Minim privacy policy



  1. General:  Tourwriter Limited (we/us/our) acknowledges and respects the privacy of individuals. This policy (Privacy Policy) sets out:
    1. how our services may be used;
    2. how we collect, use, manage and protect personal information;
    3. your rights in relation to any of your personal information that we hold; and
    4. how to contact us.
  2. Subject to Change: This Privacy Policy is subject to change. Any changes will be effective when a notice of the change is posted on Please check this Privacy Policy periodically so that you are aware of any changes.


  1. Our Services: We are in the business of providing travel booking and itinerary creation related services to travel agents. We do this through a SaaS enabled platform and a strict set of terms of use that our service users must accept before accessing the Tourwriter service (Service).
  2. Restrictions:  We restrict the use of the Service in a way that respects the privacy and rights of others.  In particular, users must comply with, all applicable laws, rules and regulations.



Information we collect and hold

  1. Collection of Information: We may collect and hold personal information provided by a travel agent organisation for whom you are either acting on behalf of, or a client of, when they sign up to the Service and as they use the Service and our websites (Personal Information).  We use Personal Information in carrying out the legitimate interests pursued by our business, including (without limitation) (i) to deliver the Service or information to our service users, (ii) to assist you (or our service users) with matters relating to the Service, (iii) to improve, and better understand your preferences and assist with your travel arrangements (iv) to notify you of any change to the Service, and (v) to fulfill our legal, contractual and regulatory obligations.  Examples of Personal Information we may collect and hold includes, without limitation:
    1. your name, address, email address and IP address; and
    2. a log of your interaction with the Service and our websites.

How we use and disclose Personal Information

  1. Use of information: We may use the Personal Information that we gather in connection with the above-stated purposes and for direct marketing purposes, such as sending you offers or information on our services that we consider may be of interest to you (or the organisation for whom you work). You can opt out of receiving marketing materials by writing to us at the below address or following any instructions to unsubscribe in one of our marketing emails.
  2. Third party providers:  We may use other companies and individuals to perform services on our behalf, or otherwise in connection with the Services. They may have access to your Personal Information as needed to perform and provide these services or otherwise obtain the benefit of the Services (as applicable), but we will not authorise them to use your personal information for any purpose that is inconsistent with this Privacy Policy.
  3. Travel Agents:  In connection with the Services provided by us to our service users, your Personal Information may be disclosed by your travel agent to other travel agents utilizing the Service solely for the purpose of assisting you with your travel arrangements.  
  4. Disclosure to third parties: We may disclose Personal Information:
    1. to meet the purpose for which it was gathered;
    2. for the purpose of processing and delivering a service related request;
    3. if we are required or authorised by law to disclose the information;
    4. if we are required to disclose the information under any agreement or arrangements we have with our third party providers or service users;
    5. to protect and defend our rights or property and those of our third party providers (and, where applicable, their end users); and
    6. to protect the safety of users of the Service or services provided by our third party providers, or the public.
  5. Law enforcement: We may preserve or disclose your Personal Information if we believe that it is reasonably necessary to comply with any law, regulation, legal process or governmental request or to address fraud, security or technical issues.  However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s (including any Governmental) request to disclose your information.
  6. Affiliates: We may disclose Personal Information to our affiliated companies and to any prospective purchasers of us or a substantial portion of our assets.
  7. Data minimization:  We will only collect and retain Personal information that is necessary for the legitimate purposes outlined in this privacy policy and our end user agreement (located on our website at and as otherwise consented to by you.   
  8. Data retention:  When you (or your travel agent) cease to use the Service and we are no longer required to comply with any legal obligation that necessitates the retention of your personal information, we will securely delete your Personal Information.  However, despite this, we may retain Personal Information in an aggregated, de-identified or otherwise anonymous form, such that there is no reliable way of identifying you from the information.


