Privacy Policy

Who we are

Middle Domain PortalLtd (“Pax Commons Network”, “we”, “us”, “our”) provides educational content, playbooks, and tools for tour operators.

Registered address: 71 Hughes Ferry, Alexland, ML9 3BS, GB. Telephone: +44 5970 715809. Email: [email protected].

For purposes of UK GDPR/EU GDPR, we are a controller of personal data we collect through our site.

Scope

This Privacy Policy applies to personal data processed through our website and related pages that link to this Policy. If we link to third-party services (e.g., booking platforms, social media), their privacy practices apply when you interact with them.

Data we collect

Information you provide

• Contact details (name, email, phone) when you contact us or submit forms.
• Professional details (company, role) if provided in messages.
• Preferences and consents (marketing preferences, cookie selections).
• Content of communications you send to us.

Information collected automatically

• Usage data such as pages viewed, referring/exit pages, timestamps, and interactions.
• Device and browser data such as IP address, device type, OS, language, and settings.
• Cookies and similar technologies for analytics and experience improvements. See “Cookies” below.

Information from third parties

• Social platforms and ad networks (e.g., limited analytics/pixel events).
• Publicly available sources (e.g., professional profiles) for partnership outreach.

Legal bases (EEA/UK)

• Performance of a contract: to respond to your requests and provide the site.
• Legitimate interests: to secure our services, measure audience and performance, prevent misuse, and improve content (balanced against your rights).
• Consent: for non-essential cookies/analytics and certain marketing communications.
• Compliance with legal obligations.

How we use personal data

• Provide and operate our website and features.
• Respond to inquiries and provide customer support.
• Analyze site performance and improve content and experience.
• Maintain security, prevent fraud and abuse, and troubleshoot issues.
• Comply with applicable laws and enforce our terms.
• Send administrative and, where allowed, marketing communications. You may opt out at any time.

How we share information

• Service providers processing data under our instructions (e.g., analytics, hosting, communications tools).
• Compliance and safety: law enforcement requests, legal claims, or to protect rights, safety, and security.
• Business transfers: in connection with mergers or similar events, subject to safeguards.

We do not sell your personal information.

International transfers

Where data is transferred outside the UK/EEA, we rely on appropriate safeguards such as adequacy regulations or Standard Contractual Clauses.

Data retention

We retain personal data for as long as necessary for the purposes described in this Policy, including to comply with legal obligations, resolve disputes, and enforce agreements. Criteria include the nature of data, risk, and legal requirements.

Security

We implement technical and organizational measures to protect personal data. No system is perfectly secure; please use caution when sharing information online.

Cookies and similar technologies

We use necessary cookies to operate our site and optional cookies for analytics and experience improvements.

• Necessary cookies: required for core functionality.
• Analytics cookies: help us measure and improve performance.
• Experience improvements: remember preferences and enhance usability.

You can manage preferences via the cookie banner and “Cookie preferences” modal accessible from the banner or by clearing stored consent and reloading the page. Browser settings also allow you to block or delete cookies.

Analytics and pixels

We use Google Analytics and Facebook Pixel to understand site usage and improve content. Where required, we request your consent for analytics cookies and disable analytics if you decline in our cookie settings. You can also use Google’s and Meta’s opt-out tools.

Your rights

Depending on your location (including UK/EEA), you may have rights to:

• Access your personal data and receive a copy.
• Rectify inaccurate or incomplete data.
• Erase your data in certain circumstances.
• Restrict or object to processing, including for marketing.
• Data portability for information you provided to us.
• Withdraw consent at any time where processing is based on consent.

To exercise rights, contact us at [email protected]. You may lodge a complaint with your local supervisory authority; in the UK, the ICO.

Children’s privacy

Our site is not directed to children under 16. If you believe a child provided personal data, contact us to remove it.

Third-party links

Our site may link to third-party sites and services. Their privacy practices govern when you interact with them.

Changes to this Policy

We may update this Policy from time to time. We will update the “Effective date” below and, where appropriate, provide additional notice.

Effective date: 23 Sep 2025

Contact us

Middle Domain PortalLtd, 71 Hughes Ferry, Alexland, ML9 3BS, GB

+44 5970 715809 • [email protected]