This notice explains how we collect and process your personal data. Please read this privacy notice carefully as it contains important information on who we are and how and why we collect, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event that you have a complaint.
This website is not intended for children and we do not knowingly collect data relating to children.
Who are we?
"Apollo" and apollocamper.eu means:
This Privacy Notice is issued on behalf of Apollo. Therefore, when we mention "Apollo", the "Group", "we", "us" or "our" in this Privacy Notice, we are referring to the respective Apollo company responsible for processing your data.
We will tell you which company is responsible for processing your personal data when you purchase a product or service from us. Apollo is the controller responsible for your data. This Privacy Notice is intended to inform you about how the companies within Apollo will handle your personal data. This includes what you tell us about yourself, what we learn when we have you as a customer or when you use our website, and the choices you give us about what marketing you want to receive from us. Click here for information on Google’s Privacy and Terms site.
Key Terms
It would be helpful to start by explaining some key terms used in this privacy notice:
"Personal data"
|
Any information relating to an identified or identifiable individual
|
"Special category personal data"
|
Personal data revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
Genetic and biometric data (when processed to uniquely identify an individual)
Data concerning health, sex life or sexual orientation
|
"Data subject"
|
The individual who the personal data relates to
|
What personal data do we collect?
We collect and process different kinds of information, including personal data about you. This may include:
- Identity Data, e.g. your name, title, date of birth, nationality, date of birth, identification documents (for example, your passport or international identity card), copies of any documents provided for identification purposes to provide you are eligible to use our services.
- Contact Data, e.g. address, email address, telephone number, and how to contact you.
- Financial Data, e.g. your bank account details, payment card details, financial position, status and history.
- Transaction Data, e.g. details about payments to and from your accounts, please note that payments will be made via third party payment gateways (Stripe and PayPal).
- Contractual Data, e.g. details about the products and services we provide to you and your preferences towards them.
- Marketing and Communications Data, e.g. your preferences in receiving marketing from us and our third parties and your communication preferences.
- Technical Data e.g. 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 access our website.
- Profile Data e.g. your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data e.g. information about how you use our website, products and services.
- Social Media Data e.g. information from accounts you link to us, e.g. Facebook and Twitter, and your professional online presence, e.g. LinkedIn profile.
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
We collect information about criminal convictions and offences as you will be asked to confirm certain information when being insured to drive vehicles for Bunk Campers. Your answers will be passed to our insurance company and supplementary questions and/or requests for further information may follow from them.
If you fail to provide personal data
We collect and use this personal data to provide products and services to you or to a business to which you are linked. If you choose not to give us the personal data we ask for, it may delay or prevent us from meeting our obligations. It may also mean that we cannot provide you or the linked business with our products and services. It could mean that we may have to cancel a product or service you or a business to which you are linked has with us, but we will notify you if this is the case at the time.
Where do we collect your information from?
We use different methods to collect data from and about you including through:
- Direct interactions: you may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- Apply for our products or services;
- Create an account on our website;
- Subscribe to our service or publications;
- Request marketing to be sent to you;
- Enter a competition, promotion or survey; and
- Give us feedback or contact us.
- Automated technologies or interactions
- As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Please see our cookie policy https://www.apollocamper.eu/en-gb/Cookies for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
- Analytics providers such as Google and Facebook;
- Advertising and marketing networks such as Google and Facebook;
- Search information providers such as Google;
- Providers of technical, payment and delivery services such as Worldpay, Stripe, Paypal;
- Social media platforms, e.g. Facebook, Twitter, and LinkedIn.
How is my information used by Apollo?
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 obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which We Will Use Your Personal Data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
To register you as a new customer
|
(a) Identity
(b) Contact
|
Performance of a contract with you
|
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(f) Contractual Data
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review or take a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Contractual Data
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
|
To enable you to partake in a prize draw, competition or complete a survey
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(e) Contractual Data
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
(g) Contractual
(h) Social Media
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
|
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
|
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
|
To make suggestions and recommendations to you about goods or services that may be of interest to you
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
(g) Contractual
(h) Social Media
|
Necessary for our legitimate interests (to develop our products/services and grow our business)
|
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
You will receive marketing communications from us if you have requested information from us or purchased products or services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.
