mytc-right
right

Privacy Policy

At Motivo, your privacy matters. As a proud franchisee of the Travel Counsellors Group, we handle your data with the same care, security, and transparency you expect across the network. The policy below explains what we collect, how we use it, and the rights you have over your information.

Introduction

Motivo takes its data protection and privacy responsibilities seriously. As a franchisee of the Travel Counsellors Group (“Travel Counsellors”), we operate within the Group’s governance, systems and policies and are committed to protecting your personal data.

This privacy notice explains how we collect and process your personal data, including when we provide services or products, when you use the MyTC App (also used within Motivo’s services), when you contact or engage with us, or when you attend our events. It also explains how we protect your personal data, your privacy rights, and how the law protects you.

How to contact us

If you have any questions about this privacy notice or our privacy practices generally, please contact the Travel Counsellors Data Protection Office (which also supports Motivo as a franchisee):
Email: DPO@travelcounsellors.com
Post: DPO, Travel Counsellors Limited, Venus, No.1 Old Park Lane, Trafford City, Manchester, M41 7HA.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection (www.ico.org.uk). We would appreciate the opportunity to address your concerns first—please contact the DPO team at DPO@travelcounsellors.com.

Changes to our Privacy Notice and changes to your personal data

We keep this notice under regular review and may update it from time to time. Please check our website or the MyTC App for the latest version.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

Our websites may include links to third-party websites, plug-ins and applications. Clicking 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, please read the privacy policy of any site you visit.


Our role and the role of independent Travel Counsellors

Travel Counsellors Limited (“TCL”, “we”, “us”, “our”) is a controller under data protection law. As a Motivo client, your data may be processed by Motivo (a Travel Counsellors franchisee) and by TCL.

If you are a customer, our independent franchisees—the Travel Counsellors (including Motivo)—are also controllers of your personal data. In most cases, your Travel Counsellor will be a joint controller with TCL for how your personal data is used (for example, when we work together to provide your travel arrangements).

In certain situations, your Travel Counsellor (including Motivo) is a separate controller and solely responsible for determining how they use and process your personal data—for example, how they market travel services to you or communicate with you. If you have questions about how your individual Travel Counsellor treats your personal data, please contact them directly.


The data we collect about you

“Personal data” means any information about an individual from which that person can be identified. It does not include anonymised data.

Depending on how you interact with us, we may collect, use, store and transfer the following categories of personal data:

  • Identity Data: first name, last name, username or similar identifier, marital status, title, date of birth, passport details (passport number, nationality, date of birth, expiry date), gender; for corporate travellers/suppliers also occupation, employer/client details, account holder/authorised booker identities, directors/shareholders.

  • Contact Data: billing/delivery address, email address, telephone numbers of lead passenger and other passengers/persons making a booking.

  • Financial Data: bank account and payment card details; payment history, outstanding debt and failed payments.

  • Booking Data: payments to/from you; products/services booked; visa and travel insurance details; criminal offence data relevant to travel; in-resort or travel issues (these categories may also relate to child passengers where applicable).

  • Travel Preferences Data: dietary needs; medical/health requirements; information relating to medical conditions or issues; religious beliefs; sexual orientation; accessibility requirements; preferred providers; preferred/closest airport.

  • Technical Data: IP address; MyTC App login data; browser type/version; browsing history; time zone/ location; plug-ins; OS and platform; device identifiers for website/MyTC App access.

  • Profile Data: MyTC App username/password; enquiries, purchases and previous bookings; passport and airline/hotel membership details; loyalty scheme and insurance details; interests, preferences, feedback, complaints, survey responses; emergency contact; next of kin/beneficiaries.

  • Usage Data: information about how you use our website, products and services.

  • Marketing Data: marketing preferences and communication preferences.

  • Telephone Interaction Data: name, contact details and any information provided during calls (which may include special category data).

  • Attendance Data (events/premises): vehicle registration, dietary requirements, access needs, CCTV images.

We may also collect, use and share Aggregated Data (statistical/demographic) for any purpose. Aggregated Data may be derived from personal data but is not considered personal data in law if it does not identify you.

Special Category Data and Criminal Offence Data

Special Category Data is more sensitive and requires extra protection (e.g., race/ethnicity, religious or philosophical beliefs, sexual orientation, health, genetic/biometric data). Depending on the services we provide, we may process:

  • Health Data (medical conditions/disabilities; pregnancy details; in-resort medical issues/emergencies).

  • Race/Ethnicity Data revealed by passport/ID (nationality, country of issue, photograph).

  • Religious Belief Data inferred from dietary requirements/preferences.

  • Criminal Offence Data relevant to travel (e.g., records impacting entry/exit or vehicle hire).

  • Other special category data you choose to disclose in connection with services/products.

If you do not provide personal data

Where we need personal data by law, under a contract (with us or a travel supplier), or to provide travel arrangements (as tour operator or agent), and you fail to provide it, we or the relevant supplier may be unable to perform the contract or proceed with a booking. We will notify you if this is the case.


How is your personal data collected?

