Introduction
The Wild Insight Safari Company Privacy Notice
Welcome to The Wild Insight Safari Company privacy notice.
The Wild Insight Safari Company respects your privacy and is committed
to protecting your personal data. This privacy notice will inform you as to
how we look after your personal data when you visit our website
(regardless of where you visit it from) or when you otherwise provide
personal data to us via other means (such as over the telephone)
(regardless of where you provide it from) and tell you about your privacy
rights and how the law protects you.
Please also use refer to the Glossary that we have set out at the end of
the Policy if there is any terminology used in this privacy notice that you
are unfamiliar with or that you don’t fully understand.
Contents:
1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW YOUR PERSONAL DATA IS COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. HOW WE DISCLOSE YOUR PERSONAL DATA
6. WHEN WE TRANSER YOUR DATA OVERSEAS
7. HOW WE SECURE YOUR DATA
8. HOW LONG WE RETAIN YOUR DATA FOR
9. YOUR LEGAL RIGHTS
10. GLOSSARY
1. Important information and who we are
Purpose of this privacy notice
This privacy notice aims to give you information on how The Wild Insight
Safari Company collects and processes your personal data, including
any data you may provide through this website or via any other means
(such as over the telephone) when you purchase travel services, when
you sign up to our newsletter, when you request a brochure by post or
by email, when you take part in a competition etc.
This website is not intended for children and the only circumstances in
which we collect data relating to children, is where you make a booking
of travel services and you have children in your party.
It is important that you read this privacy notice together with any other
privacy notice or fair processing notice 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
The Wild Insight Safari Company LTD, trading as The Wild Insight Safari
Company, is the controller and responsible for your personal data
(collectively referred to as The Wild Insight Safari Company, "we", "us"
or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for
overseeing questions in relation to this privacy notice. If you have any
questions about this privacy notice, including any requests to exercise
your legal rights, please contact the data privacy manager using the
details set out below.
Contact details
Our full details are:
Full name of legal entity:
The Wild Insight Safari Company LTD
Name or title of data privacy manager: Stephen Mortimer
Email address:
[email protected]
Postal address:
High Farm Barn, 350 Fell Lane, Keighley, West
Yorkshire, BD22 6BZ
Telephone number: 07971688335
You have the right to make a complaint at any time to the Information
Commissioner's Office (ICO), the UK supervisory authority for data
protection issues (ico.org.uk). We would, however, appreciate the
chance to deal with your concerns before you approach the ICO so
please contact us in the first instance.
Changes to the privacy notice and your duty to inform us of
changes
This is the first version of this notice, created on 22 nd Feb 2019.
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.
2. The data we collect about you
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:
. (A) Identity Data
This includes data relating specifically to your
identity, such as your first name, maiden name, last name or
similar identifier, marital status, title, date of birth and gender.
. (B) Contact Data
This includes data relating to how you may be
contacted, such as your billing address, delivery address, email
address and telephone numbers.
. (C) Financial Data
This include data relating to your means and
methods of payment, such as your bank account and payment
card details.
. (D) 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.
. (E) 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 login 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.
. (F) Usage Data
This includes information about how you use our
website, products and services.
. (G) Marketing and Communications Data
This includes your
preferences in relation to whether or not you want to receive
marketing from us and our third parties and also your
communication preferences.
We may also collect, use and share Aggregated Data such as statistical
or demographic data for any purpose. 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
We collect the following special categories of personal data about you.
Details about your:
dietary requirements which may disclose your religious or
philosophical beliefs; and health.
We collect and process the above data only where it is necessary to do
so in order to deliver the travel service that you have purchased.
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. However, without your consent, we won’t be
able to make the necessary arrangements to provide the travel services
that you have booked or are attempting to book. As a result, if you do not
provide your consent, we will be unable to proceed with your booking.
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. However, as
this will prevent us from providing the travel service you have booked,
we will be required to treat any withdrawal of consent as a cancellation
of your booking and the cancellation policy in our Booking Terms and
Conditions will become payable.
If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a
contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are
trying to enter into with you.
In other words, where we require details from you in order to provide you
with your chosen travel services, if you do not provide us with the
necessary details then we will not be able to provide the services you
have booked or are attempting to book.
In this case, depending upon when you fail to provide the necessary
date, we may either not be able to process your booking or we may have
to cancel your booking, in which case we will treat this as a ‘cancellation
by you’ in accordance with our Booking Terms and Conditions. We will
notify you if we are unable to process a booking or are required to cancel
a booking for this reason.
3. How your personal data is collected
We may 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 travel services;
• subscribe to our newsletter or other publications;
• request our brochure be sent to you;
• request marketing to be sent to you;
• enter a competition, promotion or survey; or
• give us some feedback.
. (B) Automated technologies or interactions
As you interact with
our website, we may automatically collect Technical Data about
your equipment, browsing actions and patterns.
We collect this
personal data by using cookies, server logs and other similar
technologies. We may also receive Technical Data about you if you
visit other websites employing our cookies. Please see our cookie
policy for further details.
. (C) Third parties
We may receive personal data about you from
various third parties as set out below:
Technical Data from the following parties:
(i) analytics providers such as Google based outside the EU;
(ii) advertising networks such as Facebook based outside the EU;
and
(iii) search information providers such as Google and Bing based
outside the EU.
Contact, Financial and Transaction Data from providers of technical,
payment and delivery services such as Barclays based inside the EU.
Identity and Contact Data from data brokers or aggregators such as Tour
Radar based inside the EU.
4. How we use your personal data
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.
• 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.