Access, correction and security

  1. Accuracy: We will take reasonable steps to ensure that the Personal Information we collect is accurate, complete and up-to-date.
  2. Access and correction: You can access and request correction of any of your Personal Information at any time. Any such requests should be made directly by contacting us (see below for details). Please note that there are some exceptions to your right to gain access to your information, including (but not limited to) where:
    1. providing access would have an unreasonable impact upon the privacy of other individuals;
    2. the request for access is frivolous or vexatious;
    3. the information relates to existing or anticipated legal proceedings between you and us, and the information would not be accessible by the process of discovery in those proceedings; or
    4. providing access would be unlawful.
  3. Resident of European Union:  if you are located in the European Union (including the United Kingdom) you may also:
    1. request the erasure of your personal information;
    2. restrict or object to the processing by Tourwriter of your personal information;
    3. request the porting of your personal information to another organisation;
    4. withdraw any consent that you have previously given in respect of your personal information; and
    5. lodge a complaint regarding our data processing activities as they relate to your Personal Information with the supervisory authority in your member state.

It is noted that, if Tourwriter is unable to collect or process your Personal Information, your (and your travel agent’s) use of the Service may suffer from reduced functionality, and certain features of the Service may be disabled.  Further, where we are not, or are no longer, in a position to identify you within the information we hold (including because of any de-identification techniques we have employed), then your rights described above may no longer apply.

  1. Security:  We will collect, store, use and transmit personal information securely using technical and administrative security measures as are reasonable in the circumstances, and that reduce the risk of accidental or unauthorised loss, misuse, disclosure or alteration.

Clickstream data

  1. Automated collection: Each time you visit our websites or access or use our Service our server collects some anonymous information, known as click-stream data, including the type of browser and system you are using; the address of the site you have come from and move to after your visit; the date and time of your visit; and your IP address.
  2. Aggregate and anonymous data: We may collect this information for statistical purposes to find out how our websites and services are used and navigated, including the number of hits, the frequency and duration of visits, most popular session times. We may use this information to evaluate and improve our websites and services performance or to identify individuals whom may threaten the security or integrity of our websites or services.
  3. Law Enforcement: We may disclose your IP address to law enforcement authorities if requested by the authorities to do so or if directed to do so by the courts.


  1. Cookies: A cookie is a piece of information that our web server may send to your machine when you visit our websites. The cookie is stored on your machine, but does not identify you or give us any information about your computer.
  2. Use of Cookies: A cookie helps us to recognise you when you re-visit our websites and to co-ordinate your access to different pages on our websites. We use cookies to learn more about the way you interact with our content and help us improve your experience of using our websites.
  3. Disabling cookies: With most internet browsers, you can erase cookies from your computer hard drive, block all cookies, or receive a warning before a cookie is stored. If you want to do this, refer to your browser instructions or help screen to learn more. If you reject the use of cookies, you will still be able to access our websites but please note that some of its functions may not work as well as if cookies were enabled.

Links to other sites

  1. Third party links: We may provide links on our websites to other sites. If you use these links, you will leave our sites and we are not responsible for any third party sites, their content or their usage of your Personal Information. We advise that you check the terms and conditions of use, the privacy policies and any other guidelines for access and use on those sites as they will apply to your access and use of those sites and any services and information contained on such sites.

Information validation and security review

  1. Validation: You authorise us to use and disclose your Personal Information for the purposes of validating the information provided to us in connection with the Service (and access to the Service).
  2. Transmission:  We take reasonable measures to protect all Personal Information stored within our database.  However, the transmission of information using the Internet is not completely secure. We therefore cannot guarantee the security of data transmitted to our website (or via our Service) and any transmission is at your own risk.


  1. Further Information: Please contact us if you:
    1. wish to discuss any privacy issues;
    2. wish to raise any objections to the way in which we deal with your personal information;  
    3. have any concerns regarding your personal information
    4. do not wish to receive any future communications from us.
  2. By using our websites and/or providing your Personal Information to us (either directly or via your travel agent), you are consenting to the collection, holding, use and disclosure or that information as set out in this Privacy Policy.

David Crompton

Chief Privacy Officer