Data Privacy Policy | Private Safaris East Africa
data privacy policy

Data Privacy Policy

Privacy Policy

 

Welcome to the Private Safaris (E.A) Ltd privacy notice. Private Safaris (E.A) Ltd respects your privacy and is committed to protecting your personal data either collected online or offline. This privacy notice aims to inform you on how we look after your personal data when you visit our website and all affiliate sites regardless of where you visit it from or when you otherwise provide personal data to us via other means (such as over the telephone, through feedback forms – regardless of where you contact us from) and tell you about your privacy rights and how the law protects you.

Purpose of this privacy notice

 

This privacy notice aims to give you information on how Private Safaris collects, manages and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone, through feedback forms etc.), when you purchase travel arrangements through us or otherwise provide personal data to us.

 

This website is not intended for children. The only circumstances in which we collect data relating to children is when you make booking arrangements and there are children in your party.

 

It is important that you read this privacy notice together with any other privacy notice or fair processing notice that we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

 

Controller

 

Private Safaris (E.A) Ltd is the controller and in certain circumstances a processor and responsible for your personal data (collectively referred to as “Private Safaris (E.A) Ltd”, “Private Safaris”, “we”, “us” or “our” in this privacy notice).

 

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

 

Contact details

Our details are:

 

Full name of legal entity:      Private Safaris (E.A) Limited

Email address:                       info.ke@privatesafaris.com

Postal address:                      P.O. Box 16913-00620, Nairobi, Kenya

Physical location(HQ):          Oilibya Plaza, 2nd Floor, Muthaiga Road, Nairobi, Kenya

 

You have the right to make a complaint at any time. There are many data protection supervisory bodies around the world. We would, however, appreciate the chance to deal with your concerns before you approach any of these supervisory bodies. Please contact us in the first instance.

 

Changes to the privacy notice and your duty to inform us of changes

 

This version was last updated on 24th May 2018 and historic versions can be obtained by contacting us.

 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change during the course of your relationship with us.

 

Third-party links

 

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

 

  1. Identity data: This includes data relating specifically to your identity, such as your first name, maiden name, last name, or similar identifiers, marital status, title, date of birth and gender.
  2. Contact data: This includes data relating to how you may be contacted, such as your home address, business address, email address and telephone numbers.
  3. Financial data: This includes data relating to your means and methods of payment, such as your bank account and payment card details. We don’t retain or store credit card details unless authorised to retain as a security deposit.
  4. Transaction data: This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.
  5. Technical data: This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your log-in data, browser type and version, time-zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  6. Profile data: This includes the data that we receive if and when you create a profile on our website and make use of that profile, such as your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses.
  7. Usage data: This includes information about how you use our website, products and services.
  8. Marketing and communications data: This includes your preferences in relation to whether or not you want to receive marketing from us and also your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data which we may use for various reasons. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.

 

Special categories of personal data

 

During our interactions, we may collect special categories of personal data about you as detailed below. This may be because you want us to have the information, or we may obtain this inadvertently as result of a group you travel with. It may also be because we need to know certain personal data about you, which is special category data, in order that we can provide you with the best possible service and advise you whether a trip is suitable for you. Health is one of the best examples of this.

 

Example 1: If we receive a group booking from a specific religious association we will inadvertently have details of religious beliefs of those individuals. The same can be said for groups from political associations and trade union associations.

 

Example 2: We are sometimes asked whether certain medication is allowed to be taken into certain jurisdictions, which discloses certain medical conditions.

 

Other special category of personal data, which we may end up receiving from you include details about your:

 

  • – dietary requirements which may disclose your religious or philosophical beliefs
  • – health
  • – race or ethnicity
  • – sex life or your sexual orientation
  • – political opinions
  • – trade union membership
  • – genetic and biometric data

 

We collect and process the above data only where it is strictly necessary to do so. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

 

You are not under any obligation to consent to us processing your sensitive personal data.

 

If you are happy to consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time.

We use different methods to collect data from and about you including through:

 

A. Direct interactions

You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

 

  • make a booking of arrangements
  • request a quote for arrangements
  • subscribe to our newsletter or other publications
  • request marketing
  • enter a competition, promotion or survey
  • give us some feedback
  • use our online payment and client portals

 

B. Automated technologies or interactions

As you interact with our website, we may automatically collect technical data about your equipment, browsing actions and patterns.