Cookies
Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers’ systems to recognise your browser and capture and remember certain information. We use cookies to compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. You can find out about cookies and how we use them in our cookie policy at: https://www.apollocamper.eu/en-gb/Cookies
Apollo Camper works with Google Adwords and Facebook who use technology including web beacons and cookies to collect data about our website usage and to improve the effectiveness of our marketing. Data recorded through the use of this technology is aggregated and shared with us.
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 you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
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 that 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.
International Transfers
As part of our service, we may sometimes need to transfer your data outside the European Economic Area (EEA) and/or the UK (as applicable).
Apollo is owned by Apollo Tourism & Leisure LTD who are based in Australia. Some of your personal data may be stored on our CRM system Vibe which is hosted outside of the EEA. Some of our external third party service providers and staff, are based outside the EEA and/or the UK so their processing of your personal data will involve a transfer outside the EEA and/or the UK (as applicable).
Whenever we transfer your personal data out of the EEA or the UK (as applicable), we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or the Information Commissioner's Office (ICO) (as applicable). For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission or the ICO (as applicable) which give personal data the same protection it has in Europe (as applicable). For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.
Disclosures of your personal data
We may share your personal data with the parties set out below:
- Third parties, who provide a service to us and their sub-processors, including:
- Trustpilot A/S (Trustpilot) who provides customer experience services to us. We may share personal data, including your name, email address and reference number with Trustpilot to allow to collect your feedback on our products or services.
- Debt collection agencies, in the event of your default in payment of monies owed to us.
- Our subcontractors
- Companies that form part of our Group as well as franchisees, licensees or our agents, including Apollo Tourism & Leisure LTD.
- Credit reporting and fraud checking agencies, where necessary to register a default.
- A public authority or regulator in the event that we are required to do so by law or regulation.
- City councils and government or private organisations responsible for the processing or handling of traffic related infringements.
- Driver licensing authorities.
- A third party where we are under a legal obligation to transfer it to that third party.
- A prospective seller or buyer of any of our assets or business.
- A third party where it is necessary to protect the vital interests of the data subject or another natural person.
- Our banking and financial services partners and payment networks to allow us to transfer your money internationally.
- Professional advisers, including our lawyers and accountants.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
It is still important for you to keep your account details and password safe. You should not share these with anyone.
How long do we keep your information?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
In some circumstances you can ask us to delete your data: see section 'Your privacy rights' below for further information.
In some circumstances we will 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.
Your Privacy Rights
You have a number of rights under data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data. You can receive a copy of the personal data we hold about you by writing to our Data Protection Officer at the address at the end of this notice.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- If you want us to establish the data's accuracy.
- Where our use of the data is unlawful but you do not want us to erase it.
- Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
- You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. You can withdraw your consent at any time by getting in touch with us at [email protected] or using the contact details at the end of this notice. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us: [email protected]
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 could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it could 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.
How to complain
If you are unhappy with how we have handled your personal information, you can contact our Data Protection Officer at the address at the end of this notice.
You also have the right to complain to the Information Commissioner’s Office. You can call their helpline on 0303 123 1113, or you can visit their website (www.ico.org.uk) for information on how to make a data protection complaint.
Data Protection Officer
We have appointed a Data Protection Officer, who advises us on our data protection obligations and monitors compliance.
You can contact the Data Protection Officer by writing to the
Data Protection Officer, Bunk Campers Ltd, Cyril Johnston Complex, Ballynahinch Road, Belfast, N Ireland, BT8 8DJ (NI059756) and
Data Protection Officer, Apollo Motorhome Holidays GmbH, Segeberger Chaussee 229, 22851 Norderstedt
Or by e-mail to [email protected]
Changes to the privacy notice and your duty to inform us of changes
It is important that the personal data we have about you is accurate and up-to-date. Please keep us informed if your personal information changes during your relationship with us. In particular, it is important that you inform us of any changes to your contact details, including your email address or mobile phone number.
Changes to the Privacy Notice and your obligation to notify us of any changes We regularly review our privacy policy. This version was last updated in December 2021.
Third-party links
Our 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 data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website or our app, we encourage you to read the privacy notice of every website you visit.
Date of Issue: December 202