We collect data through:

  • Direct interactions: forms, post, phone or other correspondence; purchasing services; creating a MyTC App account and profile; newsletter subscriptions/marketing requests; interactions with Travel Counsellors ads or sponsored links; competitions/promotions/surveys; feedback. Calls may be recorded for quality, improvement, or crime prevention (including fraud).

  • From your Travel Counsellor (including Motivo): data shared by your Counsellor that they collected directly from you (post, phone, email, direct message or other channels) relating to travel arrangements, marketing subscriptions and feedback.

  • From corporate clients (for corporate travellers): onboarding/KYC, travel requirements and bookings.

  • Automated technologies: cookies, server logs and similar tech on our websites/MyTC App. See our cookie policy.

  • Service providers and software providers: travel providers and technical platforms that support booking/payment solutions.

  • Other third parties/public sources: analytics/search providers (e.g., Google); publicly available information (incl. social media); for corporate bookings, credit reference agencies and public registers (e.g., Companies House).

Where you provide data about other individuals (e.g., fellow travellers), you must ensure you are authorised to share it and that they understand how their data may be used.


How we use your personal data

We will only use your personal data when the law allows. Most commonly:

  • To perform a contract with you.

  • Where necessary for our legitimate interests (or those of a third party) and your interests/fundamental rights do not override those interests.

  • To comply with legal obligations.

  • In limited cases, with your explicit consent or where use is in your vital interests (often relevant for special category data or direct marketing to individuals).

Purposes for which we will use your personal data

We use your data for the same purposes and lawful bases set out in your original text (registration; booking and provision of travel services; payments and debt recovery; after-travel support; complaints/claims; relationship management; MyTC App account/profile; competitions/surveys; website/App administration and security; content/ads personalisation; analytics; service improvement and crime prevention; legal compliance; suggestions/recommendations).
The applicable types of data and lawful bases for each purpose remain as listed in your original policy.


Marketing and Promotions

You will receive marketing communications if you requested information or purchased services and have not opted out. We may profile relevant data (Identity, Contact, Booking, Travel Preferences, Technical, Profile, Usage) to tailor offers, and we may use carefully selected third-party marketing partners to help provide a personalised service. We do not sell your personal data to third parties.

Opting Out

You can ask us to stop sending marketing at any time by contacting us. Opting out does not affect communications necessary for existing or future bookings. You can withdraw consent to profiling at any time by contacting DPO@travelcounsellors.com.

Change of Purpose

We will only use your data for the purposes collected unless another compatible purpose applies. If we need to use your data for an unrelated purpose, we will notify you and explain the legal basis. In some circumstances we may process data without your knowledge/consent where required or permitted by law.


Disclosure of your personal data

We may share your personal data with:

  • Internal third parties: companies in the Travel Counsellors Group (current/future); Travel Counsellors (franchisees, including Motivo) acting as joint or separate controllers depending on circumstances.

  • External third parties: travel suppliers (tour operators, airlines, hotels, accommodation, cruise, transfer, rail/transport, excursion providers, DMCs and their agents); professional advisers (lawyers, bankers, auditors, trust managers, insurers); regulators/authorities (e.g., HMRC, IATA, CAA, immigration/border control/security authorities); service providers (IT, systems administration, banking/payment, marketing, airline seat/aggregators and related software); where corporate, third parties performing credit/ due diligence checks; potential buyers/merger partners.
    All third parties are expected to protect your data and use it only for the disclosed purposes.

International data transfers

We share data within the Travel Counsellors Group, which may involve transfers outside the UK. Because we provide international travel services, many suppliers are outside the UK. Where data is transferred internationally, we use appropriate safeguards (e.g., adequacy decisions or standard contractual clauses) to provide equivalent protection to UK standards.


Data Security

We implement appropriate technical and organisational measures to protect your information against unauthorised access, alteration, disclosure or loss. Access is limited to those with a business need, under confidentiality obligations. We maintain procedures for actual/suspected data breaches and will notify you and regulators where legally required.

Data Retention

We retain personal data only as long as necessary for the purposes collected, including legal, regulatory, accounting or reporting requirements. We may retain data longer in case of a complaint or reasonably anticipated litigation. We consider data amount/nature/sensitivity, potential harm from unauthorised use/disclosure, processing purposes and legal requirements when determining retention. We may anonymise data for indefinite use. For retention details, contact DPO@travelcounsellors.com.


Your Legal Rights

Under data protection laws you may:

  • Request access to your personal data.

  • Request correction of inaccurate data.

  • Request erasure of your data in certain circumstances.

  • Object to processing based on legitimate interests (including direct marketing).

  • Request restriction of processing.

  • Request data portability.

  • Withdraw consent where processing relies on consent (without affecting prior lawful processing).

To exercise rights, contact DPO@travelcounsellors.com or write to the postal address above.

Fees and charges

No fee is charged unless a request is clearly unfounded, repetitive or excessive, in which case a reasonable fee may apply or we may refuse to comply.

What we may need from you

We may need to verify your identity and request additional information to expedite our response.

Response time

We aim to respond within one month. Complex or multiple requests may take longer; we will keep you updated.


Last updated: 13 January 2025.