Note that we may process your personal data
for more than one lawful ground depending on the specific purpose
for which we are using your data. Please contact us if you need
details about the specific legal ground we are relying on to process
your personal data where more than one ground has been set out
in the table below.
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, in
each case, you have not opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal
data with any company for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing messages
at any time by following the opt-out links on any marketing message sent
to you or by contacting us at any time.
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 travel services or other such transactions.
Cookies
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.
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.
If we need to use your personal data for an unrelated purpose, we will
notify you and we will explain the legal basis which 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.
5. Disclosures of your personal data
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 as set out in the Glossary.
. (B) External Third Parties as set out in the Glossary.
. (C) Specific third parties
. (D) 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.
6. International transfers
Many of our external third parties are based outside the European
Economic Area (EEA) so their processing of your personal data will
involve a transfer of data outside the EEA.
Where you have made a booking of travel services which are located or
otherwise due to be fulfilled outside the EEA, we are required and are
permitted to transfer your personal data to the supplier of the services
that you have purchased, outside the EEA in order to:
• Fulfil the contract we have with you; or
• Where we act as agent, to place you into a contract with the supplier
and so that the supplier can
fulfil the contract they have with you.
For all other transfers of data that are unrelated to the provision of
travel services to you, whenever your personal data is transferred
outside the EEA, we ensure a similar degree of protection is
afforded to it by ensuring at least one of the following safeguards is
implemented:
• We will only transfer your personal data to countries that have been
deemed to provide an adequate level of protection for personal
data by the European Commission. For further details, see
European Commission: Adequacy of the protection of personal
data in non-EU countries.
• Where we use certain service providers, we may use specific contracts
approved by the European Commission which give personal data
the same protection it has in Europe. For further details, see
European Commission: Model contracts for the transfer of personal
data to third countries.
• Where we use providers based in the US, we may transfer data to
them if they are part of the Privacy Shield which requires them to
provide similar protection to personal data shared between the
Europe and the US. For further details, see European Commission:
EU-US Privacy Shield.
Please contact us if you want further
information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your
personal data from being accidentally lost, used or accessed in an
unauthorized way, altered or disclosed. In addition, we limit access to
your personal data to 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.
8. Data retention
How long will you use my personal data for?
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.
Details of retention periods for different aspects of your personal data
are available in our retention policy which you can request from us by
contacting us.
In addition to the above, by law we have to keep basic information about
our customers (including Contact, Identity, Financial and Transaction
Data) for seven years after they cease being customers for tax
purposes.
In some circumstances you can ask us to delete your data: see Request
erasure below for further information.
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 which case we may use this information indefinitely without
further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws
in relation to your personal data. Please click on the links below to find
out more about these rights:
. (A) Request access to your personal data.
. (B) Request correction of your personal data.
. (C) Request erasure of your personal data.
. (D) Object to processing of your personal data.
. (E) Request restriction of processing your personal data.
. (F) Request transfer of your personal data.
. (G) Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us
at [email protected]
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.
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.
10. Glossary
LAWFUL BASIS
• Legitimate Interest
means the interest of our business in conducting
and managing our business to enable us to give you the best
service and the best and most secure experience. We make sure
we consider and balance any potential impact on you (both positive
and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data
for activities where our interests are overridden by the impact on
you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how
we assess our legitimate interests against any potential impact on
you in respect of specific activities by contacting us
• Performance of Contract
means processing your data where it is
necessary for the performance of a contract to which you are a
party or to take steps at your request before entering into such a
contract.
Comply with a legal or regulatory obligation
means processing
your personal data where it is necessary for compliance with a legal or
regulatory obligation that we are subject to.
THIRD PARTIES External Third Parties
i. Suppliers of travel services acting as processors based in countries
where we offer touring services who provide the travel services that
make up any booking of travel services that you make with us.
ii. Service providers acting as processors based in the UK and Australia
who provide IT and system administration services.
iii. Professional advisers acting as processors or joint controllers
including lawyers, bankers, auditors and insurers based in the UK
who provide consultancy, banking, legal, insurance and accounting
services.
iv. HM Revenue & Customs, regulators and other authorities acting as
processors or joint controllers based in the United Kingdom who require
reporting of processing activities in certain circumstances.
YOUR LEGAL RIGHTS
You have the right to:
• Request access
to your personal data (commonly known as a "data
subject access request"). This enables you to receive a copy of the
personal data we hold about you and to check that we are lawfully
processing it.
• Request correction
of the personal data that we hold about you. This
enables you to have any incomplete or inaccurate data we hold
about you corrected, though we may need to verify the accuracy of
the new data you provide to us.
• Request erasure
of your personal data. This enables you 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 (see below), 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.
• Object to processing
of your personal data where we are relying on
a legitimate interest (or those of a third party) and there is
something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object
where we are processing your personal data for direct marketing
purposes. In some cases, we may demonstrate that we have
compelling legitimate grounds to process your information which
override your rights and freedoms.
• Request restriction of processing
of your personal data. This
enables you to ask us to suspend the processing of your personal
data in the following scenarios:
(a) if you want us to establish the
data's accuracy;
(b) where our use of the data is unlawful but you
do not want us to erase it;
(c) where you need us to hold the data
even if we no longer require it as you need it to establish, exercise
or defend legal claims; or
(d) you have objected to our use of your
data but we need to verify whether we have overriding legitimate
grounds to use it.
• Request the transfer
of your personal data to you or to a third party.
We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable
format. Note that this right only applies to automated information
which you initially provided consent for us
to use or where we used the information to perform a contract with you.
Withdraw consent at any time
where we are relying on consent to process your personal data.
However, this will not affect the lawfulness of any processing carried out
before you withdraw your consent. If you withdraw your consent, we may
not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.