Our pledge to you:
- Is to hold your data securely;
- Share only where you agree;
- Use your data to tailor the information we provide you and improve our services;
- Put you in control by allowing you to update, delete and access your data;
1. Who are we?
This policy covers how we (Visit Scotland) collect, use, disclose, transfer and store your data.
VisitScotland is the national tourism organisation for Scotland. Our main aim is to contribute significantly to the advancement of Scottish tourism by giving it a real presence in the global marketplace and benefiting the whole of Scotland.
Our website www.visitscotland.com is the official consumer travel website for Scotland. The aim of the website is to ensure you experience the very best Scotland has to offer.
Our corporate website www.visitscotland.org has more details about who we are and what we do. If you are a business, travel trade or other such organisation, please visit this site for how we can work together.
2. What personal information will VisitScotland collect about me?
- The information we collect (personal or not)
- Why we collect it
- How long we store it
- Our legal basis for processing your personal data
- Who if anyone we disclose your personal data to
- Your rights and how you can see, update or delete your personal data
- To make it easy to understand what data we collect about you we have grouped this policy into how you and others get information from us/ interact with us
- Our digital services. This includes are website and apps, managed by us.
- Services we use to communicate like social media
- Contact us directly, via email, phone, letter
- Meet us in person at events or in our iCentres
3. When you use our digital services
We use website log files, cookies, digital analytics (Google) and heat mapping software, to gather information about how people use this site (www.visitscotland.com).
We do not collect or store your personal information (e.g. your name or address) in our website analytics. However, we can recognise that behaviours belong to a single person. The information collected helps us investigate whether each website meets its users' needs as well as to evaluate how each website can be improved. We store information about what pages you visit, how long you are on the site, how you got here and what you clicked on.
If we were ever to obtain your personal data via the routes in this policy, we may combine website analytics data with your personal data. For more information please see the section on Joining data and Profiling.
Website log files collect your IP address, when you visited the site and the pages you visited. IP address is a numeric code assigned to a device based on your geographical location. If for example you are in Edinburgh your IP address will be the same as other users accessing the internet from Edinburgh.
Digital Analytics & Doubleclick
Digital analytics tools such as Google Analytics and DoubleClick may be used to record anonymous user's interaction with VisitScotland websites. This data may then be used to retarget users through advertising on other websites, therefore an individual's behaviour on one of our websites may result in them being retargeted with advertising related to the pages they visited or actions they took on the site.
Remarketing/ Remarketing Lists for Search Ads (RSLA)
When you download or use VisitScotland app on your mobile device, information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie, such as by enabling the app to 'remember' you or provide you with the content you have requested.
Your web browser or device may also provide VisitScotland with information about your device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address, MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).
When you sign in to a VisitScotland app, your sign-in details may be stored securely on the device you are using, so you can access other VisitScotland apps on the same device without needing to enter your sign-in details again.
On using our app for the first time, you are also given the opportunity to agree/disagree tracking of app usage. We ask all app users to accept or deny access to analytics. These analytics are anonymous and not attributed to individuals but provide analysis of the way consumers use the app which then allows us to review and make improvements to the app. We also use geo-location information in order to provide local content on our app. This geo-location data is anonymous and is only used to provide local content to you. We do not store any geo-location information relation to your use of the app.
If you have any concerns about the information which might be accessed from or stored on your device by VisitScotland, you may wish to only access VisitScotland content through a web browser and review your web browser settings.
Creating and planning a trip
You may 'favourite' places, pages and information on this site using Trip Planner. This information will be stored for the duration of time you are on the site and deleted once you leave the site. If you would like to store the information for 'future visits' you must create an account. For information about what we store in your Account, please visit the Create an Account section below.
To join our community you require an account. For information about what we store in your account please visit the Create an Account section below.
You can control notifications about your contributions to discussions on the community. We store this data to provide the community service to you. We retain it on a secure database this data for five years after you have withdrawn consent. After this, we anonymise the data.
4. When you provide personal data
When you make a complaint to us, you can do so via an online form, email, telephone, letter or at an iCentre. The complaint is logged on a system called Vivantio. Once a complaint is been created in Vivantio, an email is sent to the VisitScotland Customer Feedback Mailbox, where a VisitScotland complaints officer will review and respond to it.
A complaint can be made anonymously. However if you do provide personal data, we request your full name and address. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
By giving us your personal data you consent to us processing it. We retain personal data obtained from complaints for five years and then confidentially destroy it.
