Privacy
Last Updated: 25/08/2025
Introduction
At Evolution Travel Network Limited, we are committed to ensure confidentiality, accuracy and security of your personal information that we may collect as part of our day-to-day business. Henceforth, we have issued this Privacy Policy (“the Policy”) to explain how we handle, process and use your personal information.
All references in this Policy to Evolution Travel Network Limited, “the Company” “we”, “us”, “our” and like terms should be interpreted accordingly.
Similarly, any reference to “you”, “your”, “yours” or “yourself” in this Privacy Policy is a reference to our clients and potential clients as the context requires unless otherwise stated.
This Policy governs your personal information which is processed as part of your relationship with us and, its collection, which shall include legal and regulatory compliance, personnel, security and operations management. It is important to us that you understand how we handle your personal information.
Kindly read this Policy carefully before sharing information with us. By using this website, you are agreeing to the terms of this Policy, our use, sharing and disclosure of information.
Who Are We?
This Privacy Policy applies to the activities undertaken by Evolution Travel Network Limited with registration number 07132168, VAT number GB986446857 and registered office at 9 Kerry Street, Horsforth, Leeds, England, LS18 4AW.
Which Personal Information do we collect?
We collect two types of personal information: personal information that can be used to identify you and non-personal information.
Personal Information is that type of information relating to an identified or identifiable natural person, whom the latter can be identified, directly or indirectly, in particular reference to an identifier. This personal information is that which you voluntarily provide to us, for instance when you inquire about our products and services.
Non-personal Information is that type of information that does not identify an individual person. This information may be about your internet connection or your IP address or search queries on our website. Moreover, non-personal information may be collected about the visitors to the website when browsing our website, through the use of cookies, flash cookies and web beacons.
We may collect the following information:
- Name, surname and gender
- Marital status
- Date of Birth
- Identification Number
- Mailing address & Email address
- Residential Address
- Telephone number
- Credit Card and payment information
- Cookies and similar technologies
- Any other information that you elect to provide to us or that we may request
In the process of collection of personal information, you should be aware that there may be instances in which the personal information provided by yourself to us is considered as “Special Category Data” which may include among others, personal information for the determination of physical and mental health, racial or ethnic origin, political opinions, religious beliefs or judicial data.
Legal Basis for Processing
The Company will only process personal data where a valid legal basis applies. The lawful bases relevant to the Company’s are the following:
- Performance of a Contract
Processing is necessary for the performance of a contract with you, such as:
- Managing affiliate onboarding and consultant agreements
- Managing consultant accounts and platform access
- Processing contracts and payroll
- Compliance with Legal Obligations
Processing is necessary to comply with UK laws, including:
- Employment, tax, and social security requirements
- Financial reporting and audit obligations
- Record-keeping obligations
- Legitimate Interests
Processing is carried out for the legitimate business interests of the Company, provided these are not overridden by the interests or rights of individuals, including:
- Customer service and quality monitoring
- Fraud prevention and security monitoring
- Business administration and supplier management
- Consent
Processing is based on your freely given, specific, informed and unambiguous consent such as:
- Direct marketing communications
- Processing of special categories of data where necessary for the performance of our services
Individuals have the right to withdraw consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
- Vital Interests
Processing may take place where necessary to protect the vital interests of an individual.
Procedure for the collection of Your Personal Information
Your personal information may be collected or accessed in a number of ways including:
- Directly from yourself (whether directly or verbally)
- Generated by us in correspondence etc.
- Received by third parties in relation to the services provided by ourselves following your permission, which may be obtained directly from you or indirectly through your actions. In such instances, we will make sure that such third parties are entitled to disclose such information to us.
We may also obtain personal information about you through the use of our website (www.evolutiontravelnetwork.com) or through the use of cookies on our website.
