• We do not generally carry out automated decision-making or profiling.
• If we ever do, you have rights to request human review, object, and obtain an explanation.
• Profiling safeguards include transparency, safeguards against errors, and prevention of discrimination.

You have the right to:

• Access, correct, or delete your data

• Restrict or object to processing

• Data portability

• Withdraw consent

• Lodge complaints with the ICO (ico.org.uk)

• Rights related to automated decision-making and profiling (see Section 14)

• Google Analytics Cookie Usage
• Hotjar Cookies

• We use first-party Cookies (set by us) and third-party Cookies (e.g., Google, Hotjar, Bing).
• Cookies are used for advertising, functionality, analytics, and site performance.
• Necessary Cookies are required for site function and cannot be disabled.
• You can manage or disable Cookies via your browser.
• For detailed information on Google and Hotjar cookies, see: 

You have the legal right to request a copy of any of your Personal Data held by us. Contact us at: concierge@escapecodetravel.com

• Some data (e.g., IP address) may be collected automatically.
• You may restrict browser Cookies (see Section 12).
• Where processing is based on consent, you may withdraw consent at any time.

• You can opt out of marketing communications via unsubscribe links.
• You may sign up to UK preference services (TPS, CTPS, MPS).

If our business is sold or transferred, relevant user data will transfer to the new owner, who will be bound by this Privacy Policy.

We may share your data with:

• Companies in our group (for sales and reporting)
• Third parties supplying services (e.g., payment processors, delivery companies, web hosting, marketing tools)
• Specific categories include: PayPal, Stripe, Amazon, Shopify, Recharge, Klarna, Klaviyo, and others

We may also share anonymised data (e.g., usage statistics) with investors, affiliates, or advertisers.

We may disclose your data where legally required (e.g., court order, government request).

• We only keep your data for as long as necessary, with a general retention period of 6 years.
• We implement physical, electronic, and managerial safeguards, including SSL encryption for payment details.
• Your data may be stored on servers located in the UK, EEA, Canada, or USA and processed by UK-based staff.
• Transfers outside the UK are protected by adequacy decisions or approved contractual safeguards.
• Note: internet data transmission may not be fully secure – please take precautions.

All Personal Data is stored securely in accordance with the Data Protection Act 2018 (“DPA”) and other applicable data protection laws.

We use your data to provide the best possible products and services, including:

• Managing your Account and access to our Site
• Personalising your experience
• Supplying products and services
• Responding to communications
• Sending you marketing communications if you have subscribed (with opt-out available at any time)
• Market research and product development
• Analysing usage of our Site to improve performance and user experience

We will not send you unsolicited marketing or spam.

A detailed table of purposes and lawful bases for processing is included in this Policy (see original Section 5 for the breakdown).

Some data will be collected automatically by our Site (see Section 12 on Cookies). Other data will be collected only if you voluntarily submit it, for example when signing up for an Account or our Mailing List. Depending upon our interactions with you and your use of our Site, we may collect some or all of the following:

• Name
• Contact information (email address, telephone number)
• Date of birth
• Information you may make available to us in connection with product trials, including images or videos
• Demographic information (postcode, preferences, interests)
• Financial information (credit/debit card numbers)
• IP address (automatically collected)
• Web browser type and version (automatically collected)
• Operating system (automatically collected)
• A list of URLs (referring site, activity on our Site, exit site – automatically collected)

This Privacy Policy applies only to your dealings with us as a customer or potential customer, or to your use of our Site. It does not extend to any websites that are linked to or from our Site (whether we provide those links or whether they are shared by other users). We have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

• Our Site is owned and operated by Escape Code Travel Ltd. a company registered in the UAE with business licence 2536117.01.

In this Policy the following terms shall have the following meanings:

•  “Account” – an account required to access and/or use certain areas and features of our Site.
•  “Cookie” – a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or use certain features. Details of the cookies we use are set out in Section 12 below.
•  “Mailing List” – our email marketing list to which we distribute our latest news and discount details. 
• “Our Site” – this website, displayed at www.escapecodetravel.com and any other URL connected to and operated by us.
• “Personal Data” – any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
• “We/Us/Our” – Escape Code Travel Ltd, a company registered in the UAE with business licence 2536117.01.

Escape Code Travel Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of all our customers and everyone who visits our Site and will only collect and use information in a manner consistent with your rights and our obligations under the law.

This Policy applies to our use of any and all data collected by us in relation to your use of our Site or any other dealings you have with us. Please read this Privacy Policy carefully and ensure that you understand it. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our Site. If you do not accept and agree with this Privacy Policy, you must stop using our Site immediately.

Effective Date: 1 October 2025