Last Updated: June 26, 2018
SABABU SAFARIS asks that you read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.
At SABABU SAFARIS, your privacy matters to us. When you use our services, you are placing your trust in us to ensure the privacy of your personal data and we are committed to protecting it. When we collect personal data about you, and you are located in the European Union, a citizen of the European Union or have an otherwise relevant nexus with the European Union, we are then subject to regulation under the General Data Protection Regulation which applies across the European Union (including in the United Kingdom) and we are responsible as controller of that personal information for the purposes of those laws.
INFORMATION WE COLLECT
Personal data you provide us
The sort of personal data we collect will be information such as name, address, email address, telephone number, date of birth, and personal travel arrangements. In addition, we may also be required to obtain your passport details. We will need to collect this information to arrange the travel and other services you are requesting.
In some cases, we may also need to collect more sensitive personal data such as information concerning medical conditions, disabilities and special requirements such as dietary requests, which may disclose your religious beliefs, so that we can consider your particular needs in relation to a booking.
Personal data we collect for legal, compliance, regulatory and crime detection and prevention purposes.
We process your personal data so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order, and to protect our property, rights and interests as well as the property, rights and interests of other persons.
We also process your personal data for crime prevention and detection purposes, including the prevention of fraud for online payments, for identity verification, for credit checking and credit scoring purposes and accounting or audit purposes.
Personal data we collect from third parties
We collect personal data from third parties who you have authorized to provide your personal data to us (for example, this may be your travel agent or another person making a booking on your behalf, your travel companion, your travel coordinator, our promotion partners, social media and other digital website). We also collect personal data from individuals who may refer you as a friend to our products or services. We ask these individuals to confirm that you are happy to hear from us.
Sensitive personal data we collect
We do not generally collect sensitive personal data from you (or those you are booking for), but where we do, we seek to minimize the collection and use of it and handle it with extra care. We also share this information with third parties (who help manage our business and deliver services such as those parties who provide wheelchairs at airports) and other companies (who help manage your booking or journey), and we transfer it globally.
Where you (or any passenger travelling) provides us with sensitive personal data you agree that you have voluntarily provided such information, and you consent (and the passenger travelling consents) for us to use that information for the purposes for which it was collected.
Personal data we collect when you are making a payment
We collect different personal data depending on your payment method (such as credit card, bank transfer, cash). For example, for credit card payments we may collect the credit card holder name, address, card number, expiry date and CVC code.
Personal data we collect automatically
When you use our services, we automatically collect certain information, including personal data, concerning the services you use and the way you use them. This includes:
- Geo-location data, about your approximate location, as determined through data such as your IP address;
- Usage and log data, such as the date and time you accessed our services, the duration of your session, data about clicks, the internet browser you use and which pages have been shown to you;
- Data about your computer’s operating system, like application versions and language settings;
- If you're using a mobile device, we might also collect data about the type of device you are using and data such as the mobile network your device is using to access our services.
HOW WE USE YOUR INFORMATION
We use, store, and process information, including personal data, about you to create tailor-made travel itineraries, for marketing purposes, for data analytics, data profiling and to improve the quality of our service.
To create tailor-made travel itineraries
When putting together tailor-made travel itineraries, we may use your personal data to:
- Fulfill our contract with you and/or deal with your booking or intended booking, including processing your booking, sending you your itinerary or other details relating to your booking;
- Update you on changes to your travel itinerary (for example, if there is a change to your booking pre-travel; if a flight is delayed or cancelled);
- Manage your wider travel or services requirements (for example, liaising with and transferring your data to airlines, service providers and/or travel facilitators so that they can facilitate your booking and/or your travel arrangements so any disruption can be minimized), this includes when you book a tailor-made itinerary, hotel, car or another service which may be provided by us or third parties with us;
- Process payments for your booking, fulfil requests for refunds and for accounting or audit purposes;
- Personalize the service and offers you receive (for example, by being aware of previous travel experiences, transactions or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile);
- Communicate and interact with you at different times throughout your journey;
- Communicate with airlines, accommodation providers and other parties that are part of your journey regarding your experience, preferences, compliments or complaints.
For marketing purposes
We may use personal data to let you know about our products and services that we think may be of interest to you. This may be based on your preferences, derived from Cookies, inferred from your interactions with us, including on our social media accounts or market research. We may also let you know about our corporate services which we believe may be relevant to you in a professional capacity.
We also work with social media and other digital websites to provide you with advertisements within those websites. We provide them with your name and contact details (such as your email address or phone numbers). If these social media and digital websites match profile information provided by us with your profile information held by them then they will serve you our advertisements. The social media websites will not identify you or share other personal data in your social media account with us.
