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GDPR Compliance Statement

Last updated: August 2026

Our Commitment to Data Protection

true-reed is committed to protecting your personal data in accordance with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This page outlines our compliance measures and your rights under GDPR.

Data Controller Information

For the purposes of GDPR, the data controller is:

true-reed
47 George Street
Edinburgh EH2 2HT
United Kingdom
Email: [email protected]

Lawful Basis for Processing

We process personal data only when we have a lawful basis to do so. Our processing activities rely on the following legal grounds:

Consent

When you provide explicit consent for specific processing activities, such as subscribing to marketing communications or accepting cookies on our website. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

Contractual Necessity

Processing necessary to fulfill our contractual obligations when you book travel services with us. This includes coordinating accommodations, transportation, and other elements of your travel experience.

Legitimate Interests

Processing necessary for our legitimate business interests, provided these interests do not override your fundamental rights and freedoms. This includes:

  • Improving and developing our services
  • Ensuring network and information security
  • Preventing fraud and illegal activities
  • Internal administrative purposes

Legal Obligation

Processing required to comply with legal obligations, such as maintaining financial records for tax purposes or responding to lawful requests from authorities.

Your Rights Under GDPR

GDPR grants you specific rights regarding your personal data. We respect these rights and have established procedures to facilitate their exercise.

Right of Access

You have the right to obtain confirmation of whether we process your personal data and, if so, to access that data along with specific information about the processing. We will provide a copy of your personal data free of charge upon request.

Right to Rectification

You have the right to request correction of inaccurate personal data and to have incomplete personal data completed. We will respond to rectification requests within 30 days.

Right to Erasure

Also known as the "right to be forgotten," you may request deletion of your personal data when:

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw consent and there is no other legal ground for processing
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed
  • Deletion is required for compliance with legal obligations

Note that certain legal obligations may require us to retain specific data even after an erasure request.

Right to Restriction of Processing

You may request that we restrict processing of your personal data when:

  • You contest the accuracy of the data, during the period we verify accuracy
  • Processing is unlawful but you prefer restriction to erasure
  • We no longer need the data but you require it for legal claims
  • You have objected to processing pending verification of whether our legitimate grounds override yours

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller when processing is based on consent or contract and is carried out by automated means.

Right to Object

You may object to processing of your personal data when:

  • Processing is based on legitimate interests or performance of a public interest task
  • Personal data is used for direct marketing purposes
  • Personal data is processed for scientific, historical research, or statistical purposes

We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or the processing is necessary for legal claims.

Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing, including profiling, which produce legal effects or similarly significantly affect you. We do not currently engage in automated decision-making that would trigger this right.

How to Exercise Your Rights

To exercise any of your GDPR rights, please contact us at:

Email: [email protected]

We will respond to your request within 30 days. In complex cases, we may extend this period by an additional 60 days and will inform you of any such extension.

You will not be charged a fee for exercising your rights unless your request is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable administrative fee or refuse to act on the request.

Data Retention Periods

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal obligations:

  • Inquiry data: 12 months from last contact
  • Customer booking data: 7 years for accounting and tax compliance
  • Marketing consent records: Until consent is withdrawn plus 1 year for compliance verification
  • Website analytics data: 26 months

International Data Transfers

When we transfer personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, including:

  • Adequacy decisions by the European Commission
  • Standard contractual clauses approved by the European Commission
  • Binding corporate rules where applicable

Data Security Measures

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of personal data in transit and at rest
  • Regular security assessments and penetration testing
  • Access controls and authentication mechanisms
  • Staff training on data protection principles and practices
  • Incident response procedures for data breaches

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay. We will also notify the relevant supervisory authority within 72 hours of becoming aware of the breach, as required by GDPR.

Data Protection Impact Assessments

We conduct Data Protection Impact Assessments (DPIAs) for processing activities that are likely to result in high risk to individuals' rights and freedoms. These assessments help us identify and minimize data protection risks.

Third-Party Data Processors

When we engage third-party processors to handle personal data on our behalf, we ensure they:

  • Provide sufficient guarantees of appropriate technical and organizational measures
  • Process data only on our documented instructions
  • Maintain confidentiality of personal data
  • Implement appropriate security measures
  • Comply with GDPR requirements

Children's Data

Our services are not directed to children under 16 years of age. We do not knowingly collect or process personal data from children. If we become aware that we have collected data from a child without appropriate parental consent, we will take steps to delete that information promptly.

Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your habitual residence, place of work, or place of the alleged infringement, if you believe our processing of your personal data violates GDPR.

For complaints in the United Kingdom, the relevant authority is:

Information Commissioner's Office (ICO)
Wycliffe House, Water Lane
Wilmslow, Cheshire SK9 5AF
United Kingdom
Website: ico.org.uk

Updates to This Statement

We may update this GDPR compliance statement periodically to reflect changes in our practices, legal requirements, or regulatory guidance. Material changes will be communicated through our website with an updated "Last updated" date.

Contact for Data Protection Matters

For questions or concerns regarding our GDPR compliance or data protection practices, please contact:

Email: [email protected]
Address: 47 George Street, Edinburgh EH2 2HT, United Kingdom

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47 George Street
Edinburgh EH2 2HT
United Kingdom

[email protected]

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