Privacy Policy | KILROY

First and foremost, we want you to know that your privacy concerns us, and we take the responsibility you directly or indirectly have entrusted us with seriously. 

This policy explains how KILROY collects customer data, uses the data and in which situations and to whom the data is disclosed.   

Collection and processing of personal data is an unavoidable and necessary part of conducting this kind of business and to fulfil the purposes described in this privacy policy. 

KILROY is Data Controller for the processing of personal data for these purposes. 

If you have any questions regarding this privacy policy or to our handling of your personal data, our address is: 

KILROY Travel UK Ltd

43 Queens Road, Clifton, Bristol, BS8 1 QQ

More information about the processing of customer data at KILROY can also be obtained by writing to [email protected]  

 1. PROTECTION AND SAFETY IS IMPORTANT TO US 

Responsible handling of personal data collected as part of the operation of our business is crucial to our business objectives and reputation. In this privacy policy we will account for how your personal data is collected and used when you are a customer, supplier, or business partner and how you can gain access to your own personal data. 

2. WHAT IS PERSONAL DATA?

Personal data is any kind of data about an identified or identifiable living individual. An identifiable individual is understood as a person, who directly or indirectly can be identified, among other things, by an identification number or one or more elements, that are particular to a given person’s identity. 

3. WHAT TYPE OF PERSONAL DATA ARE WE PROCESSING AND WHY?

Your personal data will be used for different purposes in relation to your position as customer and the operation of KILROY. The data collected may vary, depending on whether you are a customer, supplier, or business partner, but in general it will be data regarding customer administration, supplier administration, direct marketing and data regarding KILROY rights and obligations. Failure to provide personal data on your part, may mean that KILROY is unable to fulfil its obligations towards you as customer or supplier. 

As a rule, KILROY only collects and processes regular personal data. In specific cases of booking a trip, it can be necessary for us to a limited extent, to process sensitive personal data (e.g. information regarding special meals or special needs assistance during your trip), as well as information regarding social security numbers (e.g. in connection with collecting passport copy for visa applications), but only when it is necessary for booking the trip and assistance you require. KILROY will typically gather the following information: 

3.1 Information concerning our customers 

The information provided to us when booking a trip or creating a customer profile with us, e.g. online via the webpage or by contacting our customer service / travel consultants, including contact details (first name, middle name(s), surname, address, telephone number, email address, title and job position), social security number (for visa applications etc.), passport number, bank details, debit- and credit card details, information you provide regarding special preferences during your trip (e.g. information on dietary restrictions, special needs assistance due to disability or illness, etc.), health information (when booking trips for health- or medical treatments, sports trips, etc.), information regarding your height, weight, clothing and shoe size (for booking equipment on ski trips, sports trips, etc.), purpose of travel, information regarding which languages you speak, citizenship, information about your emergency contacts and travel insurance, in the extent that you provide it to us, in connection with e.g. Backpacker Adventure trips], requisition (in the case of business- or health trips), information regarding your marketing and communication preferences, along with information you have given us if you contact us with questions, to report a problem or when you contact us with reference to your customer relationship, information regarding student, teacher, youth card issuance photo, place of study (applies only for International Student Identity Card (ISIC)), place of work (applies only for International Teacher Identity Card (ITIC)), promotional code, card validity, date of issue, card number, information regarding fees payment (price, type of payment, date, payment confirmation). The personal data processed in relation to management of events or contests is: the information about the event (title, content, date, time, place, price of the ticket); information regarding participant in the event (first name, last name, email address, phone number (optional), IP address (in case of webinars)); questions asked during the event or webinar as well as the communication via email/phone regarding the event (optional); payment handling information (first name, last name, price/fee, date of payment, method of payment). 

3.2 Information concerning our suppliers and business partners 

Information you provide when entering a contract or agreement with us, including contact information (job, job title, first name, middle name(s), surnames, addresses, telephone number, email address), information regarding your marketing and communication preferences, as well as information you have given us if you contact us with questions, to report a problem or when you contact us with reference to your customer relationship. 

3.3 Information concerning collection of applications for universities and organisations 

When you decide to apply for an internship, studies, or academic courses via KILROY we act on behalf of the institution providing an internship, studies, or academic courses. Thus, KILROY processes the personal data for the purposes stated by the institution – collection of applications. Thus, an institution (university, organization, other institution) processes data as a controller and KILROY processes personal data as a processor on behalf of the institution. For detailed information about your data processing, please read the data privacy policy of the institution you apply to. 

4. WHAT DO WE USE YOUR PERSONAL DATA FOR?

KILROY processes your personal data to fulfill the purposes stated below. Notice that not all purposes, categories of information, recipients of information and types of procedures are applicable to you in all cases. 

