Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE

[ Tourloom Ltd ]

PRIVACY POLICY

1. Introduction

This Privacy Policy explains how Tourloom Ltd (“we”, “us”, “our”) collects, uses, stores, and protects your personal data when you use our website at tourloom.co.uk, contact us via WhatsApp, telephone, email, or any other communication channel, or use our travel consultation and visa preparation guidance services.

Tourloom Ltd is registered in England and Wales. Our registered address is Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE.

We are committed to protecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Data (Use and Access) Act 2025, and the Privacy and Electronic Communications Regulations 2003 (PECR).

For the purposes of data protection law, Tourloom Ltd is the data controller of the personal data we collect from you.

2. Personal Data We Collect

We collect and process the following categories of personal data:
2.1 Information You Provide Directly
  • Full name (first name and surname)
  • Phone number (including WhatsApp number)
  • Email address
  • Nationality and passport country
  • Current UK immigration status (e.g., Student Visa, Skilled Worker, ILR, BRP/eVisa holder)
  • Intended travel destination (Schengen country)
  • Intended travel dates
  • City of residence in the UK
  • Previous visa application history (including whether you have previously been refused a visa)
  • Financial information provided voluntarily (e.g., whether you hold 6 months of bank statements)
  • Any additional information you choose to share in free-text fields or WhatsApp messages
2.2 Information Collected Automatically
  • IP address and approximate geographic location
  • Browser type and version
  • Device type (mobile, desktop, tablet)
  • Pages visited on our website and time spent on each page
  • Referral source (how you found our website, including Google Ads click data)
  • Cookies and similar tracking technologies (see Section 8 below)

3. How We Use Your Personal Data

We use your personal data for the following purposes:

  • To provide our consultation services — assessing your eligibility, reviewing your documents, preparing cover letters, and advising on appointment strategy
  • To communicate with you — responding to your enquiries via WhatsApp, phone, or email
  • To send you your consultation results and personalised recommendations
  • To improve our website and services — analysing how visitors use our site to improve content and user experience
  • To comply with legal obligations — including record-keeping, tax reporting, and responding to lawful requests from authorities
  • To send you marketing communications — only where you have given explicit consent or where we rely on soft opt-in (see Section 6 below)
  • To measure advertising effectiveness — tracking whether Google Ads clicks result in enquiries (using anonymised, aggregated data)

4. Lawful Basis for Processing

Under the UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following bases:

  • Consent (Article 6(1)(a)) — where you submit a form on our website or send us a WhatsApp message, you consent to us using your data to provide consultation services. You may withdraw consent at any time.
  • Contractual necessity (Article 6(1)(b)) — where processing is necessary to provide the consultation services you have requested.
  • Legitimate interests (Article 6(1)(f)) — for website analytics, fraud prevention, improving our services, and direct marketing to existing clients (where proportionate and where your rights do not override our interests).
  • Legal obligation (Article 6(1)(c)) — where we are required by law to retain certain records (e.g., for tax or regulatory purposes).

5. Who We Share Your Data With

We do not sell, rent, or trade your personal data to any third party. We may share your data with:

  • Service providers who assist us in operating our website and business, including web hosting providers, email service providers, and analytics platforms. These providers process data on our behalf and are bound by contractual obligations to protect your data.
  • Google — we use Google Ads and Google Analytics. Google may receive anonymised or pseudonymised data related to your website visit for advertising measurement purposes. See Google’s Privacy Policy at policies.google.com/privacy.
  • WhatsApp (Meta Platforms) — when you contact us via WhatsApp, your messages are processed by Meta Platforms in accordance with WhatsApp’s Privacy Policy.
  • Professional advisors — including accountants, auditors, or legal advisors where necessary for the conduct of our business.
  • Law enforcement or regulatory authorities — where required by law, court order, or regulatory obligation.

We do not share your personal data with any embassy, consulate, visa application centre (VFS Global, TLScontact, BLS International), or government authority. Your data is used solely for our consultation services. You are responsible for submitting your own information to official bodies.

6. Marketing Communications

We may send you marketing communications about our services where:

  • You have given us your explicit consent to receive marketing (e.g., by ticking an opt-in box or requesting to be added to our mailing list); or
  • You are an existing client and we are contacting you about similar services to those you have previously used (soft opt-in under PECR Regulation 22).

