The Thinking Luxury LTD | Trading as The Thinking Luxury 

Website: www.thethinkingluxury.com | Email: hello@thethinkingluxury.com 

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1. OUR COMMITMENT TO YOUR PRIVACY

At The Thinking Luxury LTD (“the Company”, “we”, “us”), we respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and safeguard your information when you engage our travel design services, request bespoke itineraries, or subscribe to our publication, The Edit.

We operate in strict compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018

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2. THE DATA WE COLLECT

To design, coordinate, and execute travel arrangements on your behalf, we collect personal information directly from you. This includes:

• Identity & Passport Data: Full names, titles, dates of birth, gender, nationality, passport copies, visa details, and national identification numbers required for passenger manifests and destination entry.

• Contact Data: Email addresses, telephone numbers, billing addresses, and digital communication handles (e.g., WhatsApp or mobile messaging) for real-time coordination.

• Travel Preferences & Special Requirements: Dietary requirements, room preferences, preferred paces, mobility assistance needs, or relevant medical considerations you disclose to ensure a seamless itinerary.

• Financial Data: Payment card details and bank transfer information processed securely for itinerary deposits, supplier payments, or consultation fees.

• Editorial & Marketing Data: Your name, email address, and content preferences when you subscribe to The Edit or submit a travel inquiry on our website.

3. LEGAL BASIS FOR PROCESSING YOUR DATA

We process your personal data under the following legal grounds under UK GDPR:

• Contractual Necessity: To perform the travel advisory and booking services you have requested, including reserving accommodation, charters, guided tours, and local transfers.

• Consent: When you subscribe to The Edit or explicitly provide special category data (such as dietary or health considerations) to tailor your travel experience. You may withdraw consent for marketing at any time.

• Legal Obligation: To comply with border control regulations, tax laws, accounting rules, or official governmental mandates.

• Vital Interests: In emergency situations during travel, where sharing essential information (e.g., medical alerts) is necessary to protect your physical safety or that of your party.

4. HOW WE SHARE YOUR DATA WITH TRAVEL SUPPLIERS

To facilitate your travel arrangements, we must share relevant personal data with independent third-party Suppliers involved in delivering your itinerary. This includes:

• Hospitality Partners: Hotels, resorts, lodges, and private property managers.

• Transport & Charter Operators: Marine charter operators, private aviation providers, rail services, and ground transport handlers.

• Local Specialists & Ground Partners: Destination management specialists, local fixers, and activity guides who assist in executing your itinerary.

Note: We only provide Suppliers with the specific data necessary to fulfil your travel booking. We do not sell, rent, or trade your personal data to third parties for commercial marketing purposes

5. INTERNATIONAL DATA TRANSFERS

Because travel by nature involves foreign destinations, fulfilling your itinerary frequently requires transferring your personal data to Suppliers located outside the United Kingdom or European Economic Area (EEA).

Where data is transferred to countries that may not have data protection laws equivalent to UK GDPR standards, we take all reasonable steps to ensure that your data is handled securely and in accordance with this policy.

6. DATA SECURITY & STORAGE

We employ technical and organisational security measures to protect your personal data against unauthorised access, loss, misuse, or alteration. Access to your personal data is strictly restricted to authorised team members and essential operational personnel who require access to coordinate your travel.

7. DATA RETENTION & PREFERENCE PROFILES

We retain your personal travel records only for as long as necessary to satisfy legal, accounting, and reporting obligations.

To make future travel design effortless, we may maintain a secure Travel Preference Profile detailing your past destinations, preferred paces, and travel habits. You may request the deletion of your preference profile at any time.

8. YOUR LEGAL RIGHTS

Under UK GDPR, you have the following rights regarding your personal data:

• Access: The right to request a copy of the personal data we hold about you.

• Correction: The right to request that we correct inaccurate or incomplete data.

• Erasure ("Right to be Forgotten"): The right to request the deletion of your personal data, subject to legal retention obligations.

• Restriction & Objection: The right to restrict or object to the processing of your data, including opting out of direct communications from The Edit.

To exercise any of these rights, please contact us at hello@thethinkingluxury.com. You also have the right to lodge a complaint with the UK Information Commissioner’s Office (ICO) at www.ico.org.uk.

Last update October 2026