We will only send you direct marketing, whether about us, carefully selected third parties or partners, products or services, in accordance with your marketing preferences. We may contact you by email, SMS/text, social media, or through other communication channels that we think you may find helpful. If at any time you would like us to stop sending you marketing material, please contact us or choose the relevant "unsubscribe" option.
For profiling purposes
We use personal data such as your date of birth, gender, country of residence, transactions (for example, payments made with us and flights taken), information derived from Cookies and your preferences and behaviors for profiling. Some of the legitimate purposes we profile personal data include:
- To obtain a better understanding of what you would like to see from us and how we can continue to improve our services for you;
- To provide you with tailored content online and optimize your experience of our Website;
- To provide you with tailored advertisements on other websites you visit, such as social media websites;
- To share marketing material we believe may be of interest to you, including from our third-party partners;
- To help us operate our services more efficiently.
We will take steps to ensure that prior to profiling your personal data for a legitimate interest that our legitimate interest is not overridden by your own interests or fundamental rights and freedoms.
For data analytics
We aggregate personal data and remove any identifying elements in order to analyze patterns and improve our marketing and promotional efforts, to analyze website use, to improve our content and products and services, to customize our website’ content, layout, products and services, and to support our business operations and we may appoint third parties to do this on our behalf.
We gather certain usage information like the number and frequency of visitors to our website. This information includes which website you were redirected from, which web pages you visit during your session, what browser you are using, your device ID and your IP address. This collective data helps us to determine how our customers use parts of our website and do research on our users’ demographics, interests, and behavior to better understand them. One of the ways we do this is by installing and using Cookies on your browser or device.
To improve the quality of our service
In our efforts to improve the quality of service we offer you, we may use your personal data to:
- Improve the products and services we offer or help us to create new ones;
- Conduct customer satisfaction surveys so that we can obtain a better understanding of how we can continue to improve the products and services we offer or help us to create new ones. During these surveys we may collect personal data from you relating to your thoughts/comments about your experience with us;
- Improve our internal systems, for systems testing, IT maintenance or development training, benchmarking and performance measurement.
Legal basis for using your information
We will only collect, process, use, share and store your personal data where we are satisfied that we have an appropriate legal basis to do this. This may be because:
- We need to use your personal data to perform a contract or take steps to enter into a contract with you. For example, to manage your inquiry, to manage your booking with us, to take payment for your booking, or to complete your travel arrangements;
- We need to use your personal data for our legitimate interest as a commercial organization. For example, we may record the calls of our travel consultants so that we can review how we handle calls. We may also capture your interactions with our website and booking journey via tools on our website in order to identify errors or issues and ensure your customer experience meets expectations. In all such cases, we will look after your information at all times in a way that is proportionate and that respects your privacy rights.
- We need to use your personal data to comply with a relevant legal or regulatory obligation that we have; and
- We have your consent to use your personal data for a particular activity. For example, where you consent to us sharing special offers with you which, we think, may be of interest.
HOW WE SHARE YOUR INFORMATION
We do not share your personal data with companies, organizations or individuals outside of SABABU SAFARIS except in the following cases:
With your consent
We may share your personal data when you have provided consent as described at the time of consent.
Service providers of your tailor-made travel itinerary
We will share your personal data with service providers whose products or services you are purchasing through our websites and are part of your tailor-made travel itinerary; or otherwise to service providers such as airlines, tourism agencies, hotel, transfer and car hire companies, tour and excursion providers or travel agents, including if there is a problem with your booking so that your travel agent can resolve it with you.
Third-party service providers
We may share your personal data with third parties, who help us manage our business and deliver our products and services. These third parties have agreed to confidentiality obligations. Any personal data we share with them or which they collect on our behalf is used solely for the purposes of providing the contracted service to us.
These third parties:
- Help manage our IT and back-office systems;
- Advertise our company online and using social media websites;
- Manage communications and tailor marketing campaigns;
- Provide internet and infrastructure services for our facilities;
- Conduct research that assists us in understanding consumer interests.
We may need to share certain reservation details with the payment service provider and the relevant financial institution to verify payments (such as banks and payment card companies). We may share information with relevant financial institutions if we consider it strictly necessary to detect fraudulent transactions and security incidents.
For legal reasons
We may share personal data with governments, government organizations and agencies, border control agencies, regulators, law enforcement and others as permitted or required by law, in relation to API or such other legal requirements as they apply from time to time when travelling to or from a particular country, and to generally comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies.