KILROY exclusively processes your personal data to the extent necessary for you as customer, supplier, or business partner (as specific interests in each case are taken into account) or in accordance with existing law. 

4.1 Customer administration 

KILROY processes your personal data when establishing and administering your customer relationship with KILROY, as a part of the operation of our company, including booking trips and delivery of our different products (e.g. management of contests and events, visa application, travel insurance, transfer service, student, teacher, youth card issuance, etc.), maintenance of our customer registers, billing, marketing, statistics, etc. 

All statistics and analysis are compiled in anonymized form and therefore do not contain information that can lead directly back to you as a person. 

4.2 Administration of supplier and business partner relationships 

KILROY processes your information when co-administrating supplier and business partner relations, where you are the supplier or business partner, or contact person with a supplier or business partner, which KILROY is working with as a part of the operation of our company, including maintenance of our CRM-registry with information about our contact with each supplier and business partner. 

4.3 Compliance with current laws and regulations 

KILROY processes your personal data in compliance with the laws and regulations that KILROY is subject to with respect to the operation of the business or for filing different liability and disclosure requirements in accordance with applicable laws and regulations does not use your personal data to make decisions, that are solely based on automatic processing, except for profiling. Profiling is a form of automated processing of your personal data. We use profiling and data modelling e.g. to be able to offer you specific services and products that meet your preferences for marketing purposes. 

KILROY strives to guarantee that all personal data we process is correct and up to date. We therefore always ask you to inform us regarding possible changes in your personal details (e.g. change of address, name, phone number or payment) so that we can guarantee that your personal data is always correct and up to date. You should update your personal data immediately in case of changes. 

5. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

KILROY will retain information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with the Services or to comply with applicable legal, tax, or accounting requirements). 

Data processing retention period for establishing and administering customer relationship with KILROY is 36 months after the provision of the services or expiration of the product you have purchased (e.g. visa expiration, travel insurance expiration, transfer service has been provided, student, teacher, youth card expiration, date of arrival, date of an event or a contest, etc.) whichever comes last. When a customer declines a requested proposal, the personal data is stored for 36 months after the proposal expires. Information regarding emergency contacts and travel insurance will be stored for the same retention period as your customer data (36 months after the trip or service has ended), after which it will be deleted. 

KILROY use your personal data for direct marketing purposes for 36 months after you have subscribed to newsletters or after receiving your consent. Your personal data is also used for direct marketing purposes for 36 months after you have bought products or services at KILROY. Your data shall be deleted after we have received and executed your request to delete your personal data, or you have unsubscribed from newsletters. 

The personal data for the purposes of administration of supplier and business partner relationships is stored for 36 months after the expiration of business relations. KILROY processes personal data according to the retention periods provided by the laws and regulations. The data retention periods are never prolonged unless it is based under specific law and regulation. 

6. LEGAL BASE FOR PROCESSING YOUR PERSONAL DATA

In addition, there may be situations where we treat your personal data for the sake of KILROY or third parties' legitimate interests with regard to the purposes described above, unless consideration for your interests is deemed more important (ex. direct marketing, customer administration). 

7. SHARING OF PERSONAL DATA

KILROY only discloses data to the extent necessary for the operation of our business, including providing your trip and the other products you have purchased with us in connection therewith. KILROY will typically pass personal data to the following recipients when booking a trip and related products: 

7.1 Global Distribution System (GDS) 

A GDS is an IT network system owned or operated by a company that allows transactions between the travel industry's service providers, mainly airlines, hotels, car rental companies and travel agents. A GDS connects services, prices and booking by consolidating products across the three travel sectors, i.e. flight reservations, hotel reservations and car rental. 

7.2 Airlines 

KILROY discloses personal data to airlines when booking your trips. For the purpose of booking your flight, we will typically provide details of first name, middle name(s), surname, departure airport, destination, departure and return dates, bonus card number, special requests regarding your trip, including booking special meals during flights and necessary special needs assistance on the plane or at the airport for the chosen airline. With respect to trips to special destinations, we can also provide information about your passport number to the airline. 

7.3 Hotels 

KILROY passes personal data to the hotels that you intend to use during your trip. For the purpose of booking your hotel accommodation, we will typically provide information about first name, middle name(s), surname, destination, date of arrival and departure, room category, bonus card number, special requests for your trip, including dietary restrictions or special needs assistance due to disability or illness, during your stay at the given hotel. 

7.4 Car rental services 

KILROY discloses personal data to car rental companies if you require a vehicle during your trip. For the purpose of booking your rental car, we will typically provide information about your first name, middle name(s), surname, pickup location, rental period, vehicle category, bonus card number, special needs in connection with rental of the vehicle, including special requirements relating to disability or illness, child seats etc. 

