Privacy Policy

1.Welcome to our privacy policy

At Sthgilf.com, a brand of NEWARKA GROUP LTD, creating seamless travel experiences is at the heart of what we do. Equally important is how we handle and protect the personal information you share with us. We want you to feel confident that your data is safe, secure, and used responsibly to improve your experience with us.

We value your privacy and are fully committed to protecting your personal data. This privacy policy outlines:

  • How we collect, use, and safeguard your data when you use our website—whether you’re booking a trip, signing up for updates, or entering one of our promotions.
  • Your rights regarding your personal data.
  • How current data protection laws apply to you and how they protect your information.

We’ve designed this privacy policy to be easy to navigate, so you can focus on the areas that matter most to you. For a quick overview, you can also refer to our summary section.

2. About Us

We are NEWARKA GROUP LTD, operating under the trading name "Sthgilf". We primarily provide travel agency services, including booking services for flights, accommodations, transportation, and visa assistance.

NEWARKA GROUP LTD is a company incorporated under the laws of England and Wales with company registration number 16388247. Our postal address is PO Box, Feltham, TW14 0JS, United Kingdom. You can contact us by phone at +44 (0) 7511111951 or via email at sales@sthgilf.com.

NEWARKA GROUP LTD is the data controller responsible for your personal data (collectively referred to in this privacy notice as "Sthgilf", "we", "us", or "our").

3.what data do we collect?

Personal Data is any information about you from which you can be identified. It does not include data where your identity has been removed (it's called anonymous data).

We may collect, use, store and transfer different kinds of personal data about you and other individuals on your booking. We have grouped the data sets together as follows:

  • Identity Data includes details such as passenger title, full name including any middle names and maiden names, gender and biometric data held on travel document(s).
  • Emergency Contact Data for Booking which can include passenger next of kin details such as, full names, address details and contact telephone numbers.
  • Contact Data includes passenger billing address, email address, contact number, full postal address.
  • Financial Data includes passenger bank account and payment card details.
  • Transaction Data includes details about payments made to passenger (refunds) and from passenger and other details of products and services that have been purchased from us.
  • Special Data which relates to passenger disability requests for wheelchair arrangements, meal preferences, dietary and religious requirements.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform you use to access our website.
  • Profile Data includes your username and password, purchases and orders made by you, your interests, preferences and loyalty memberships.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
  • Customer Care Data includes your correspondences, feedback to us, survey responses for market research purposes and voice mail recordings when you contact us.

We also process your personal data to derive information so that we can make personalised offers that we feel are relevant to you. The derived information does not directly or indirectly reveal your identity. However, if we combine or connect the derived information with your personal data, it can directly or indirectly identify you. So, we treat the combined data as personal data which will be used in accordance with this privacy policy.

Where we need to collect personal data by law and you fail to provide that data when requested, we may not be able to provide you with our travel agency services. We may also have to cancel the service you have with us but we will notify you if this is the case at the time.

4.how do we collect your personal data?

We collect personal data in a variety of ways, including:

Direct interactions.You may provide personal information—both your own and that of others in your booking—when you fill out forms on our website or communicate with us via post, phone, email, or other methods. This includes data shared when you:

  • Book our travel services
  • Create an online account
  • Subscribe to updates or newsletters
  • Request promotional material
  • Enter competitions, surveys, or promotional campaigns
  • Send us feedback or contact our support team

Automated technologies When you interact with our website, we may collect certain technical data automatically, such as information about your device, browsing activity, and usage patterns. This is typically gathered through the use of cookies and similar technologies. For more information, please refer to our Cookie Policy.

Third-party or external sources

If you use social media accounts (e.g., Facebook, Twitter, or YouTube) to log into our services, we may receive personal information from those platforms. This can include your name, email address, date of birth, location, and any other details you’ve chosen to share via your social profile.

5.How We Use Your Personal Data

We only use your personal data when legally permitted to do so. Most commonly, your data is used under the following circumstances:

  • To fulfil a contract with you, such as when we provide our travel services in line with our terms and conditions.
  • Where it is necessary for our legitimate business interests, and where your own rights and freedoms do not override those interests.
  • To comply with legal or regulatory obligations that apply to us.

