1 Introduction
This privacy policy explains how Sovereign (“we”, “us”, “our”) collects, uses, shares and protects your personal data when you visit our website, contact us, or purchase our services.
We are committed to protecting your privacy and complying with the United Kingdom General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1.1 Who are we?
Sovereign Luxury Travel is operated by Specialist Holidays (Travel) Limited, part of Travcorp Holdings Ltd.
Contact details
- Email: [email protected]
- Postal address: 4th Floor, West Point, Springfield Road, Horsham, RH12 2PD
Travcorp Holdings Ltd acts as the group data controller for certain shared systems and administrative functions.
2 What personal data we collect
We may collect and process the following categories of personal data:
- Identity and contact details – name, title, postal address, email address, telephone number.
- Booking and travel information – passenger names, itinerary, payment details, loyalty numbers, and special requests (such as accessibility or dietary needs).
- Technical information – IP address, device identifiers, browser type, and cookie data.
- Marketing preferences – your communication choices and consent records.
- Customer service records – correspondence and call notes.
We may also collect limited special category data (such as health information relevant to travel arrangements) where necessary and with your explicit consent.
3 How we use your personal data and our lawful bases
We use your personal data for the following purposes, relying on one or more lawful bases under UK GDPR:
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Purpose
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Example
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Lawful Basis
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To provide our services
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Processing bookings, travel documentation, payments
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Contract performance
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To communicate with you
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Responding to enquiries, providing updates about your booking
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Legitimate interests
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To send marketing communications
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Email newsletters or offers (only where you have provided consent)
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Consent
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To personalise and improve our services
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Understanding site usage and preferences, complaints handling
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Legitimate interests
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To comply with legal obligations
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Accounting, tax, fraud prevention, regulatory reporting, visa and travel documentation
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Legal obligation, Contract performance
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To process your job applications
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Responding to job applications, contacting for interview, engaging in employment (both directly and/or via an agent).
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Legitimate interests
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To comply with travel regulations and governmental requirements.
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Compliance with governmental and regulatory requirements for international travel. This may include sharing your information with border control, immigration authorities, customs, security agencies, and law enforcement
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Legal obligation, Contract performance
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To protect, realise or grow the value in our business and assets.
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significant corporate transaction or restructuring, which may include (without limitation) merger, acquisition, asset sale or initial public offering or in the event of insolvency.
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Legal obligation, contract performance, legitimate interests
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You can withdraw consent to marketing at any time
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4 How do we use your data for marketing and advertising purposes?
When we will get in touch with you
One of the other reasons we sometimes collect your information is so that we can form a view on what we think you may want or need, or what may be of interest to you. With this information, we decide which products, services and offers may be relevant for you and what marketing you may be interested in.
We may contact you by email, text message, phone or post to share our latest offers, promotions, and competitions. These messages may also include news or deals from other brands within the Travcorp Holdings Ltd Group — including Sovereign Luxury Travel, Citalia, American Holidays, Destination 2, Destination 2 Cruise, and Holiday Gems — that we think may be relevant or of interest to you. We may also send gentle reminders if you have items left in your booking basket.
We will only engage in direct marketing in accordance with the laws of the relevant country or jurisdiction you are located in. Where required by applicable law, we rely on your consent to contact you directly about relevant products and/or services. In other scenarios, we will rely on our legitimate interests, whilst always ensuring that your rights are protected.
What if I don’t want to receive marketing?
We never want to send our marketing to someone who isn’t interested in receiving this content. If you have decided that you no longer wish to hear from us, you can unsubscribe from marketing by clicking on the ‘unsubscribe’ link included in all of our e-mails or by contacting us.
Third parties and marketing
We do not share your personal data with any third parties for marketing of their products or services unless you provide express opt-in consent.
Sometimes we may use third parties to send communications to you on our behalf, such as brochures or e-newsletters, however these companies do not have the right to send marketing to you for their own purposes.
The marketing material we send to you may occasionally also include information about selected business partners who provide services closely related to our own product.
Social media and online platforms
We share personal information with media agencies, social media, search engines and other online platforms to help us target our online marketing. These third parties might link your data to other information they collect to deliver targeted ads to you or create custom audiences that we think would be interested in our online marketing.