7.5 Bus operators 

KILROY discloses personal data to bus companies if a bus trip is part of your trip (e.g. for day trips to tourist attractions, etc.). For the purpose of booking your bus trip, we will typically provide information about first name, middle name(s), surname, pickup location, date and time of bus, destination and special requests during the bus trip, including booking special meals and necessary special requirements or assistance relating to disability or illness. 

7.6 Shipping companies 

KILROY discloses personal data to shipping companies if you are going on a ship trip as part of your trip (e.g. for day trips to tourist attractions, cruises, etc.). For the purpose of booking your ship trip, we will typically provide information about first name, middle name(s), surname, destination, itinerary, date and time of departure and return as well as special requests during sailing, including booking special meals and necessary special requirements or assistance relating to disability or illness and information about travel documents. 

7.7 Bedbanks 

A bedbank is an IT network system owned or operated by a company that allows transactions between travel industry service providers, mainly hotels and travel agencies or end customers. KILROY discloses personal data to bedbanks to book the hotels that you will use on your trip. For the purpose of booking your hotel accommodation through a bedbank, we will typically provide information about first name, middle name(s), surname, destination, date of arrival and departure, room category, bonus card number, as well as special requests, including booking special meals during the hotel stay and necessary special requirements or assistance relating to disability or illness. 

7.8 Travel Agents 

If you, as a part of your trip, participate in excursions or need transfer, KILROY may pass personal data to travel agents. The travel agent’s responsibility is to organise the excursion or transfer, when booking a given service from a local supplier at the destination. For booking your excursions, transfers, etc. we typically provide information about first name, middle name(s), surname, date and time of arrival and departure, type of vehicle, destination, as well as special requests, including booking special meals during the hotel stay and necessary special requirements or assistance relating to disability or illness. 

7.9 Insurance companies 

As part of the booking of your trip with us, you can purchase a travel and/or cancellation insurance. If you wish to purchase this insurance, we will disclose personal data to the insurance company for the purpose of taking out the insurance with them. For the purpose of taking out a travel and/or cancellation insurance, we typically provide information to the insurance company about first name, middle name(s), surname, e-mail address, destination, departure and return date, and travel type. 

7.10 Equipment Rental Companies 

As part of the booking of your trip with us, you can rent any equipment that you may need on your trip, e.g. ski equipment, diving equipment, etc. If you wish to rent such equipment, we will disclose the information to the company at your destination from which you will be renting the equipment. For equipment rental we typically provide information to the rental company about first name, middle name(s), surname, type of equipment, pick-up location, rental period and information about height, weight, clothes and shoe size. 

7.11 Tour operators 

KILROY discloses personal data to tour companies if you are going on a tour as part of your trip (e.g. for a day tour to tourist attractions, scuba-diving, etc.). For the purpose of booking your tour, we will typically provide information about your first name, middle name(s), surname, tour, itinerary, date and time of tour as well as special requests during the tour, including booking special meals and necessary special requirements or assistance relating to disability or illness, information about travel documents (only if needed). 

7.12 ISIC 

When ordering a student, teacher, or youth card, KILROY passes personal data to ISIC Association company registration number 26746760 registered address Nytorv 5, 1450 Copenhagen Denmark. This is where ISIC Association stores cardholder data for all active student, teacher or youth cards globally. The purpose of the data provision is to prove student, teacher, or youth card validity globally. The following data is provided: first name, surname, birth date, place of study, photo, place of work (applies only for ITIC), email address, address, C/O-address, card number. 

7.13 Specially regarding qualified offers 

When you choose KILROY, you have the opportunity to get a qualified offer on a trip. A qualified offer is a type of offer, in which a preliminary reservation of the desired trip is made for you when preparing the offer. This allows you to reserve space on the desired departures for up to three days before deciding whether a ticket should be issued for the preliminary reservation, or it should be annulled. 

In order to create a qualified offer, we provide information about you and the requested reservation to a GDS (as mentioned above), which makes the preliminary reservation at the airline, the hotel, etc. 

As a part of obtaining a qualified offer, personal data is passed on to several new independent data controllers (GDS, airlines, hotels, etc.). Your information may be retained by these recipients after the expiry of the offer - also in case the offer is annulled. 

Furthermore, KILROY may disclose your personal data to other suppliers and service providers as a part of normal operation of the company, e.g. in connection with external administration of our IT systems, analysis reports, marketing, debt collection, credit rating, audit, legal assistance, etc. 

For further information regarding our suppliers’ and partners' processing and protection of your personal data, please refer to their privacy policies and terms of use. KILROY strives to limit the disclosure of personal data in personally identifiable format to the maximum extent possible, thereby limiting the cases where information can lead back to you personally. 

KILROY does not disclose your personal data unless it is necessary to perform our business or meet your needs. 

8. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA

Due to the nature of the business, your personal data may be transferred to countries outside the EU/EEA when booking a trip with us. In order to be able to deliver our services to you, we have to use partners and suppliers outside the EU/EEA in certain cases. 

