Privacy Policy

UK GDPR, Data Protection Act 2018 & Data Use and Access Act 2025 Compliant

Effective: 1 July 2026 | Eagle Spirit Travel Limited | Reg. No. 15910187

1. Who We Are and How to Contact Us

Eagle Spirit Travel Limited is the data controller responsible for your personal data.

Company name: Eagle Spirit Travel Limited

Company registration number: 15910187

Registered address: 19 Mount Road, Wibsey, Bradford, BD6 3BA, United Kingdom

Email: info@eaglespirittravel.co.uk

Telephone: +44 7853 117 228

Website: www.eaglespirittravel.co.uk

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 (www.ico.org.uk, telephone 0303 123 1113). We would appreciate the opportunity to address your concerns before you approach the ICO — please contact us in the first instance.

2. Data We Collect About You

2.1 Information You Give Us

Identity: full name, date of birth, nationality, passport number and expiry date
Contact: email address, telephone number, postal address
Booking: tour preferences, departure dates, room type, special requests, dietary requirements, emergency contact name and number
Health: any medical conditions, disabilities, or reduced mobility voluntarily disclosed for tour suitability
Payment: billing name and address (payment card numbers are processed solely by our payment provider — we do not store them)
Communications: records of correspondence by email, telephone, or post
Marketing preferences: records of consent to receive marketing communications

2.2 Information Collected Automatically

Technical: IP address, browser type and version, operating system, device type
Usage: pages visited, time on site, links clicked, referral source
Cookies: as described in our Cookie Policy below

3. How and Why We Use Your Personal Data

We will only use your personal data when the law allows us to. The legal basis for each processing activity is set out below.

Booking and fulfilment: Processing your reservation, confirming your booking, managing payments, and fulfilling all elements of your tour. Legal basis: Contract.

Pre-departure communications: Sending your itinerary, visa guidance, health advice, flight-meeting instructions, and packing information. Legal basis: Contract.

Sharing with suppliers: Sharing necessary personal data with our ground operators, accommodation providers, transport companies, and local guides in Japan, India, and Vietnam. Legal basis: Contract.

Financial protection: Sharing booking and payment data with our financial protection provider as required to maintain PTR insolvency protection arrangement. Legal basis: Contract and legal obligation (PTR 2018).

Legal and regulatory compliance: Complying with the PTR 2018, UK GDPR, tax, accounting, and other legal obligations. Legal basis: Legal obligation.

Emergency management: Sharing information with emergency services, consular authorities, and medical providers during your tour. Legal basis: Vital interests and legitimate interests.

Marketing: Sending newsletters, destination inspiration, and tour promotions where you have opted in. Legal basis: Consent. You may withdraw consent at any time.

Website improvement: Using anonymised analytics to understand how our website is used and improve it. Legal basis: Legitimate interests.

4. Special Category Data

Health information you voluntarily disclose (such as medical conditions or mobility requirements) is special category data under UK GDPR. We process this data on the basis of your explicit consent, solely to assess tour suitability, make appropriate arrangements, and safeguard your wellbeing during travel. This data is shared only with suppliers who require it for your safety. It will not be used for any other purpose and will be deleted within 3 months of your tour completion.

Ground operators, accommodation providers, transport companies, and local guides in Japan, India, and Vietnam — to fulfil your tour
Our financial protection provider
Our IT infrastructure, website hosting, and email service providers
Legal, accounting, and professional advisors
HMRC and other UK regulatory authorities where required by law
Emergency services and consular authorities in emergency situations

We do not sell your personal data to any third party. We do not share your data with third parties for their own marketing purposes. All third-party processors are required to handle your data in accordance with UK GDPR and are bound by appropriate data processing agreements.

6. International Data Transfers

To deliver your tour, we necessarily share personal data with suppliers in Japan, India, and Vietnam. These countries do not have data protection frameworks equivalent to the UK. We ensure all international transfers are made using appropriate safeguards, including standard contractual clauses (SCCs) and, where applicable, transfer risk assessments as required under UK GDPR and the Data Use and Access Act 2025. For further information on the safeguards in place for any specific transfer, please contact us at info@eaglespirittravel.co.uk.

7. Data Retention

Booking, financial, and payment records: 7 years from the date of tour completion (legal and tax compliance requirement)
Health and special category data: deleted within 3 months of tour completion unless ongoing relevance
Marketing data and consent records: retained until you withdraw consent, or after 3 years of inactivity
General correspondence: 3 years from the date of last contact
Website analytics data: 26 months (anonymised and aggregated)

After the relevant retention period, personal data is securely and permanently deleted or irreversibly anonymised.

Right of access: request a copy of the personal data we hold about you (Subject Access Request)
Right to rectification: correct inaccurate or incomplete data
Right to erasure: request deletion where there is no legitimate purpose for continued retention
Right to restriction: ask us to restrict processing in certain circumstances
Right to data portability: receive your data in a structured, commonly used, machine-readable format
Right to object: object to processing based on our legitimate interests, or to direct marketing at any time
Right to withdraw consent: at any time where processing is based on consent, without affecting the lawfulness of prior processing
Rights relating to automated decision-making: we do not use automated decision-making that produces legal or significant effects on you
Right to complain: lodge a complaint with the ICO at www.ico.org.uk or 0303 123 1113

To exercise any of the above rights, contact us at info@eaglespirittravel.co.uk or by post at 19 Mount Road, Wibsey, Bradford, BD6 3BA, United Kingdom. We will respond within one calendar month of receiving your request. We may ask you to verify your identity before actioning your request.

9. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. Our measures include encrypted data transmission (TLS), access controls limited to authorised personnel, secure password policies, and periodic security reviews of our systems and key suppliers.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the ICO within 72 hours of becoming aware of it. Where the breach is likely to result in a high risk to your rights, we will notify you without undue delay.

10. Marketing

We will send you marketing communications only where you have opted in. Every marketing email includes a clear and functional unsubscribe link. You may also opt out at any time by emailing info@eaglespirittravel.co.uk or writing to us at our registered address. Opting out of marketing does not affect our ability to send you service-related communications about your booking.

11. Automated Decision-Making

We do not use automated decision-making processes, including profiling, that produce legal or similarly significant effects on you.

12. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in the law, regulation, or our data practices. We will notify you of material changes by email (where we hold your email address) and by posting the updated policy on our website with a revised effective date.

Last updated: 1 July 2026

Eagle Spirit Travel Limited | Registered in England and Wales | Company No. 15910187 | 19 Mount Road, Wibsey, Bradford, BD6 3BA, United Kingdom