Occasionally you can request a brochure by post. In order to do this, we need your name and postal address and the brochure requested. Our legal basis for processing is contract and we will retain it for two months after the request.
When you request a brochure we also collect a unique identifier which Google assigns to you. For more information, please read the section Joining and Profiling.
However, if you consent to future marketing we will continue to process your data on that basis. We store this in a secure database for five years after your last communication with us, unless you withdraw consent. If you withdraw consent it will be deleted within a month.
To fulfil your request our mailing company receive your personal information. They store it for 3 months after a brochure is sent.
We have many newsletters, among them:
- Travel & holidays - inspiration, travel tips, news and offers
- Ski - a partnership newsletter from SkiScotland
To provide these newsletters, we request contact details including but not limited to - your email address, country, and postcode.
We only collect this data when we have your consent and retain it on a secure database. We store this data for five years after your last communication with us, unless you withdraw consent. If you withdraw consent it will be deleted within a month.
When you sign up for enewsletters we also collect a unique identifier which Google assigns to you. For more information, please read the section 'Joining and Profiling'.
Enter a competition
When you enter a competition, we may collect your name, email address and postal address. You are also given the option to consent to future marketing from us and our partners. We process this data as part of our contact to you and we retain it for 2 months after the competition has closed.
However, if you consent to future marketing we will continue to process your data on that basis. We may use this data and other data we hold about you to tailor the communications we send and improve our service to you and others. We store this in a secure database for five years after your last communication with us, unless you withdraw consent. If you withdraw consent it will be deleted within a month.
If you consent to marketing from our named partners, we will share your data with them. When you enter a competition on our site, we also collect a unique identifier, which Google assigns to you. For more information, please read the section 'Joining and Profiling'.
Give us feedback (unprompted)
You do not need to include your name or contact details in order to provide us with general feedback or information about any technical problems on this site. You will however need to include an email address if you want us to reply to you. For some enquiries, contact details will be required.
We will only use any personal information provided to deal with your request and will not share it with other organisations. This data is stored for six months after we respond to your feedback, in case you ask for more detail or have other feedback you'd like to make.
We reserve, however the right to use non-personal information for business, research and marketing purposes. Uses include:
- An internal report listing technical problems on the website and solutions
- Marketing literature using quotes drawn from feedback about the site
Our legal basis for processing this data is legal obligation.
Give us feedback (when we ask you)
We may ask you for feedback whilst on the website. You only need to include an email address if you want us to reply to you or you would like to be included in future research.
By giving us your personal data, you consent to us processing it. We will store it securely for a maximum of 14 months.
We may share this data with a research agency who conduct the research on our behalf and destroy the personal data when the research is complete.
When you create an account
We collect your email, country and postcode to create an account. When you login, we will track this and your behaviour. We may use this data and other data we hold about you to tailor your experience in the account and any communications we send. We may also use it improve our service to you and others.
If you ask us to close your account, we will delete the data within a month. If there is no activity on your account for 18 months, we will contact you to confirm it is still required before closing it and deleting the data.
However, if you consent to receive marketing we will continue to process your data on that basis. We store this in a secure database for five years after your last communication with us, unless you withdraw consent. If you withdraw consent, we will delete your data within a month.
When you enter a competition on our site, we also collect a unique identifier, which Google assigns to you. For more information, please read the section 'Joining and Profiling'.
5. When you use other services (like Facebook) to interact with us
When you use a social media platform, details about how your personal information is held, is described within the relevant social media policy, such as Facebook or Twitter.
Forms on social media
We use a third party provider, to manage our social media interactions.
If you send us a private or direct message via social media the message will be stored by our provider for 3 months and then confidentially destroyed. It will not be shared by any other organisations.
Our legal basis for processing this information is contract and we do so to fulfil a service to you.
You can sign up for enewletters via social media, please see the 'request an enewsletter' section and the terms presented in the service at the point of sign-up.
6. When you contact us directly
When you phone us
We do not collect caller line identification information when you call us. We will only collect personal information that you consent to provide to us in order to deliver a service.
When you email us
When you contact us via email, we will retain your email and our response to it for as long as the business issue remains. After this, the information will be confidentially destroyed.
When you write to us
When you contact us via post, we will retain your email and our response to it for as long as the business issue remains. After this, the information will be confidentially destroyed.
7. When we meet in person
At our iCentres
VS will collect personal information from you at iCentres which will help us to deliver a service, for example, to book accommodation, or purchase a ticket. Once the business use has passed, we will destroy this data confidentially.
