoicing purposes and to maintain communication.
In processing your data, we must establish our legal basis for doing so and the legal basis can be different depending on the purpose we use it for.
To register you as a client, we will process contact details such as your name, telephone number, email address and physical address. The lawful basis for this is Article 6.1.b UK GDPR – performance of a contract.
If we book travel for you then we will also process additional personal data in the form identifiers such as passports, driving licences, visas as well as date of birth. The lawful basis for this processing is Article 6.1.b UK GDPR – Performance of a contract.
We may process information which is optional, such as special assistance or dietary requirements, we do this on behalf of the carrier and as such act as their data processors.
All other optional data is processed with the lawful basis of Article 6.1.f UK GDPR – legitimate interest, which is to ensure the traveller receives the best service available.
We will use your personal data to maintain communication with you, and to send information about our services that we feel would be of interest. The lawful basis for this processing is Article 6.1.f UK GDPR – legitimate interest, as we have a legitimate commercial interest maintaining our client base and expanding our business.
We process your personal data for invoicing purposes with the lawful basis of Article 6.1.b – performance of a contract.
There may be extreme circumstances, in an emergency, where it will be necessary to process your personal data in your vital interests, when you are unable to provide your own consent. This is accordance with Article 6.1.d – Vital Interests
We require your personal data to enter a contract to supply our services and to fulfil all the requirements of domestic and international travel. If you fail to provide the required personal data, we will not be able to provide our services to you.
We may receive your personal data from a third party, such as employers or management companies which are facilitating travel on your behalf.
Recipients of your data
As a general principle, we will not transfer your personal data to other recipients without your permission. There are some exceptions to this:
If you do not pay your bills, we may choose to engage a third party to recover any money you owe us. Our lawful basis for doing this is Article 6.1.f - we have a legitimate interest to pursue money owed to us.
It is possible, though unlikely, that we might be forced to disclose your information in response to a court order or other legal requirement. Our lawful basis for doing this is Article 6.1.c - Legal Obligation
His Majesty’s Revenue and Customs will also receive limited personal data as will Companies House through our financial reporting requirements. Our lawful basis for sharing this is Article 6.1.c – performance of a legal obligation.
We will share your personal data with airlines, hotels, couriers, hire companies and associated services. Our lawful basis for this is Article 6.1.b – performance of a contract.
Data processed by third parties on our behalf.
We use the services of other organisations in the processing your data. We use cloud based email and encrypted document storage solutions. We also use IATA approved international global ticketing solution, and travel management and administration software.
Those organisations that process personal data on our behalf are subject to a data processing contract as required by Article 28 of the UK GDPR. This ensures that your data is handled in accordance with the UK GDPR.
Transferring your data outside of the UK
Data is held in the UK, Canada and the USA. The transfer of data to Canada is performed under a recognised adequacy decision and the USA, via Standard Contractual Clauses approved by the EU and currently valid for UK use.
We will retain your data only for the time we require it for the purposes stated. The criteria for retention is determined by legal obligation or other legitimate purpose.
We will keep client data used for accounting purposes for a minimum of 7 years. This is to comply with HMRC audit requirements.
The UK GDPR provides you with several rights in relation to the data we process. The rights relevant to our activities are:
You have the right to get access to and copies of your personal data.
You can ask us to rectify any inaccurate information we may be holding.
You can restrict our processing of your data
You can object to us processing any personal data we process under a legitimate interest basis.
You have the right of data portability
If you want to exercise any of these rights, contact us on the above email address.
You also have the right to lodge a complaint about our processing with a supervisory authority — the UK's Information Commissioner's Office.
Information Commissioner's Office
Telephone: 0303 123 1113