Individuals who choose to access, and subsequently use, the Website (“you” or “User[s]”) consent to the data practices described in this Policy as well as our Terms and Conditions (“Terms”). All definitions, capitalized terms and interpretations used in our Website’s Terms have been adopted in this Policy.
Upon accessing the Website, including any version of the Website that may be amended to geographically suit its Users, you will be asked to consent to being bound by this Policy and the Terms. Therefore, Users are advised to review this Policy and the Terms prior to use of the Website. If a User does not wish to consent to this Policy and/or the Terms, we reserve the right to refuse that User access to the Website.
We reserve the right to use any information relating to an individual who accesses the Website (“Personal Information”), for the purposes of statistical analysis and improvement of the Website. By using the Website, Users agree to the collection and use of their Personal Information in accordance with this Policy.
INFORMATION COLLECTION AND USE
- This Policy applies to the processing of Personal Information in connection with the Website utilized by current and/or prospective clients as advertised on the Website.
- We may collect Personal Information about you as may be deemed necessary to pursue our legitimate business interests (except where such interests are overridden by the interests, rights or freedoms of the data subject). We additionally use Personal Information and relevant data to:
- Make the Website available for use;
- Process any transactions that take place through the Website;
- Manage, develop and improve our Website;
- Perform our marketing and sales operations;
- Protect our employees, affiliates, customers and assets; and
- Ensure compliance with laws and regulations.
- You are responsible for ensuring the accuracy of any Personal Information that you submit to us. Inaccurate information may affect your experience when using the Website and our ability to contact you as described in this Policy.
- When providing Personal Information, collected through use of our Website, Users agree to the use, processing and storage of Personal Information in countries which may have data protection laws that differ from the laws in the User’s country.
- By accessing the Website, Users grant consent to our use of their Personal Information in line with this Policy. We will only use Personal Information that has been collected lawfully and all Personal Information shall be treated as confidential.
- We ensure that any Personal Information is processed in a way that values your privacy rights. You have the right to object to processing, pertinent to the data subject’s rights to restriction of, or objection to, processing of Personal Information.
- The Personal Information we collect may include, without limitation:
- Email addresses, active phone numbers, any search item that the User enters on the Website and any other content that the User might share with us while they use the Website;
- Technical information, including the internet protocol address used to connect the User’s computer or mobile phone to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and Website; and
- Non-personal identification (“Non-Personal Information”) about Users including, without limitation, technical information about the User’s means of connection to the Website, the date and time Users visit the Website, the specific pages Users visit on the Website and other similar information. We do not link Non-Personal Information with any personally identifiable information.
- Except as described in this Policy, we will not share your personal data with third parties without the consent of the data subject, unless for:
- Being in compliance with our duties and contractual obligations to our Users;
- Responding to duly authorised information requests from police and governmental authorities;
- Complying with law, regulation or court order;
- Enforcement and protection of our rights and properties;
- Protection of the rights or personal safety of our employees and third parties with respect to using our property when allowed, and in each case in compliance with applicable laws; and
- When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.
- From time-to-time and upon receiving consent from the User, we may also conduct online research surveys through e-mail invitations, pop-up surveys and online focus groups. When participating in a survey, we may ask you to enter Personal Information. The Personal Information you submit in a survey may be used by us for research and measurement purposes, as described below, including to measure the effectiveness of content, advertising or programs available on the Website. When our market research surveys collect Personal Information, we may not knowingly accept participants who are under the age of eighteen (18).
- Market research surveys conducted by or on behalf of the Company will contain a link to this Policy.
- We are committed to protecting the privacy of children. We do not collect Personal Information from any person whom we know for certain is below the age of eighteen (18) years of age (“Minor”). A parent or legal guardian is solely responsible for supervising the Minor’s use of the Website. The parent or legal guardian of the Minor assumes full responsibility for ensuring that the Personal Information is kept secure, and that the information submitted is accurate.
