Nairobi, Kenya

1. POLICY OVERVIEW

Scope of this policy

Afro Atlas Limited understands and respects the importance of your privacy and we are committed to safeguarding your personal information. In providing our service to you, we must collect personal information from you and this policy outlines how we treat your personal data after it has been collected by any of our channels which include our website, call centre, mobile app, and any future digital services or channels as they evolve.

This Privacy Policy concerns all the information that we collect, use and otherwise process about you as a customer, potential customer or just enquirer (for example as a direct booker, agent booker, site visitor, job applicants or otherwise).

Policy updates

We review our Privacy Policy regularly to make sure we’re being transparent about how we use your personal information. Any changes to our Privacy Policy will be reflected here on our website.

2. ABOUT US

We are Afro Atlas Limited, a company incorporated in Kenya and Somalia.

How to contact us

If you have any questions about this Privacy Policy or the ways in which we handle your personal information, please contact us as follows:

info@afro.travel

3. WHAT INFORMATION MIGHT WE COLLECT ABOUT YOU?

The type of information we collect about you depends on the nature of your interactions with us. Depending on the circumstances, we may collect some or all of the following:

• Details about you. Your name, email address, address, telephone number, date of birth, your hotel room preferences, loyalty membership details, frequent flyer membership details, payment details, your reasons for travel, meal and other travel preferences or dietary requirements and, if necessary, information about your health to the extent that it’s relevant to your fitness to fly, your holiday itinerary or to provide you with special assistance;
• Identification documents. If you are travelling on a route requiring Advance Passenger Information, your passport or identity card details including your passport number, the country in which your passport was issued and the expiry date;
• Details about the services you arrange with us. Your travel details, including details of your travel itinerary, where you are flying from and to, your booking information, any onward travel details if relevant (for example if you need our assistance for a connecting flight, if you’ve booked transportation or a tour with us), details of experiences or excursions booked through us, your baggage requirements, any upgrade information, your lounge visits, seat preferences, meal preferences or requirements, details of any special assistance you might need from us and any other information relevant to enable us to provide you with the travel or other services that you’ve arranged with us;
• Your interactions with us. Information about your interactions or conversations with us and our people, including when you make enquiries, comments, complaints or submit feedback to us (whether formally via email or simply verbally to our people);
• Job applications. If you apply for a job with us, your CV, work history, educational details and the role you’re applying for; and
• Your use of our systems and services. Details of the way in which you use our site, call centres and/or social media pages.

You are responsible for ensuring that other members of your party are aware of the content of this Policy and consent to your acting on their behalf in all your dealings with us.

4. HOW WE COLLECT INFORMATION ABOUT YOU

How we collect information about you will depend on how you interact with us and what services you arrange with us. Depending on the circumstances, we collect information in any of the following ways:

• When you browse our site;
• When you book or search for a holiday or other service (such as a flight, cruise, hotel lounge access, transportation or special assistance) via our site or our call centre;
• When you fill in part of the booking information on our site but do not complete the booking;
• When you apply for a job with us;
• When you contact us via our website, call centre, social media, post, email or instant messenger;
• When you request a brochure, sign up to receive email updates, participate in any of our competitions, promotions (for example via any social media channels, email or our site), surveys or market research;
• When you provide us with information about an accident, illness or incident that occurred in connection with your travel or holiday;
• If you make a complaint via a third party (such as an airline or hotel).

5. WHY DO WE NEED TO COLLECT YOUR SENSITIVE INFORMATION?

In certain circumstances, we will collect information that is deemed sensitive. This is most likely to include:

• Information about your health (for example if you ask us to provide you with special assistance during your holiday, or to determine your fitness to fly, or if you specify a meal preference that indicates a medical condition such as celiac disease); and/or
• Information about your religion (for example if you specify a meal preference that indicates a particular religion such as halal meal).

We seek to limit any sensitive personal data that we collect and, unless we have other specific lawful reasons to use this information (such as in an emergency situation), we will ask for your consent to collect it.

6. HOW WE USE YOUR INFORMATION

For what purposes do we use your information?