5 Sharing your personal data
We may share your personal data in the following circumstances:
Within Travcorp Holdings Ltd Group
Sovereign is part of the Travcorp Holdings Ltd Group of companies, which also includes Citalia, American Holidays, Destination 2, Destination 2 Cruise, and Holiday Gems.
- We may share limited personal data (for example, your name and contact details) with other Travcorp Holdings Ltd Group brands only where you have provided consent to receive marketing from them, or where it is otherwise lawful to do so (for example, for group-level administrative or IT purposes).
- Each brand acts as a separate data controller for its own marketing.
- All intra-group sharing is governed by data-sharing agreements ensuring consistent privacy and security standards across Travcorp Holdings Ltd Group companies.
With service providers and partners
We use trusted third-party providers to help operate our business, such as IT hosting, CRM systems, payment processors, travel suppliers (e.g. airlines and hotels), analytics providers, and email or SMS delivery partners. These organisations act under written data-processing agreements and may not use your data for their own purposes.
Legal and regulatory disclosures
We may disclose personal data where required by law, regulation, or to protect our legal rights. Sometimes we must provide ‘Advance Passenger Information’ about you to border or immigration authorities of the country you are travelling to. This would usually be the basic information contained in your passport, but the laws of certain countries may require additional information. We will provide this information when we are required to do so
International transfers
Where personal data is transferred outside the UK, we use appropriate safeguards such as adequacy decisions, the UK International Data Transfer Agreement (IDTA), or Standard Contractual Clauses (SCCs), supported by technical and organisational controls (e.g. encryption, access management).
6 Cookies and similar technologies
Our website, sovereign.com, uses cookies and similar technologies to enhance site functionality, improve performance, and support marketing (with your consent).
Essential cookies are used to enable site operation. Non-essential cookies (such as analytics and advertising cookies) are only used where you have given consent through our cookie banner or preference centre.
For full details of the cookies used on our site and how to manage your preferences, please see our separate Cookie Policy.
7 Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this policy and to meet legal, accounting, or regulatory requirements.
Retention periods vary by data type, but we regularly review and securely delete information when it is no longer required.
8 Data Security
We implement appropriate technical and organisational measures to safeguard personal data, including encryption, access controls, network security, and staff training.
All service providers handling data on our behalf are required to meet equivalent security standards.
9 Your rights as a data subject
Under the UK GDPR, you have the following rights:
- To request access to your personal data (a “subject access request”)
- To correct inaccurate or incomplete data
- To request erasure (“the right to be forgotten”)
- To object to or restrict processing in certain circumstances
- To withdraw consent where processing is based on consent
- To lodge a complaint with the Information Commissioner’s Office (ICO)
To exercise your rights or contact us about your data, email [email protected].
By law, you can ask us what information we hold about you, and you can ask us to correct it if it is inaccurate. If we have asked for your consent to process your personal data, you may withdraw that consent at any time.
If we are processing your personal data for reasons of consent or to fulfil a contract, you can ask us to give you a copy of the information in a machine-readable format so that you can transfer it to another provider.
If we are processing your personal data for reasons of consent or legitimate interest, you can request that your data be erased.
You have the right to ask us to stop using your information for a period of time if you believe we are not doing so lawfully.
Finally, in some circumstances you can ask us not to reach decisions affecting you using automated processing or profiling.
To submit a request regarding your personal data by email, post or telephone, please use the contact information provided above in the Who Are We section of this policy.
10 Children’s data
Our services are not directed to children. Where children’s data is required to arrange travel services, we process it only as necessary and with appropriate safeguards.
11 Your right to complain
If you have any questions about this policy or how we handle your data, please contact:
Data Protection Officer
Travcorp Holdings Ltd
Email: [email protected]
If you remain unhappy with how we process your data, you have the right to complain to the Information Commissioner’s Office (ICO):
www.ico.org.uk
Telephone: 0303 123 1113
12 Updates to this privacy policy
We regularly review and, if appropriate, update this privacy policy from time to time, and as our services and use of personal data evolves. If we want to make use of your personal data in a way that we have not previously identified, we will contact you to provide information about this and, if necessary, to ask for your consent.
We will update the version number and date of this document each time it is changed.
Last updated: November 2025
