Data Protection Statement

 

Introduction

For purposes of this Statement:

“Applicable Laws” means local, foreign and international laws, regulations, treaties and codes, for example the Financial Intelligence Centre Act 38 of 2001, the National Credit Act 34 of 2005 and the Foreign Account Tax Compliance Act of the United States of America.

“Client” or “you” means any prospective, new or existing client of any Seagull Travel CC & Seagull Tours International CC Entity.

“Seagull Travel CC & Seagull Tours International CC ” or “we” means Seagull Travel CC & Seagull Tours International CC Southern African (PTY) Ltd and its direct and indirect subsidiaries.

This Statement sets out how your personal information will be used by Seagull Travel CC & Seagull Tours International CC and applies to any information, including personal and special personal information, you give to Seagull Travel CC & Seagull Tours International CC, or which Seagull Travel CC & Seagull Tours International CC may collect from third parties.

It is important that you read this Statement carefully before submitting any personal information to Seagull Travel CC & Seagull Tours International CC

The provisions of this Statement are subject to mandatory, unalterable provisions of Applicable Laws.

 

How to contact us        

If you have any comments or questions about this Statement please contact the Information Officer, Seagull Travel CC & Seagull Tours International CC,  The Travel Campus, 2nd floor,  26 Girton Road, Parktown, Johannesburg,  or you may send an email to dataprotection@harveyworld.co.za .

 

Amendment of this Statement  

We may amend this Statement from time to time for any of the following reasons:

  • To provide for the introduction of new systems, methods of operation, services, products, or facilities;
  • To reflect an actual or expected change in market conditions
  • To comply with changes to any legal or regulatory requirement;
  • To ensure that our Data Protection Statement is clearer and more favourable to you;
  • To rectify any mistake that might be discovered from time to time; and/or
  • For any other reason which Seagull Travel CC & Seagull Tours International CC, in its sole discretion, may deem reasonable or necessary.

Privacy and security      

Seagull Travel CC & Seagull Tours International CC takes your privacy and the protection of your personal information very seriously, and we will only use your personal information in accordance with this Statement and applicable data protection legislation. It is important that you take all necessary and appropriate steps to protect your personal information yourself (for example, by ensuring that all passwords and access codes are kept secure).

We have implemented reasonable technical and operational measures to keep your personal information secure.

 

Information which we may collect about you    

We may collect the following information about you:

  • This information may include your name, address, contact details, date of birth, identity number, passport number, visa information;loyalty number;  and dietary requirements.
  • Medical information as it pertains to conditions that impact your travel experience to be shared with service providers;
  • Information about your beneficial owner (if applicable);
  • Records of correspondence or enquiries from you or anyone acting on your behalf;
  • Details of transactions you carry out with us;

We may require you to provide additional personal information, in order for us to meet our legal or regulatory obligations.

Where you provide us with the personal information of third parties you should take steps to inform the third party that you need to disclose their details to us, identifying us. We will process their personal information in accordance with this Statement.

 

How we collect information      

You may provide personal information to us either directly or indirectly (through an agent acting on your behalf), by completing a booking for our products and services or requesting further information about our products and services, whether in writing via email, through our website, over the telephone or any other means.

We may also collect your personal information from your appointed agent, requestor or other third party that may hold such information.

 

Use of information collected     

We may use, transfer and disclose your personal information for the purposes of:

  • Providing you with the services, products or offerings you have requested, and notifying you about important changes to these services, products or offerings;
  • Complying with your instructions;
  • Assessing and dealing with complaints and requests;
  • Operational, marketing, auditing, legal and record keeping requirements;
  • Verifying your identity or the identify of your beneficial owner;
  • Complying with Applicable Laws, including lawful requests for information received from local or foreign law and government;
  • Conducting market research and providing you with information about Seagull Travel CC & Seagull Tours International CC products or services from time to time via email, telephone or other means (for example, events);
  • Ensuring that where you have unsubscribed from certain direct marketing communications, we do not send such direct marketing to you again;
  • Disclosing your personal information to third parties for reasons set out in this Statement or where it is not unlawful to do so;
  • Monitoring, keeping record of and having access to all forms of correspondence or communications received by or sent from Seagull Travel CC & Seagull Tours International CC or any of its employees, agents or contractors, including monitoring and recording telephone communications between you and Seagull Travel CC & Seagull Tours International CC to be used in the event of any dispute arising between you and Seagull Travel CC & Seagull Tours International CC; and
  • Improving or evaluating the effectiveness of Seagull Travel CC & Seagull Tours International CC business or products, services or offerings.

We may from time to time contact you about services, products and offerings available from Seagull Travel CC & Seagull Tours International CC which we believe may be of interest to you, by email, phone, text or other electronic means, unless you have unsubscribed from receiving such communications.

 

Disclosure of your information  

Your personal information will be shared with our travel product service providers, and selected third parties who process the information on our behalf, in order to fulfil your travel request.

We may also disclose your personal information to third parties in the following circumstances:

  • To any other third parties to –
    • assess and monitor any of your requests for Seagull Travel CC & Seagull Tours International CC products or services, including the risk involved to comply with Applicable Laws;
    • determine which products and services of these entities may be of interest to you and/or to send you information about such products and services, unless you object or choose not to receive such communications;
    • keep your usual contact within Seagull Travel CC & Seagull Tours International CC informed of the progress of any new bookings;
    • have a better understanding of your circumstances and needs to provide and improve Seagull Travel CC & Seagull Tours International CC products and services; and
  • To establishments who have received booking requests made by the Client in order for that institution to identify the Client;

We may transfer your information to our travel product service providers or a third party who carries on business in another country, including one which may not have data protection laws similar to those of the Republic. If this happens, we will ensure that anyone to whom we pass your information agrees to treat your information with the same level of protection as if we were dealing with it.

If you do not wish us to disclose this information to third parties, please contact us at the contact details set out above. We may, however, not be able to provide products or services to you if such disclosure is necessary.

 

Retention of your information  

We may retain your personal information indefinitely, unless you object, in which case we will only retain it if we are permitted or required to do so in terms of Applicable Laws. However, as a general rule, we will retain your information in accordance with retention periods set out in Applicable Laws, unless we need to retain it for longer for a lawful purpose. (For example, for the purposes of complaints handling, legal processes and proceedings.)

 

Access to, correction and deletion of your personal information            

You may request details of personal information which we hold about you under the Promotion of Access to Information Act 2 of 2000 (“PAIA”). Fees to obtain a copy or a description of personal information held about you are prescribed in terms of PAIA. Confirmation of whether or not we hold personal information about you may be requested free of charge.

You have a right in certain circumstances to request the destruction or deletion of and, where applicable, to obtain restriction on the processing of personal information held about you. If you wish to exercise this right, please contact us using the contact details set out above.

You have a right to object on reasonable grounds to the processing of your personal information where the processing is carried out in order to protect our legitimate interests or your legitimate interests, unless the law provides for such processing.

 

Complaints       

Should you believe that Seagull Travel CC & Seagull Tours International CC has utilised your personal information contrary to Applicable Laws, you undertake to first attempt to resolve any concerns with Seagull Travel CC & Seagull Tours International CC.

If you are not satisfied with such process, you may have the right to lodge a complaint with the Information Regulator, using the contact details listed below:

Tel: 012 406 4818

Fax: 086 500 3351

Email: inforeg@justice.gov.za

 

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