To use WiFi at our iCentres, you need to accept our terms and conditions. We will request your name and email address. This information is held only while you are using WiFi and is then deleted.
When you log onto our WiFi, there is also an opportunity to sign up to receiving future communications. To find out more information about how we handle your personal information for this, please see the 'Request an enewsletter' section.
Sign up to eNews
To find out more information about this, see the 'request an enewsletter' section.
Provide feedback or make a complaint
If you want to provide feedback or make a complaint, you can so anonymously, or provide personal data so we can respond to you.
If you do provide personal data, we will request your full name and address. We will only use the personal information we collect to process the complaint and to check on the level of service we provide. We do compile and publish statistics showing information like the number of complaints we receive, but not in a form which identifies anyone.
By giving us your personal data you consent to us processing it. We retain personal data obtained from complaints for five years and then confidentially destroy it.
When make a purchase at an iCentre, we retain financial information about the transaction. We have a legal requirement to retain this data for seven years. Then it is destroyed.
At Outreach events
Attend an event
When you attend an event we will only request you name and address in order to provide a service. Once the service has been provided, we will destroy this data confidentially.
Enter a competition on our stand
To find out more information about this, see the 'Enter a competition' section.
8. When we contact you
We may email you regarding a contract or service or in response to a request, you have made. Your data will be stored for the purpose and time required to fulfil this.
We only send emails to you promoting Scotland where we have your consent. However, if you subscribed to regular information via email before May 2018, you have not asked us to stop and you have engaged with the content recently we will continue to contact you. The legal basis for this is legitimate interest.
We store this in a secure database for five years after your last communication with us, unless you withdraw consent. If you withdraw consent, we will delete your data within a month.
Occasionally we send brochures by post.
We only communicate to you via post where we have your prior consent. Our legal basis for processing this data is consent.
If you subscribed to regular information via post before May 2018, you haven't asked us to stop and we believe the information is in your interest we will continue to contact you. The legal basis for this is legitimate interest.
We store this information for five years after consent has been withdrawn or we no longer believe it in your interest.
We use a third party provider to pack and send the brochure. They store your personal data for 18 months after it has been sent.
9. Joining data and profiling
We want to provide the best possible service to you. To achieve this we, where possible, join anonymous and personal data.
When you provide personal data via a form on the website, we collect a unique ID assigned to you by Google. We use this to combine your personal information with information from Google. The information we collect from Google includes how you reached our website and your behaviour whilst on the site. This applies to visits where you submit a form, previous and future visits, if available.
We may use this information to improve our service to you and to tailor the information we provide in future. We may also use it to understand the success of our marketing and make improvements to our services overall. Personal data is stored for as long as the purpose intended (see section: 'When you provide personal data').
Profiling is defined as under the General Data Protection Regulations as the automated processing of personal data to evaluate certain things about an individual. Profiling can be part of an automated decision-making-process. Automated decision-making is making a decision solely by automated means without any human involvement.
We may use these techniques to make the information in our emails, website or app more relevant to you. We therefore process this data in your legitimate interest. If you do not want us to use your data in this way, please email email@example.com. Likewise if you would like to see the data that we use for this purpose contact us.
10. Your rights
Under the General Data Protection Regulations, you have rights as an individual which you can exercise in relation to the information we hold about you.
Read more about your individual rights on the Information Commissioner's Office website.
11. Access to personal information
VisitScotland tries to be as open as it can be in terms of giving people access to their personal information. Individuals can find out if we hold any personal information by making an 'right of access' request under the General Data Protection Regulations. If we do hold information about you we will:
- Give you a description of it;
- Tell you why we are holding it;
- Tell you who it could be disclosed to; and
- Let you have a copy of the information in an intelligible form.
12. Links to other websites
We keep our privacy notice under regular review. This privacy notice was last updated on 18 April 2018.
You can access this policy at any time through the link at the bottom of our websites and from any e-newsletters you are subscribed to.
14. How to contact us
VisitScotland tries to meet the highest standards when collecting and using personal information. For this reason, we take any complaints we receive about this very seriously. We encourage people to bring it to our attention if they think that our collection or use of information is unfair, misleading or inappropriate. We would also welcome any suggestions for improving our procedures.
This privacy notice was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of VS's collection and use of personal information. However, we are happy to provide any additional information or explanation needed. Any requests for this should be sent to the address below.
Email us firstname.lastname@example.org
Telephone: 0131 472 2222
Or write to:
Records Management and Data Protection Officer
Ocean Point One
94 Ocean Drive