Privacy Policy

Pharos Data is committed to safeguarding your right to privacy as a user of our online services.  It is our policy to respect your privacy and in this policy we explain how we will handle your personal data. 

Pharos Data Ltd confirms that any customer or enquirer information will only be used in the execution of an enquiry, order, proposal, or administration of affairs and that the information held will be kept confidential. The information you provide to us will be held for your booking agent/supplier on Pharos servers in the UK and we will not transfer it outside the UK.

We further declare that:

  • We will not sell, or pass your information to third parties
  • We will not make your information available to anyone outside of our company except where we are under legal obligation to do so
  • We will not use this information for any other purpose than contacting you to bring you information about new products and services that are relevant to your enquiry, or business
  • In such cases where we do contact you about new products and services you will have the right to unsubscribe to further information distribution

Pharos Data Ltd respects the rights of clients and enquirers to privacy and protection of their personal and company information. A written copy of this statement on Company letterhead is available on request.

What exactly do we mean by ‘information’?

We have outlined below the different situations in which we are involved in handling your personal information and for what reason.  We have also set-out the choices to you regarding:

  1. how we collect, use, secure and store your Personal Information; and 
  2. how you can request that your Personal Information is updated, corrected, and/or transferred within the EU, or deleted.

Information relating to natural living persons is now categorised under new regulations (GDPR 2016/679) as either Personal Information or Sensitive Information

“Personal information” means any information that can be used to identify an individual.  This could include: 

name, address, email address, phone number, login information (account number, password), marketing preferences, social media account information, IP addresses, location data, personal identification numbers (passport numbers, visa numbers, social security numbers, etc.), photos, video footage with your likeness, audio recordings, payment card number, criminal record, educational and professional records, 

“Sensitive Information” also relates to information about a natural person, but has greater protection owing to the type of data categorised, including:

any form of biometric, health, genetic, racial, religion, political affiliation, gender-based, sexual preference, age-related, or other identifying personal data.

“Children’s Information”

For marketing, we do not knowingly collect Personal Information from minors under the age of eighteen (18) without appropriate parental or guardian consent. If you believe that we may have collected Personal Information from someone under the applicable age of consent in your country without proper consent OR if you wish to give your parental or guardian consent to allow us to record information on minors, please let us know by emailing 

Children’s Personal Information may be included within travel booking information provided to us by 3rd Parties

How we collect your information?

As a Data Controller, we collect data about you that you volunteer to us (for example, you provide your name and email details by filling in forms on our site or by sending us emails).  We may also collect analytical data from you as you use our website by using cookies and similar technologies. Please see our cookie policy below for more details about this.

As a Data Processor for our clients we may receive and share Personal Information with third parties who provide services to and alongside Pharos Data to complete your travel booking arrangements.  Where we share your personal information with third party service providers, we require that they use your information only for the purpose of providing services to us and that their terms are consistent with this privacy policy.

We do not profile your information.

What data do we collect?


If you ask us to send you information, we will collect and retain your Personal Information to enable us to fulfil your request (permitted under the Privacy and Electronic Communication Regulations). You can ask us to stop sending you marketing messages at any time by following the opt-out links (unsubscribe) on any marketing message sent to you OR by emailing us at

If you opt out of receiving marketing communications this opt-out does not apply to Personal Information (including Sensitive or Children’s Information) provided as a result of other transactions, such as our processing of travel bookings detailed below.

We will not share your personal data with any third party for their own marketing purposes.

Processing bookings

We will collect and process your information as provided to us during the purchase process, which you have confirmed to be accurate as your own information. This information may include your booking data such as: Surname, Title, Forename, Initials, Sex, Age, Nationality, Passport (or other identification document) number, Passport expiry date, Identification document issuing state, Visa number, Date of birth, Place of birth, Province of birth, Disabilities, Address, Telephone numbers and Email address. This may also include details of children you have supplied us with in your capacity as their legal parent or guardian.

Pharos Data does not collect any of the following Sensitive Data about you: details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, genetic and biometric data information about your health (other than health data as required to facilitate your booking).  We do not collect any information about criminal convictions and offences.

What do we use your data for?

Your data may be processed for the purposes of:

  • managing your booking with our suppliers and affiliate organisations. In this context, we are processing your data to fulfil our contractual obligations to you and complete your booking
  • providing our services, ensuring the security of our website and services, maintaining back-ups of our databases, testing our software solutions and communicating with you. The legal basis for this processing is contractual/consent of our legitimate interests, namely the proper administration of our website and business OR the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract
  • We may process information contained in any enquiry you submit to us regarding products and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant products and/or services to you. The legal basis for this processing is consent, which is implied in your volunteering your contact details to us.
  • where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
  • In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
  • Please do not supply any other person’s personal data to us, unless we prompt you to do so

Our use of your personal data is limited to that which is reasonably required in order to provide our service to you and to make improvements to that service which benefit both us and you. We do not use your personal data for any reasons not stated in this Privacy Policy and never use it in an excessive manner that is disproportionate to our aims of providing and improving our service or in a way that is contrary to your interests.

How and where do we store or transfer your data?

We only store your personal data in the UK. This means that it will be fully protected under the GDPR.

Do we share your data?

We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes set out in this policy.

We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining and maintaining insurance coverage, managing risks, obtaining professional advice and managing legal disputes.

We may disclose your Surname, Title, Forename, Initials, Sex, Age, Nationality, Passport (or other identification document) number, Passport expiry date, Identification document issuing state, Visa number, Date of birth, Place of birth, Province of birth, Disabilities, Address, Telephone numbers and Email address to our suppliers or subcontractors insofar as reasonably necessary for provision of services as requested by you.