Collection and Use of Data
We may collect Non-personal information to analyse trends and to gather other demographic information. Personal information is collected for our legitimate purposes and for any purposes we may disclose to you at the time of collection. We will make sure that your personal information is processed fairly and lawfully, and only to the extent necessary as may be allowed in terms of law, or in terms of our agreement or our terms and conditions. Personal Information may be processed:
- to provide you with our services requested and, any ancillary services related thereto;
- to communicate with you and to fulfil your requests for our products or services;
- to improve our products or services where possible;
- for customer service purposes;
- for marketing and promotional purposes, including remarketing;
- to conduct research;
- to provide information that we believe may be of interest to you;
- to enforce the legal terms that govern your use of our Website, and/or for the reasons specific to the type of collection of information.
Disclosure of Your Personal Information
Your personal information may be disclosed with our employees, affiliated Travel Consultants and contractors, our subsidiary companies and any other third parties which may require such information in order to be able to assist us in handling the relationship which we have with you. When we share your personal information with such third parties, we make sure that such parties make use of this data in a manner which ensures safety and security to your personal data. We will not sell or rent your personal information to third parties for marketing purposes without your consent.
We may further disclose personal information when lawfully requested by public authorities including information based on law enforcement requirements such as credit card processing and fraud prevention.
Restriction of Processing of Personal Information
We recognise your right to restrict the processing of personal information where one of the following applies:
- Accuracy is contested: You contest the accuracy or correctness of the personal data and processing will be restricted until the data is certified or corrected.
- Unlawful processing: The processing is unlawful, however you oppose the erasure of the personal data and requests the restriction of personal data instead or;
- Legal claims: you require the data to be kept for the establishment, exercise or defence of legal claims;
- Objection to processing: You have objected to processing pending the verification whether the Company’s legitimate grounds override yours.
Group Companies
Evolution Travel Network Limited is part of a group of related companies, situated in various jurisdictions, that are linked together and operate different parts of the business. We act as a group and henceforth we share information and data with other group companies as may be necessary. We confirm that all group companies adhere to the data protection obligations listed herein and subject to the extent and limitations imposed by any national laws of any particular company. By accepting our T&Cs, you confirm that you are bound by this Privacy Policy and also accept that we may share information with other group companies, and that any processing may be done by any one of the group companies.
Your Consent
When your consent is required for the collection, processing and disclosure of personal information, we will ensure that such consent is freely given and is unambiguous. Furthermore, subject to legal or contractual restrictions, you may withdraw your consent to the processing of your personal information. Any communications with respect to such withdrawal or variation of consent shall be in writing and addressed at privacy@evolutiontravelnetwork.com
Accuracy, Access and Rectification of Your Personal Information
We will employ reasonable means to keep your personal information accurate, complete and up to date for its intended use, however you must immediately inform us, if and when, your personal information changes.
In so far as your personal information in concerned, you shall have the right to receive confirmation that your personal information is being processed and may request access to the said personal information. You may further request a copy of such information obtained by ourselves – such request may be made verbally or by electronic means. We will provide a copy of such in a commonly used electronic form.
Provided however, your right of access to personal information is not absolute. Where applicable law or regulatory requirements allow us to refuse to provide such personal information we shall reserve our right not to respond. Where it is impossible to provide you with access to your personal information, we will provide reasons as to why this is not possible, subject to any legal or regulatory restrictions.
You may review your personal information which we hold on yourself for you to be able to verify the lawfulness of the processing carried out by ourselves. When you become aware of any inaccurate or incompleteness in their personal information, you are to inform the Company for rectification. Where it results that there is inaccurate information, we will amend such information with the alternative text that you believe that it is accurate. Furthermore, we shall take all the necessary steps to inform any relevant third parties which hold the inaccurate information to rectify accordingly.