We may share aggregated data (combined data of our website users or clients that no longer identifies or references an individual website user or client) and non-personally identifiable information for analysis, demographic profiling, marketing and advertising, and other business purposes.
HOW WE TRANSFER YOUR DATA OUT OF THE EUROPEAN UNION
We may transfer your personal information to the following which are located outside the European Economic Area (EEA) as follows:
Such countries do not have the same data protection laws as the EEA. Whilst the European Commission has not given a formal decision that such countries provide an adequate level of data protection similar to those which apply in EEA, any transfer of your personal information will be subject to appropriate or suitable relevant safeguards as permitted under Article 46(5) of the General Data Protection Regulation that are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information.
HOW WE PROTECT AND STORE YOUR INFORMATION
Protection of your personal data
We have implemented and maintain appropriate technical and organizational security measures, policies and procedures designed to protect the personal data that you share with us and safeguard the privacy of such information. For example, the measures we take include:
- Placing confidentiality requirements on our staff members and service providers;
- Destroying or permanently anonymizing personal data if it is no longer needed for the purposes for which it was collected; and
- Following security procedures in the storage and disclosure of your personal data to prevent unauthorized access to it; and
- Using secure communication channels on our website such as SSL ("secure sockets layer") for transmitting data that is sent to us. SSL is the industry standard encryption protocol used to protect online transaction channels.
Storage of your personal data
In some circumstances, we may store your personal data for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances, we may store your personal data for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or if we reasonably believe there is a prospect of litigation relating to your personal data or dealings.
OTHER IMPORTANT INFORMATION
How we treat personal data about children
For children younger than 18 years old, the use of our services is only permitted with the lawful consent of a parent or a guardian. In the case where a child is part of a booking, we collect and use personal data of the child only as it is provided by the parent or guardian and with their consent.
We reserve the right to erase all personal data of any child under 18 years old if we become aware that the data was provided to us without the lawful consent of a parent or a guardian.
A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our websites and the internet and helps us provide better website services to you. Cookies cannot harm your computer in any way and are an industry standard. They are small text files that contain only information provided by you, the visitor, to the website. Furthermore, our users may configure their browsers to not accept our cookies.
Cookies may collect personal data about you. Cookies help us remember information about your visit to our website and other settings and searches. Cookies enable us to understand who has seen which web pages and how frequently, and to determine which are the most popular areas of our website. They can also help us to operate our website more efficiently and customize your view of the website to reflect your preferences and activities. They also help us tailor our marketing and advertisements to you on our website, other websites you visit, social media websites and your other devices.
You have certain rights in relation to your personal data. In order to exercise your rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal data to you.
You can exercise your rights by emailing us at firstname.lastname@example.org. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request within 30 days or inform you if we require further information in order to fulfill your request.
You may also write to us at:
Sababu Safaris LLC
10 City Place, #16C
White Plains, NY 10601
We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
Access your personal data
You have the right to be given reasonable access to your personal data. You may also have the right to request copies of personal data that you have provided to us in a structured, commonly used, and machine-readable format.
Rectify inaccurate or incomplete personal data
You have a right to request that we rectify inaccurate personal data. We may seek to verify the accuracy of the personal data before rectifying it.
Erase your personal data
If you no longer want us to use your information, you can also request that we erase your personal data in limited circumstances where:
- It is no longer needed for the purposes for which it was collected; or
- You have withdrawn your consent (where the data processing was based on consent); or
- Following a successful right to object; or
- It has been processed unlawfully.
We are not required to comply with your request to erase personal data if the processing of your personal data is necessary:
- For compliance with a legal obligation; or
- For the establishment, exercise or defense of legal claims.
Please note that if you request the erasure of your personal data:
- We may retain some of your personal data as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety;
- Due to maintenance reasons and protection from accidental or malicious loss and destruction, residual copies of your personal data may not be removed from our backup systems for a limited period of time.
Object to us processing of your personal data
You can object to any processing of your personal data, which has our legitimate interests as its legal basis if you believe your fundamental rights and freedoms outweigh our legitimate interests.
Lodge a complaint with a regulator
If you think that we have not complied with data protection laws, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. If you contact us we and tell us where you work, live or where the infringement took place we will try and locate for you the contact details for the appropriate authority..
CHANGES TO THIS POLICY
When you contact us please:
- Let us have enough information to identify you (your account number/previous travel itinerary).
- Let us have proof of your identity and address (send us correspondence from a previously associated email address for your, or perhaps a copy of your driving license or passport and a recent utility or credit card bill).
- Let us know the information to which your request relates.
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