Privacy Policy

Scope of this Policy

This Privacy Policy applies to websites, digital portals, landing pages, mobile interfaces, and online enquiry forms operated or powered by Zentrix Digital Holdings Limited and used in partnership with Gordon Sadler Travel.

This includes the DealsHub network, conversational travel discovery platforms such as SavvyTravelHub, specialist websites including NoFlyCruising, UltraLuxuryCruiseWorld and WineCruiseEurope, and related campaign pages or regional domains.

It also applies when you contact us by email, telephone, online form or another direct communication channel in connection with these platforms.

Who Is Responsible for Your Information

The organisation responsible for your personal information depends on the stage of your interaction.

Each organisation may act as an independent data controller for the processing it undertakes. They work together to ensure that an enquiry submitted through a covered platform reaches the appropriate travel specialist.

Information We Collect

Depending on how you use our platforms and whether you proceed to a booking, we may collect:

• Identity and contact details: your name, postal address, email address and telephone number.
• Travel preferences: destinations, dates, departure points, party size, accommodation or cabin preferences, budget, accessibility requirements, dietary needs, anniversaries and other information you include in an enquiry.
• Booking and payment information: itinerary details, supplier references, payment status and transaction records. Payment-card details may be handled directly by an authorised payment provider rather than stored by the websites.
• Correspondence: emails, call notes, form submissions, feedback, complaints and records of communications with us.
• Technical and usage information: IP address, browser and device type, operating system, referring pages, pages visited, approximate location, timestamps, cookie identifiers and security logs.
• Marketing preferences: your choices about receiving travel inspiration, offers or other promotional communications.

Travel requirements can sometimes reveal health, accessibility, religious or dietary information. We ask you to provide such information only where it is relevant. Where special category information is required, we use it only with your explicit consent or where another condition permitted by data protection law applies.

How We Collect Information

We collect most personal information directly from you when you complete an enquiry form, interact with a conversational travel tool, email or telephone us, request a quotation, make a booking, or ask for support.

We may also receive information from a travelling companion who includes you in an enquiry or booking; from a referring website or campaign; from travel suppliers and booking partners; from payment and fraud-prevention providers; or automatically through cookies, server logs and similar technology.

If you provide another person’s details, you should ensure that they understand how their information will be used and that you are authorised to provide it.

How We Use Information and Our Lawful Bases

UK data protection law requires us to have a valid reason, known as a lawful basis, whenever we use personal information.

Responding to enquiries

To understand your requirements, route your enquiry and prepare a tailored proposal. We rely on steps requested by you before entering into a contract and, where appropriate, our legitimate interests in operating an effective enquiry service.

Bookings and travel services

To confirm availability, administer bookings, collect payment, issue documents and provide customer support. We rely on performance of a contract or steps taken at your request before a contract.

Legal and regulatory duties

To maintain financial and booking records, protect customer funds, respond to regulators, prevent fraud and comply with applicable law. We rely on legal obligations and, where relevant, legitimate interests.

Platform operation and security

To operate, maintain, troubleshoot and protect our websites, systems and users. We rely on legitimate interests in maintaining secure and reliable digital services.

Service improvement

To understand aggregate usage, assess enquiry quality and improve journeys, content and matching tools. We rely on legitimate interests, using consent where non-essential cookies or similar technology require it.

Marketing

To send relevant travel inspiration or offers where you have asked to receive them, or where another lawful route is available. You can opt out at any time.

Where we rely on legitimate interests, we consider whether the use is necessary and balance our interests against your rights and reasonable expectations.

Artificial Intelligence and Profiling

Some platforms use artificial intelligence, including EmbarkOS, to interpret travel requirements expressed in your own words. The technology may identify likely preferences, organise enquiry information and help a travel specialist find relevant options.

This processing supports discovery and adviser efficiency. It does not make a booking, accept a payment, or make a decision that produces legal or similarly significant effects without meaningful human involvement. A Gordon Sadler Travel adviser reviews the relevant details before issuing a proposal or booking confirmation.

Please avoid entering information that is not necessary for your travel enquiry. You may ask for a human review or clarification of how your enquiry was handled by using the contact details below.