You can opt out of marketing communications at any time by:

  • Replying “STOP” to any WhatsApp marketing message
  • Clicking the unsubscribe link in any marketing email
  • Contacting us at info@tourloom.co.uk

Opting out of marketing will not affect the provision of our consultation services.

7. How Long We Keep Your Data

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

  • Consultation records (including WhatsApp messages and case notes): retained for 24 months after your last interaction with us, unless you request earlier deletion.
  • Financial and invoicing records: retained for 7 years as required by HMRC for tax purposes.
  • Website analytics data: retained in anonymised form for 26 months (Google Analytics default).
  • Marketing consent records: retained for as long as you remain subscribed, plus 12 months after you unsubscribe (to evidence that we have honoured your opt-out).

After the retention period expires, your data is securely deleted or anonymised.

8. Cookies and Tracking Technologies

Our website uses cookies and similar technologies. Cookies are small text files stored on your device when you visit our site.
8.1 Essential Cookies
These are necessary for the website to function properly (e.g., session management, security). They cannot be disabled.
8.2 Analytics Cookies
We use Google Analytics to understand how visitors use our website. These cookies collect anonymised data about pages visited, time on site, and referral sources. You can opt out of Google Analytics by installing the Google Analytics Opt-Out Browser Add-on.
8.3 Advertising Cookies
We use Google Ads conversion tracking to measure whether ad clicks result in enquiries. These cookies do not identify you personally but may link your visit to a Google Ads click for measurement purposes. You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies or delete existing cookies. Please note that disabling cookies may affect the functionality of our website.

9. Your Rights Under UK GDPR

Under UK data protection law, you have the following rights:

  • Right of access — you can request a copy of the personal data we hold about you (a Subject Access Request or “DSAR”).
  • Right to rectification — you can ask us to correct any inaccurate or incomplete data.
  • Right to erasure — you can ask us to delete your personal data where there is no longer a lawful reason for us to retain it.
  • Right to restrict processing — you can ask us to temporarily stop processing your data in certain circumstances.
  • Right to data portability — you can request that we provide your data in a structured, commonly used, machine-readable format.
  • Right to object — you can object to processing based on legitimate interests or for direct marketing purposes.
  • Rights related to automated decision-making — you have the right not to be subject to a decision based solely on automated processing that produces legal or significant effects on you. We do not currently use automated decision-making.

To exercise any of these rights, please contact us at info@tourloom.co.uk or write to us at the address below. We will respond to your request within one calendar month.

If you are not satisfied with our response, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO) at ico.org.uk or by calling 0303 123 1113.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These measures include:

  • SSL/TLS encryption on our website (HTTPS)
  • Secure access controls for internal systems
  • Regular review of data processing practices
  • Staff awareness of data protection responsibilities

While we take all reasonable precautions, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your data.

11. International Data Transfers

Some of our service providers (such as Google and Meta/WhatsApp) may process data outside the United Kingdom. Where personal data is transferred outside the UK, we ensure that adequate safeguards are in place, including:

  • Transfers to countries with UK adequacy decisions
  • The UK International Data Transfer Agreement (IDTA)
  • The UK Addendum to the EU Standard Contractual Clauses

You can contact us for further details about the safeguards applied to specific transfers.

12. Children's Data

Our services are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child under 18 without appropriate parental consent, we will take steps to delete that data promptly.

13. Links to Third-Party Websites

Our website may contain links to external websites, including official embassy and visa application centre websites. We are not responsible for the privacy practices or content of these external sites. We recommend that you read the privacy policies of any external website before providing personal data.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or regulatory guidance. Any significant changes will be communicated via our website. The date at the top of this policy indicates when it was last updated.

We encourage you to review this policy periodically.

15. Data Protection Complaints

In accordance with the Data (Use and Access) Act 2025, we maintain a process for handling data protection complaints. If you have a concern about how we handle your personal data:

  • Step 1: Contact us at info@tourloom.co.uk with details of your complaint.
  • Step 2: We will acknowledge your complaint within 5 working days and investigate within 28 calendar days.
  • Step 3: If you are not satisfied with our response, you may escalate your complaint to the Information Commissioner’s Office (ICO) at ico.org.uk.

16. Contact Us

If you have any questions about this Privacy Policy or wish to exercise your data protection rights, please contact us:

Tourloom Ltd

Unit 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE

Email: info@tourloom.co.uk

Phone: +44 7490 333835

[ Get in Touch ]

Your Definitive Path to Schengen Approval