 

 

C. Third parties

We may receive personal data about you from various third parties, as set out below:

 

Technical Data from the following parties:

 

  1. Analytics providers, such as Google, which is based outside the EU
  2. Travel, email and trust platform networks, such as tripadvisor.com, which are based outside the EU

 

D. From time to time, we may run competitions with third parties where we would collect data about you; however, all participants have the option to opt-in or out to receive any information from us.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

 

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

 

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at info.ke@privatesafaris.co.ke.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

There may be more than one lawful basis on which we may process your personal data depending on the specific purpose for which we are using your data. Please contact us at info.ke@privatesafaris.co.ke if you need details about the specific legal basis we are relying on to process your personal data where more than one basis has been set out in the table below.

 

Purpose/Activity/Type of Data Lawful basis for processing including basis of legitimate interest
Register you as a prospect and initial profile creation

 

Type of data:

a)      Identity

b)      Contact

 

 

Necessary for our legitimate interest

Creation of itinerary and trip planning, which includes the transfer of data to other jurisdictions

 

Type of data:

a)      Identity

b)      Contact

c)      Special Categories of personal data

 

 

 

a)      Performance of a contract with you

b)      Necessary for our legitimate interest

To process and deliver your booking including:

 

a)      Putting final itinerary together and adding additional requests

b)      Transfer of further data to other jurisdictions as requested by the guest

c)      Manage payments, fees and charges

d)      Collect and recover money owed to us

 

Type of data:

a)      Identity

b)      Contact

c)      Financial

d)      Transaction

e)      Marketing and Communications.

f)       Special Categories of personal data

 

 

 

 

 

 

 

a)      Performance of a contract with you.

b)      Necessary for our legitimate interests (to recover debts due to us)

To manage our relationship with you which will include:

 

a)      Right to rectification of your personal information

b)      Asking you to leave a review or take a survey

 

Type of data:

a)      Identity

b)      Contact

c)      Profile

d)      Marketing and Communications

e)      Special Categories of personal data

 

 

 

 

 

a)      Necessary to comply with a legal obligation

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

To enable you to partake in a prize draw, competition or complete a survey

 

Type of data:

a)      Identity

b)      Contact

c)      Profile

d)      Usage

e)      Marketing and Communications

 

 

a)      Performance of a contract with you

b)      Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

 

Type of data:

a)      Identity

b)      Contact

c)      Technical

 

a)      Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

b)      Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

 

Type of data:

a)      Identity

b)      Contact

c)      Profile

d)      Usage

e)      Marketing and Communications

f)       Technical

 

 

 

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).  To ensure marketing is relevant to your requirements or interests

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

 

Type of data:

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, to develop our business and to inform our marketing strategy)

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

 

Type of data:

a)      Identity

b)      Contact

c)      Technical

d)      Usage

e)      Profile

 

 

 

 

Necessary for our legitimate interests (to develop our products/services and grow our business)

 

 

 

 

Marketing

 

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional offers from us

We may use your identity, contact, technical, usage and profile data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

 

You will receive marketing communications from us if you have requested information from us or purchased services from us and if you have, in each case, you have opted in to receive that marketing. This will be through newsletters, sms or such other communication that allows us to keep in touch with you.

 

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out unsubscribe links on any marketing message sent to you, sms shortcodes or by contacting your travel consultant/specialist at any time, or by sending an email to info.ke@privatesafaris.co.ke

 

Where you opt-out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of arrangements or other such transactions.

 

Cookies (TBA)

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://www.privatesafaris.co.ke/cookies.

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at info.ke@privatesafaris.co.ke.

 

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.

 

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

A. Internal third parties: Other companies in the Private Safaris brand name acting as joint controllers or processors and who are based globally and provide travel related services, IT and system administration, human resources-related services, finance and legal.

 

B. External third parties. These are:

i) Service providers acting as processors based globally and providing travel related services.

ii) Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, information technology service providers and insurers based globally who provide consultancy, banking, legal, insurance and accounting services.

iii) HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based globally who require reporting of processing activities in certain circumstances.

 

C. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If you are travelling outside the European Union (EU), we do transfer your personal data outside the EU in order to satisfy our contract with you.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to only those employees, agents, contractors and other third parties, who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

 

In addition to the above, by law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for ten years after they cease being customers for tax purposes.

 

In some circumstances, you can ask us to delete your data. In this case, you have the right to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you, if applicable, at the time of your request.

 

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes. In this instance, we may use this information indefinitely without further notice to you.

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These are:

 

  1. Request access to your personal data
  2. Request correction of your personal data
  3. Request erasure of your personal data
  4. Object to processing of your personal data
  5. Request restriction of processing your personal data
  6. Request transfer of your personal data
  7. Right to withdraw consent

 

If you wish to exercise any of the rights set out above, please contact us at info.ke@privatesafaris.co.ke.

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.  You will be required to show your identification at a Private Safaris office in Kenya.  Please contact us at info.ke@privatesafaris.co.ke to determine your nearest location.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.