Privacy Policy
This policy explains how Acumon Ltd (“we”), the data controller for Acumon Holiday Planner, collects and uses personal data, and the rights you have under the UK GDPR and EU GDPR. Contact our privacy team at privacy@example.com.
Data we collect
- Identity & contact — names and email addresses of the organiser and the participants they invite.
- Interview & preferences— your chat messages and the holiday preferences, votes, and feedback extracted from them. Please don’t share special-category data (e.g. health) unless it’s necessary for the trip; if you do, you consent to us using it to plan.
- Traveller booking data— for an actual booking: each traveller’s name, date of birth, gender as required by the carrier, contact details, and the booking reference and itinerary.
- Technical data — limited request metadata (e.g. IP address and timestamps) used to keep the Service secure and to enforce rate limits.
We do not use payment card numbers — see “Payments” below.
Why we use it, and our lawful basis
- To run the planner (interviews, brief, options, voting) — necessary to perform our contract with you, and our legitimate interest in providing the Service to the group.
- To make a booking you request (passing traveller details to the airline / accommodation provider via our booking provider) — necessary to perform the contract.
- To send service emails(invites, “options ready”, booking confirmations, a pre-departure reminder) — contract performance and legitimate interests.
- To keep the Service secure and prevent abuse — legitimate interests.
- To meet tax, accounting and legal obligations for completed bookings — legal obligation.
- Any special-category details you volunteer for the trip — your explicit consent, which you can withdraw at any time.
AI processing
The interview, reconciliation and research are performed by AI models. Your messages and preferences are sent to our AI providers to generate the brief and options. Output is advisory and may be inaccurate. We do not use your personal data to train third-party models, and we don’t make solely-automated decisions that produce legal or similarly significant effects about you.
Who we share data with
We use carefully selected processors and partners to deliver the Service:
- AI providers (e.g. xAI, Anthropic) — to run the interview, brief and research.
- Booking & payment provider (Duffel Ltd) — to search, order, and take payment for flights and accommodation. They act as merchant of record for card payments and as a processor/controller for booking data as applicable.
- Airlines & accommodation providers — to fulfil a booking you request; they are independent controllers of the data needed to provide your travel.
- Email and hosting providers — to send service emails and run the application.
We do not sell your personal data.
International transfers
Some providers are outside the UK/EEA (e.g. in the United States). Where data is transferred, we rely on appropriate safeguards such as the UK International Data Transfer Addendum and the EU Standard Contractual Clauses, or an adequacy decision.
How long we keep it
- Planning data (interview, preferences, votes) — kept while the trip is active and deleted on request, or routinely after the trip concludes.
- Booking records — kept for about 7 years after travel to meet tax, accounting and dispute-handling obligations.
Payments
In-app card payments are handled by Duffel Ltd as merchant of record. Card details are entered into their secure form and are not transmitted to or stored on our servers — we only receive a confirmation and an authentication reference.
Cookies
We use a small number of strictly-necessary cookies only — for example, an organiser session cookie so the dashboard knows it’s you, and (where the platform integration is enabled) a single sign-on session cookie. We don’t use advertising or cross-site tracking cookies.
Your rights
You have the right to:
- access a copy of your data, and have inaccurate data corrected;
- erase your data, and restrict or object to certain processing;
- data portability (receive your data in a machine-readable form); and
- withdraw consent at any time, without affecting prior processing.
You can exercise access, export and erasure yourself from your data & privacy page (open it from your interview or results link), or email privacy@example.com. If you’re in the UK you can also complain to the Information Commissioner’s Office (ico.org.uk); in the EU, to your local supervisory authority.
Children
The Service is for adults. Where children travel, the organiser provides only the minimum details the carrier requires and confirms they are authorised to do so. We don’t knowingly collect children’s data for any other purpose.
Changes
We’ll update this policy as the Service evolves; the “last updated” date below reflects the current version. Material changes will be highlighted where appropriate.
Last updated 2026-05-31 · Acumon Ltd