Your Right of Erasure
There are certain instances where you may ask us to have your data concerning you to be erased. Upon such request, the Company will take all the necessary measures in order to erase all personal information concerning you without undue delay. The right of erasure will apply in the following instances:
- Data is no longer necessary: the personal data is no longer needed for the purposes for which it was collected or processed;
- Withdrawal of consent: you withdraw consent, and there is no other lawful basis for processing;
- Objection to processing: you object to processing and there are no overriding legitimate grounds to continue;
- Unlawful processing: the personal data has been unlawfully processed;
- Legal Obligation: the data must be erased to comply with a legal obligation under UK law.
Provided that, the right of erasure of personal data is not absolute as this is limited by, and subject to all compliance, regulatory and legal obligations, including anti-money laundering regulations, employment legislation, tax and accounting purposes, whereby the Company is obliged to hold personal data for such period stipulated by law, even after the termination of the relationship between yourself and the Company, or any other such longer time which may be necessary in view of the particular services provided to you.
Erasure also does not apply for the establishment, exercise, or defence of legal claims and reasons of public interest in the area of research and statistical purposes.
Marketing Communications and Campaigns
We may use your personal data (such as your name, surname and contact details) to inform you about our services, special offers, or promotions that may be of interest to you. For this purpose, we may carry out online marketing campaigns on platforms such as Meta (Facebook, Instagram), to reach individuals who may be interested in our services.
The processing of your personal data for marketing purposes is based on your consent, which you may withdraw at any time, or on our legitimate interest, where permitted by law. Where we rely on legitimate interests, we balance our interest in promoting our services with your rights and freedoms.
Your personal data will not be shared with Meta in a form that directly identifies you beyond what is necessary for the campaign to function. Data is uploaded in a protected, encrypted manner and is only used to match our records with Meta’s user database for the purposes of displaying relevant advertisements. Meta acts as an independent data controller for any further processing it undertakes.
You have the right to object at any time to the processing of your personal data for direct marketing purposes, including profiling related to such marketing. If you object, your personal data will no longer be processed for such purposes.
If you no longer wish to receive marketing communications from us, you can unsubscribe at any time by contacting us at privacy@evolutiontravelnetwork.com.
International Transfer of Personal Data
Where we allow contractors or third parties to process your personal information outside the United Kingdom, we will make sure that there are the proper safeguards in place so as to ensure that your personal information is subject to the same standards, security and protection as when processing your personal information inside the United Kingdom.
Protection, Storage and Retention of Personal Information
Safeguarding the privacy of your personal data is of utmost importance to us. Personal Information is retained on our servers in Germany and in other European countries. We will use appropriate administrative, technical and physical measures to safeguard your personal information against loss, misuse, theft, modification, disclosure or destruction. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information to Evolution Travel Network Ltd.’s employees, contractors and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
We will retain your personal information for as long as we believe that such information is necessary to fulfil the purposes for which the personal information was collected, except as otherwise allowed or required by applicable laws and regulatory requirements.
When we consider that such personal information is no longer required, we will remove any details that will identify you or destroy any records in relation to yourself.
Electronic Notices
You may sign up for our periodical newsletter by opting in to receive such newsletter via our website, and by further confirming your consent to such newsletter by clicking on a link which is sent to you via email. You may decide to unsubscribe to our newsletter at any time by selecting the ‘unsubscribe’ icon on our website. We may also send you transactional, technical or other service notifications from time to time.
Links to other Websites
When you access other websites from hyperlinks on our website, we have no control over the content of those websites.
Changes to this Policy
Please note that this policy may change from time to time. All updates will be published on the Website and, if the changes are significant, the changes will be posted on the Website and on this page thirty days prior to taking effect. Each version of this policy will be identifiable at the top of this document by its effective date and version number. We encourage you to refer to this policy periodically.
Complaints and Concerns
If you have any concerns with regards to our privacy methods and processes, you have the right to contact us by telephone, in writing or by e-mail to make a complaint at privacy@evolutiontravelnetwork.com. Your concerns will be dealt within the shortest time possible. In case you are not satisfied with our response, you may contact the Information Commissioner’s Office (ICO). You can find the details about how to do this on the ICO website at https://ico.org.uk/make-a-complaint/