Below are examples of how we may use your personal data, along with the lawful basis for doing so:

  • To manage bookings and deliver travel services (contractual obligation)
  • To communicate with you about your trip or account (legitimate interest)
  • To improve our website, products, and services through analysis and feedback (legitimate interest)
  • To send you marketing or promotional materials you’ve opted in to receive (consent)
  • To meet our legal obligations, including fraud prevention or tax compliance (legal obligation)

We always ensure that your data is handled fairly, lawfully, and with respect to your privacy.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Purpose

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity Data

(b) Contact Data

Performance of travel agency services in accordance with terms and conditions

To supply products and services you request

To charge for products and services requested

(a) Identity Data

(b) Passenger Data

(c) Emergency Contact Data for Booking

(d) Contact Data

(e) Special Data

(f) Financial Data

(g) Transaction Data

(a) Performance of travel agency services in accordance with terms and conditions and explicit consent for processing Special Data

(b) Necessary for our legitimate interests (to recover any sums owed to us)

To manage our relationship with you and administer your account which will include:

(a) Notifying you about changes to our terms and conditions or privacy policy

(b) Detecting and preventing crime and terrorism

(c) Asking you to leave a review or take a survey

(d) Manage any concerns that you raise to our customer care department

(e) Quality assurance and monitoring purposes

(a) Identity Data

(b) Passenger Data

(c) Contact Data

(d) Profile

(e) Marketing and Communications

(f) Customer Care

(g) Usage

(a) Performance of travel agency services in accordance with terms and conditions

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in a competition or complete a survey for purely market research purposes (non-promotional)

(a) Identity Data

(b) Contact Data

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of travel agency services in accordance with terms and conditions

(b) Necessary for our legitimate interests (to study how customers use our products/services to serve better products to them)

To market products and services to you

To complete a survey (promotional)

(a) Identity Data

(b) Your Contact Data  

(c) Marketing and Communications

(d) Profile

(a) Legitimate interest to process marketing data (to serve our products to our customers) and consent for sending electronic marketing communications for new customers or an existing customer relationship to send electronic marketing communications

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant for clients, to inform our marketing strategy so that we serve our customers with better products and services)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity Data

(b) Contact Data

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to inform our marketing strategy so that we serve our customers with better products and services)

Marketing

You will receive marketing communications from us either if you have consented to receive them or you have purchased Sthgilf products or services, and in each case, you have not opted out of receiving that marketing.

6.Managing Your Marketing Preferences

You can opt out of receiving marketing communications from us at any time. Just click the “unsubscribe” or opt-out link included in any marketing email you receive, or contact us directly at sales@sthgilf.co.uk

You can also reach out to let us know your preferences on how you'd like to hear from us—whether by email, SMS, or telephone.

Please note that opting out of marketing communications will not affect important messages related to your bookings, purchases, or customer service requests.

7. Who We Share Your Personal Data With

Your personal data may be shared with trusted third parties where necessary, for the following purposes:

  • Internal support teams and affiliated service entities assisting with customer service, bookings, and administration.
  • External service providers who handle IT infrastructure, hosting, marketing systems, and support services on our behalf.
  • Travel partners and suppliers such as airlines, hotels, transport providers, and visa services, to fulfill your travel arrangements.
  • Government authorities (e.g., immigration, customs, border control) where required by law to ensure safety, security, or regulatory compliance.
  • • In the case of a business transition (e.g., sale, merger, or reorganisation), your personal data may be transferred to the new ownership, following the same privacy standards.s

All third-party partners are required to handle your data securely, only use it as instructed, and comply with relevant data protection laws.

8. How secure do we keep your personal data?

We have implemented appropriate security measures to protect your personal data from accidental loss, unauthorized access, use, alteration, or disclosure. Access to your personal data is limited to staff members and trusted third parties who need it to perform their duties and who are bound by confidentiality obligations.

We have established procedures to address any suspected data breaches and will notify you and relevant authorities when legally required.

We work only with carefully selected suppliers who perform certain services on our behalf. We share only the minimum personal data necessary with these suppliers under strict contractual agreements.

9. How long do we retain your personal data for?

We retain your personal data only as long as necessary to fulfill the purposes for which it was collected, including complying with legal and regulatory obligations.

When determining the retention period, we consider factors such as the nature of the data, potential risks of misuse, our processing purposes, alternative means to achieve those purposes, and applicable laws.

In some cases, we anonymize data for research or statistical purposes and may use it indefinitely without further notice.

10. What are your privacy rights?

You have rights under data protection laws regarding your personal data, including:

  • Access: - Obtain a copy of your personal data and verify lawful processing.
  • Correction: - Request correction of incomplete or inaccurate data.
  • Erasure: Request deletion of data when no longer necessary or if processed unlawfully, subject to legal limitations.
  • Objection:Request suspension of processing under certain circumstances.
  • Data portability: Request transfer of your data in a structured, machine-readable format.

To exercise any of these rights, please contact us at sales@sthgilf.co.uk.

We generally do not charge for these requests unless they are manifestly unfounded, repetitive, or excessive. We may ask for information to verify your identity before processing your request.

We aim to respond within one month, but complex requests may take longer, and we will keep you informed.

11.How to contact us?

For any questions, concerns, privacy compliance queries, or to exercise your data rights, please contact our Customer Service team by phone at +44 (0) 7511111951 or by email at sales@sthgilf.co.uk

You also have the right to lodge a complaint with the relevant data protection authority at any time, though we appreciate the opportunity to resolve your concerns first.

+44 (0) 7511111951