We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.

Security of your Personal Information

We have security measures in place to prevent your personal data being accidentally or maliciously lost, used, altered, disclosed or accessed without authorisation. We also operate ‘business need-to-know” internal restrictions on who has access to your data.  Our staff will only process your data on our instructions and they must keep it confidential. 

We have internal systems in place to manage data breaches, in the rare event they may occur, and will notify you and the UK regulator of a breach if we are required to do so. 

How long do we keep your Personal Data?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.


Your contact details will be retained on our systems in order to keep you updated on news and opportunities.  You may ask us to delete your contact details at any time by using the ‘Unsubscribe’ option in marketing communications sent to you or by emailing  If you do not ask us to delete your data and we haven’t had any direct contact with you, we will hold on to your data until you instruct us to do otherwise. 

Processing bookings

We will retain your Personal Information for the period required to fulfil the purposes for which it has been collected.  These purposes may include the need to fulfil various commercial and legal requirements. For data provided to us by our clients, we are also governed by their data retention rules as specified in their privacy notices.

In certain circumstances, we have a statutory obligation to keep your personal information for a set period of time for example financial information (normally 6-7 years) for financial auditing purposes.

Notwithstanding the other provisions of this section, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

What are your rights as a Data Subject?

You have the following rights under the GDPR:

  • The right to be informed about our collection and use of your personal data (as described in this Privacy Policy).
  • The right to access your personal data by means of a subject access request (see below).
  • The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. 
  • The right to erasure (also known as the right to be forgotten). 
  • The right to restrict or object to our processing of your personal data for particular purposes. 
  • The right to data portability. This means that you can ask us for a copy of your personal data to re-use with another service or business. Please note, however, that this right applies only if you have provided personal data to us directly, we are using it with your consent or for performance with a contract, and your data is processed using automated means.
  • Rights relating to automated decision-making and profiling. We do not, however, use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us at  Please note that if you delete your account or restrict our processing of your information you will no longer receive details of up-to-date news and opportunities.

Further information about your rights can be obtained from the Information Commissioner’s Office. You also have the right to lodge a complaint with the Information Commissioner’s Office if you feel that your rights have been breached.

How Can You Access Your Personal Data?

You may opt-out of receiving Pharos email marketing materials by using the unsubscribe link in communications we send or you may opt-out or ask to see what information we hold by emailing  

 We will not charge for subject access requests unless they are ‘excessive’ (e.g. repetitive). You should receive a response to your request within 30 days of our receiving it. 



Cookies are small text data files which are either automatically downloaded to, or accessed on, a server by your web browser from a website you are visiting. These data files are commonly used to make visiting a particular website more convenient and give a better experience.

They hold only a modest amount of data about the visitor and rarely collect or contain information of a personal nature. The cookie generally expires after your visit to the site, or within a specified number of hours/days after your visit.

By law all UK companies are legally obliged to inform visitors whether or not their website uses  ‘cookies’. Information must be provided about which cookies are used and why they are used. This website does use cookies and your use of this website does imply acceptance of their use.

The cookies we use do not retain any personal data specifically about you, or the IP addresses of computers used by you to access this website. We only use cookies at this website for the following purposes: –

  1. To render our ‘cookie’ message when you arrive at our website. This cookie tracks your session (visit) so that we do not continually display the ‘cookie’ message on every page you view.
  2. For the purposes of compiling analytical data and statistics about your visit to our website. This cookie is a third-party cookie provided by Google for use with its Analytics product. In terms of third-party cookies like those used in Google Analytics the cookie will only give statistical information about your use of the site but will retain no information personal to the visitor.

Google Analytics

We use Google Analytics cookies, as one of the most widely used and trusted analytics systems on the web, to help us understand how you use the site and ways that we can improve your experience. These cookies will monitor how long you spend on the website and the pages that you visit to help us to produce applicable and engaging content.  For more information on Google Analytics cookies, see the official Google Analytics page.

Are Cookies Enabled in my Browser?

Each browser can be set to accept or decline cookies according to the version of browser used. Settings for cookies can usually be found in the ‘Options’ section of your browser. You can set to reject or decline all cookies, or set a privacy level which will accept some types of cookie but decline others. Alternatively you can remove cookies by choosing the option to delete temporary internet files.

Are cookies a threat to me?

A lot has been said about the use of cookies, but generally so long as you are not visiting suspicious websites they do not in themselves present a threat to privacy, since they can only be used to store information that the user has volunteered, or that the web server is already aware of. If you are concerned that the information you provide to a web server will not be treated as confidential then you should question whether you actually need to provide that information at all.


Copyright Notice

All information published at this website is the property of Pharos Data Ltd, its clients and partners and cannot be used, reprinted, or published in any form whatsoever without the specific written permission of the Company.

Written permission to use any, or part of the information contained herewith can be requested from:

Pharos Data Ltd
400 Thames Valley Park Drive
Reading RG6 1PT
United Kingdom

Pharos Data Ltd has permission to use examples of client logos, testimonials and other details, which remain the property of our clients. Pharos acknowledges with kind thanks to our clients the permission to use these materials.



Terms of Use

Pharos Data Ltd (the Company) has made every reasonable effort to ensure that the information displayed at this website is accurate and responsible.

The Company does not accept responsibility, nor legal liability, for information that may have become incorrect, or misleading due to the passage of time, changes of ownership, or market conditions.

To the best of our knowledge information about products, services and client case studies is accurate at the time of writing and publication.

Any opinions expressed at this web site are given without prejudice and may, or may not be the current opinion of the Company.

Registered address:

400 Thames Valley Park Drive
Reading RG6 1PT
United Kingdom
Reg. No. 2697868