Who We Share Information With

We share personal information only where necessary for the purposes described in this policy. Recipients may include:

• Zentrix Digital Holdings Limited and Gordon Sadler Travel, so enquiries can be routed, answered and progressed.
• Cruise lines, tour operators, airlines, rail operators, ferry companies, hotels, transfer providers and other travel suppliers when preparing or fulfilling your chosen arrangements.
• Protected Trust Services and relevant payment, banking, accounting or fraud-prevention providers.
• Service providers supporting website hosting, email, customer relationship management, analytics, communications, document storage and information security.
• Professional advisers, insurers, auditors, regulators, law-enforcement bodies or courts where disclosure is necessary or required by law.

We require service providers acting on our behalf to protect personal information and use it only for the agreed purpose. We do not sell personal information to third-party advertisers.

International Transfers

Travel is international by nature. A booking may require us to send relevant personal information to suppliers or service providers outside the United Kingdom, including organisations in the country you will visit.

Where UK data protection law applies to a transfer, we use an approved safeguard where required. This may include a UK adequacy regulation, the UK International Data Transfer Agreement, the UK Addendum to approved contractual clauses, or a permitted exception where the transfer is necessary to perform your travel contract.

You can contact us for more information about the safeguard used for a particular transfer.

How Long We Keep Information

We retain personal information only for as long as it is reasonably needed for the purpose for which it was collected, including legal, accounting and dispute-resolution requirements.

Enquiries that do not become bookings

Normally up to 24 months after the last meaningful contact, unless you ask us to delete the information sooner or a longer period is required for a dispute.

Booking and transaction records

Normally for up to seven years after completion of travel, to meet tax, accounting, insurance and legal requirements.

Marketing records

Until you opt out, or after 24 months without meaningful engagement, subject to keeping a minimal suppression record so that we can respect an opt-out.

Website and security logs

Normally for up to 12 months, unless the information is needed for a security investigation or legal claim.

We may anonymise information so that it can no longer identify you. Anonymous information may be retained for statistical and service-improvement purposes.

How We Protect Information

We use proportionate technical and organisational measures to protect personal information against accidental loss, unauthorised access, alteration or disclosure. Measures may include access controls, account authentication, encryption in transit, secure hosting, backups, monitoring, staff procedures and supplier due diligence.

No internet service is completely secure. If we identify a personal data breach that creates a risk to your rights, we will take appropriate steps and notify you and the Information Commissioner’s Office where the law requires it.

Cookies and Analytics

Our platforms may use cookies and similar technology to keep pages working, remember choices, protect forms, understand website performance and measure marketing activity.

Strictly necessary technology may operate without consent where the law permits. We ask for consent before using non-essential analytics, advertising or personalisation cookies where consent is required. You can change your choices through the cookie controls made available on the relevant website and through your browser settings.

Further details are available in our Cookie Policy, together with any site-specific cookie panel provided by the platform you are visiting.

Your Data Protection Rights

Depending on the circumstances, you may have the right to:

• request access to the personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to erase information that we no longer need;
• ask us to restrict how information is used;
• object to processing based on legitimate interests or to direct marketing;
• receive certain information in a portable format;
• withdraw consent at any time where processing relies on consent; and
• ask for human intervention where a solely automated decision has a legal or similarly significant effect.

These rights are not absolute, and an exemption may apply in some circumstances. We may need to verify your identity before acting on a request. We do not normally charge a fee.

Marketing Choices

We may send travel inspiration, offers or service updates where you have asked to receive them or where another lawful route permits us to do so. Marketing preferences are kept separate from your ability to make an enquiry or booking.

You can stop marketing messages at any time by using the unsubscribe option in the message or by contacting us. Stopping marketing does not affect service messages that are necessary for an active enquiry or booking.

Children’s Information

Our websites are intended for adults arranging travel. They are not directed at children, and children should not submit enquiries independently.

We may need information about a child when an adult includes them in a family or group booking. The adult providing that information must have authority to do so. We use it only as necessary to arrange and support the travel services.

Contact Us and Make a Complaint

Please contact the organisation handling the relevant part of your interaction. If you are unsure, either contact can route your request appropriately.

Information Commissioner’s Office

If you remain concerned about how your personal information has been used, you have the right to complain to the Information Commissioner’s Office. You can find guidance and submit a complaint at ico.org.uk/make-a-complaint. We would appreciate the opportunity to address your concern first.

Changes to this Policy

We may update this Privacy Policy when our services, suppliers or legal obligations change. The current version will always be published at the canonical address shown above, together with its last-updated date.

If a change materially affects how we use information already collected, we will provide an additional notice where reasonably practicable or where the law requires it.