- The parent or the legal guardian also assumes full responsibility for the interpretation and use of any information or suggestions provided through the Website to the Minor.
- We keep track of the pages our Users visit within the Website. This data is used to deliver customized content within the Website to Users whose behaviour may indicate that they are interested in a particular subject area. The Website uses tracking pixels to collect information that help the Company provide the services to Users.
- Please note that any “do not track” signals sent by the User’s web browser or other mechanism have no effect on the collection of personally identifiable information by the Website. In addition, third parties who perform data analytics for the Website, may collect personally identifiable information on the User’s online activities while using the Website. Third-party affiliates of the Company may have different policies with respect to “do not track” signals and we make no representations with respect to such policies.
- We may also use third-party advertising companies, who may use some of your Personal Information (not your name, e-mail address, telephone numbers, booking history, or other confidential information), to display advertisements that may interest you.
- We adopt standard data collection, storage, processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of Users’ Personal Information, and data stored on our Website.
- In accordance with the European Union General Data Protection Regulation 2016/679 of 27 April 2016 (“GDPR”), the Company shall implement relevant data protection procedures in order to ensure compliance with the GPDR. Users of the Website residing in the European Union and/or within the applicable jurisdiction of the GDPR will be subject to the protection mechanisms prescribed thereunder.
- We do not sell, trade, or rent Users’ Personal Information to others. We may, however, share generic aggregated demographic information, not linked to any Personal Information with our business partners and trusted affiliates for the purposes outlined above in accordance with the aforementioned Clause 20.
- We endeavour to exercise our best efforts to keep your information secure. However, we cannot guarantee the safety of your Personal Information and therefore shall not be held liable in the event of a breach of security beyond our reasonable control.
- We encrypt the transmission of your Personal Information (including any personal information collected from various tools on our Website) or use secure socket layer connections technology to ensure security and confidentiality.
- We hold your Personal Information, as well as any other data collected hereunder, only as long as we have a valid legal reason to do so, which includes providing you with the services you have requested, maintaining the Website, meeting our legal and regulatory obligations, resolving disputes and enforcing our contractual, legal and moral obligations. The length of time for which we keep different types of Personal Information can vary, depending on why we originally obtained them, the reason we process them and the legal requirements that apply to them.
- When setting our data retention and deletion timescales we take into account a range of factors including applicable regulations and standards relating to taxation, payment processing and complaint handling, the need to prevent or detect crime or other misuse of our Services, and audit requirements. To fulfil our requirements, some of your personal data will need to be retained for a period of time after you cease to be a customer. When we no longer need it to fulfil the above requirements, we will delete it securely. Where we wish to retain any information for analysis purposes, we will first anonymise it so that it can no longer be linked back to an individual. Please note that if you opt out of receiving marketing from us, we will still need to keep your contact details in order to suppress them from future marketing activity.
- In the event of a corporate change in control resulting from, for example, a sale to, or merger with, another entity, or in the event of a sale of assets or a bankruptcy, we reserve the right to transfer your Personal Information to the new party in control or the party acquiring assets. In the event of such a change, your Personal Information will continue to be treated in accordance with this Policy unless any changes to the Policy are made in accordance with the Clause 6 below.
This Policy shall remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediate after being posted on this page. We reserve the right to update or change our Policy at any time and therefore, Users are encouraged to frequently visit these sections in order to be updated about changes or modifications. Your continued use of the Website after we post any modifications to the Policy will constitute your acknowledgement of the modifications and your consent to abide and be bound by the modified Policy.
By using the Website, Users signify their acceptance of this Policy. We reserve the right to alter, modify and/or amend any one of the provisions stated herein without prior notice to any User. Continued use of the Website following any alterations, modifications and/or amendments will be deemed as the Users’ acceptance of such changes. If you have any questions about this Policy, the practices of our Website, or our dealings with the Website, please contact us at via [email protected]
This document was last updated in March 2022.