Without the possibility of transferring your information to recipients outside the EU/EEA, KILROY will be unable to deliver certain travel arrangements. This applies if booking your trip requires that information is sent to recipients outside the EU/EEA, for example, to book flights, hotels, etc. at your travel destination. 

KILROY does not, in any case, pass your personal data to recipients outside of the EU/EEA, unless this is necessary to carry out our business and meet your needs e.g. by delivering the requested trip.  

Rest assured that to the extent your personal data is transferred to countries outside the EU/EEA, KILROY will ensure that the transfer takes place in accordance with applicable data protection law.  

For certain countries outside the EU/EEA, the European Commission has decided that the countries provide a level of protection adequate with the protection ensured within the EU/EEA. For transfers to the United States, KILROY relies on the EU–US Data Privacy Framework adopted in July 2023. For other countries without an adequacy decision, KILROY ensures the establish of appropriate safeguards (including the EU Commission Standard Contractual Clauses) and, where necessary, supplementary security measures to the extent possible, this entails entering into the EU Commission's Standard Contractual (SCCs) between KILROY and the recipient in the country which will form the legal transfer basis ensuring an adequate level of protection. Further, supplementary security measures will be adopted prior to the transfer if deemed necessary.  

In other cases, where the transfer cannot be based on the SCCs or corresponding legal basis and only occurs occasionally, the transfer will be based on another valid legal transfer ground, such as GDPR article 49(1)(b) as the transfer of your personal data to a certain country is necessary for the performance of a contract between you and KILROY (the booking of your trip) or for the purpose of executing measures at your request prior to entering such a contract (e.g. in the case of a qualified offer as mentioned in section 6.13), GDPR article 49(1)(c) as the transfer is necessary for the conclusion or performance of a contract between KILROY and another party but in your interest, GDPR article 49(1)(e) as the transfer is necessary for the establishment, exercise or defense of legal claims, or GDPR article 49(1)(f) as the transfer is necessary to protect vital interest where the person is incapable of providing consent, whichever applies in the specific instances. 

You can request a copy of the legal basis for the transfer by contacting [email protected] 

9. DATA INTEGRITY AND SECURITY

Personal data will be stored no longer than necessary in order to fulfil the purpose for which they have been collected, unless the storage is required to comply with national legal requirements, including statutory storage periods in connection with bookkeeping, etc. 

It is KILROY policy to protect personal data by taking adequate technical and organizational security measures. When your personal data is no longer needed, we will ensure that they are deleted in a safe manner. 

10. YOUR RIGHTS

You are entitled to access any personal data we have registered and use, information on where it comes from and what we use it for. You can obtain information about how long we store your data, who receives data about you and to what extent we disclose data in KILROY and abroad. Your right of access may, however, be restricted by legislation, protection of other persons’ privacy and consideration for our business and practices. Our know-how, business secrets as well as internal assessments and material may also be exempt from the right of access. 

In certain circumstances, you have the right to object to our processing your personal data. This is the case for example when the processing is based on our legitimate interests. Objection to direct marketing: You have the right to object to our use of your personal data for direct marketing purposes, including profiling that is related to this purpose. 

If the data is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or erased with the restrictions that follow from existing legislation and rights to process data. These rights are known as the “right to rectification”, “right to erasure” or “right to be forgotten”. 

If you believe that the data we have registered about you is incorrect, or if you have objected to the use of the data, you may demand that we restrict the use of these data to storage. Use will be restricted to storage only until the correctness of the data can be established, or it can be checked whether our legitimate interests outweigh your interests. 

If you are entitled to have the data we have registered about you erased, you may instead request us to restrict the use of these data to storage. If we need to use the data we have registered about you solely to assert a legal claim, you may also demand that other use of these data be restricted to storage. We may, however, be entitled to other use to assert a legal claim or if you have granted your consent to this. 

You can withdraw your consent at any given time. Please note that if you withdraw your consent, we may not be able to offer you specific services or products. Note also that we will continue to use your personal data, for example, to fulfil an agreement we have made with you or if we are required to do so by law. 

If we use data based on your consent or as a result of an agreement, and the data processing is automated, you have a right to receive a copy of the data you have provided in an electronic machine-readable format. 

If you wish to claim one or more of your rights, please contact us at [email protected]  Your request will be processed in accordance with the data protection legislation currently in force. 

Complaints about the processing of your personal data by KILROY can be made to: 

UK – Information Commissioner’s Office
Wycliffe House, Water Ln, Wilmslow SK9 5AF, England Website: https://ico.org.uk/

11. UPDATES

KILROY regularly evaluates and updates this privacy policy. Therefore please regularly check this privacy policy for any changes that may affect our processing of your personal data. 

Updated 29 August 29, 2025