About this policy
This policy explains how Starlt Ltd, trading as travl.love, collects, uses and protects your personal information when you enquire with us, travel with us, use our website or hear from us.
Many of our clients value discretion. We treat everything you tell us about yourself, your family and your travel as confidential, and we only share it where we need to in order to arrange your trip, or where the law requires it.
This policy should be read together with our Booking Terms and Conditions.
1. Who we are
Starlt Ltd is the "controller" of your personal information, which means we decide how and why it is used.
- Company: Starlt Ltd, trading as travl.love, registered in England and Wales, company number 10803217
- Registered office: At Aston House Cornwall Avenue, London, N3 1LF
- Registered with the Information Commissioner's Office (ICO): registration number ZA895515
- Privacy contact: Nicola Wright, hello@travl.love
2. The information we collect
Depending on how you work with us, we may collect:
- Contact details: name, email address, phone and WhatsApp number, home address.
- Travel and booking details: names, dates of birth and nationalities of everyone travelling; passport numbers, issue and expiry dates; visa and travel authorisation details; frequent flyer and hotel loyalty numbers; flights, accommodation, transfers, restaurants and experiences booked; emergency contact details.
- Preferences: the trips you have loved and the ones that went wrong, how you like to travel, room and seat preferences, and anything else you tell us so that we can plan around you.
- Payment information: payment amounts, invoices and bank transfer details. Card payments are taken securely through the payment system provided by Protected Trust Services; we do not see or store your full card number.
- Insurance details: your travel insurance provider, policy number and emergency assistance number, so that we can add them to your itinerary.
- Special category information: health, mobility or accessibility needs, and dietary requirements (which may indicate religious beliefs). See section 5.
- Communications: emails, WhatsApp messages, call notes and enquiry answers.
- Website information: technical information such as your IP address, browser and pages visited, collected through cookies. See section 11.
3. Where we get it from
- From you: by WhatsApp, email, phone, our newsletter sign-up or in person.
- From the lead traveller: when someone books for a group, family or household, they give us details for the others travelling. If you book for others, please make sure they are happy for you to share their information and show them this policy.
- From people who introduce you: such as a partner, assistant, family office or referral partner who contacts us on your behalf.
- From suppliers: such as hotels, airlines and tour operators, when they send us confirmations or updates about your booking.
4. How we use it, and our legal reasons
The law requires us to have a lawful basis for each way we use your information.
- To plan, quote for and book your travel, issue your Travefy itinerary and look after you while you are away. Lawful basis: to perform our contract with you, or to take steps at your request before entering into one.
- To pass your details to suppliers so that they can provide your arrangements. Lawful basis: to perform our contract with you.
- To keep a record of your preferences so that we can plan future trips around you. Lawful basis: our legitimate interest in providing a personal service. You can ask us to stop at any time.
- To take payment, keep accounts and meet tax, financial protection and regulatory obligations (including to HMRC, Protected Trust Services and for ATOL). Lawful basis: legal obligation, and our legitimate interests.
- To share information with border, customs and immigration authorities where they require it. Lawful basis: legal obligation.
- To send you our newsletter and news about trips. Lawful basis: your consent, or, where you are an existing client, our legitimate interest in telling you about similar services. You can unsubscribe at any time.
- To handle complaints, claims and disputes. Lawful basis: our legitimate interests, and legal obligation.
- To run and improve our website. Lawful basis: your consent for non-essential cookies, and our legitimate interests.
5. Special category information
5.1Information about health, mobility, accessibility, and dietary or religious requirements is more sensitive, and the law gives it extra protection.
5.2We only collect it when you choose to give it to us, and we only use it to arrange suitable travel and pass it to the suppliers who need it (for example, a hotel, airline or restaurant). We rely on your explicit consent to do this. You can withdraw consent at any time, but we may then be unable to make arrangements that meet your needs.
5.3If you give us this information about someone else in your party, you confirm that they have agreed.
6. Children
We arrange travel for families, so we may hold information about children travelling with a parent or guardian. We only collect it from the adult responsible for the booking, and we use it only to arrange and look after the trip. Our website and newsletter are not aimed at children.
7. Who we share it with
We never sell your personal information. We share it only as follows:
- Travel suppliers: hotels, villas, airlines, cruise lines, tour operators, transfer and car companies, restaurants, experience providers and local agents who provide your arrangements.
- Booking and financial protection partners: Protected Trust Services (PTS), which holds client payments in trust and provides our booking and payments system, and ATOL franchise details via PTS.
- Airline booking systems: global distribution systems (such as Sabre) and airline systems used to book and ticket flights.
- Insurers: if we arrange travel insurance for you.
- Authorities: border, customs, immigration and security authorities in the UK and abroad (for example, US Customs and Border Protection), the police or courts, where the law requires it.
- Service providers who help us run the business, under contracts that require them to keep your information secure and use it only on our instructions: Travefy (itineraries), Monday.com (client records), Google Workspace (email and documents), Mailchimp (newsletter), WhatsApp (messaging), our accountants, IT support and website host GoDaddy and Lovable.
- Professional advisers: such as lawyers and insurers, where needed.
- A buyer: if our business is ever sold or restructured, under confidentiality obligations.
8. Sending information outside the UK
8.1Travel often means sharing your information with suppliers in other countries, including countries whose data protection laws are not as strong as the UK's. Where you ask us to book travel abroad, we transfer your information to those suppliers because it is necessary to perform our contract with you.
8.2Some of our service providers store information outside the UK, including in the United States. Where they do, we make sure appropriate safeguards are in place, such as the UK government's adequacy regulations (including the UK-US data bridge) or the ICO's approved international data transfer agreement.
9. How long we keep it
- Booking and financial records: 7 years after your trip ends, to meet tax and legal requirements and to deal with any claims.
- Passport and travel document details: deleted within 3 months of your return if requested, otherwise we keep them on file for future bookings in our secure database.
- Your travel preferences: while you remain an active client. If we have not heard from you for 5 years, we will delete or anonymise them.
- Enquiries that do not lead to a booking: 2 years.
- Newsletter: until you unsubscribe. We keep a record of the unsubscribe so that we do not contact you again.
10. Keeping your information secure
We limit access to your information to members of our team who need it, use secure systems with password protection and two-step verification, and require our service providers to protect it too using 1Password software.
We will never ask you to change payment details by email or WhatsApp. If you receive a message that appears to come from us asking you to do so, please call us on a number you already hold before paying.
11. Cookies
11.1Our website uses cookies, which are small files stored on your device. Essential cookies make the site work. We only use non-essential cookies, such as analytics, if you agree to them through our cookie banner, and you can change your choice at any time.
11.2Full details of the cookies we use are on our Cookie Policy.
11.3You can also block or delete cookies in your browser settings.
12. Your rights
You have the right to:
- ask for a copy of the information we hold about you;
- ask us to correct information that is wrong or incomplete;
- ask us to delete your information;
- ask us to restrict how we use it;
- object to how we use it, including for direct marketing;
- ask us to transfer information you gave us to you or another organisation; and
- withdraw consent at any time, where we rely on consent.
Some rights have exceptions. For example, we must keep booking records for tax purposes. To use any of these rights, contact hello@travl.love. We will respond within one month, and there is usually no charge.
13. Complaints
13.1If you are unhappy with how we have handled your information, please contact us first at hello@travl.love. We will acknowledge your complaint within 30 days and take steps to resolve it without undue delay, keeping you informed of progress.
13.2You also have the right to complain to the Information Commissioner's Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113.
14. Changes to this policy
We may update this policy from time to time. The latest version will always be on our website, with the date it was last updated.