We’ll use your information for a variety of different purposes, some of which will depend on the services that you engage us for. This includes:

• To manage your booking with us. We will use your information to provide you with any services that you request or purchase from us. This may include booking your flight or hotel, arranging a tour, transportation or car hire, and issuing you with your tickets and providing you with any special assistance;
• To send you service and support communications. We will use your information to send you any communications relevant to the services you’ve requested or purchased from us. This includes sending you an email to notify you of changes to your itinerary, or providing you with a voucher, ticket or e-ticket. We will also provide you with customer service and support, deal with your enquiries, scheduling changes, complaints, comments or observations shared with us;
• To send you marketing communications. We will use your information to keep you up to date with the latest news, events, offers, sales, brochures, promotions and competitions that we think might be of interest or relevant to you;
• To provide assistance with online bookings. We collect your information when you fill in the required fields of our online booking forms but do not complete your booking or transaction in order to offer our assistance in case you are experiencing difficulties with our website;
• To personalise your customer experience. We use your information to provide you with a more personalised service.;
• To improve our customer service. To ensure that we carry out your instructions accurately, to help improve our service and in the interest of security, we may monitor and/or record: (1) your telephone calls; and (2) customer transactions and activities on our website. All recordings are and shall remain our sole property.
• To process your job applications. We will use your information to process any job applications that you submit to us, whether directly or via an agent or recruiter (speculatively or in response to any ad) ;
• To optimise our sites. If you use our sites, we may use your information to ensure that the content from our websites are presented in an effective manner for you and your device, to provide you with access to our site and app in a manner that is effective, convenient and optimal, and to provide you with content that is relevant to you, using site analytics and research and in certain circumstances combining that with other information we know about you;
• To ensure security and protect our business interests. In certain circumstances, we use your information to ensure the security of our services, buildings, and people, including to protect against, investigate and deter fraud, unauthorised or illegal activities, systems testing, maintenance and development;
• To conduct research. We may use your information to carry out anonymised research about general engagement with our services and systems, or if you choose to participate in customer surveys, consumer focus groups and research; and
• To comply with our legal obligations. In certain circumstances, we will need to use your information to comply with our legal obligations, for example to comply with any court orders.

On what grounds will we process your information?

We will use your information for the purposes listed above, either:

• For the performance of your contract with us and the provision of our services to you;
• To comply with a legal obligation we have;
• For our legitimate interests (we explain what we mean by this below);
• To protect your vital interests;
• With your consent;
• For establishing, exercising or defending legal claims; and
• For reasons of substantial public interest.

What do we mean by “legitimate interests”?

As outlined above, in certain circumstances we may use your personal information to pursue legitimate interests of our own or those of third parties, but this is provided your interests and fundamental rights do not override those interests. By “legitimate interests” we mean our interests in conducting and managing our business activities and to ensure that we are guaranteeing the best service and experience for you and our customers. This involves:

• Using your information to protect you against fraud when you transact on our site, and to ensure that our systems and sites are secure;
• Determining the effectiveness of our site / tools / services and improving the security and optimisation of our network, sites and services;
• Confirming information that you provide to us in a CV or application, by reference to past employers and/or publicly available employment or business profiles;
• Personalising, enhancing, modifying or otherwise improving the services and/or communications that we provide to you, such as sending you marketing and serving you with advertising that is relevant and likely to be of interest to you; and/or
• Detecting, monitoring and preventing fraud or other unlawful acts, and operating a safe and lawful business.

Where we use your information for our legitimate interests, we make sure that we take into account any potential impact that such use may have on you. Our legitimate interests don’t automatically override yours, and we won’t use your information if we believe your interests should override ours unless we have other grounds to do so (such as when we have your consent, or we have a legal obligation to use your information in that way). You may have the right to object to our using your information for our legitimate interests. However, please keep in mind that your objection to this sort of processing may affect our ability to carry out the tasks that we have set out above.

7. REASONS FOR SHARING YOUR INFORMATION

In connection with the purposes described above, we share your personal information with the following third parties:

• Third party suppliers that we work with to provide your booking and our other services to you. We may share your information with third party suppliers including other Afro Atlas companies that provide us with services in connection the provision of our services to you. This includes for example: airlines, hotels, tour operators, transport companies, excursion providers, airport authorities, insurance companies, car hire companies, ground handling agencies, etc;
• Other third party suppliers that we work with in connection with our business. We share your information with third party suppliers that provide us with services in connection with our business and the provision of our services to you. This includes for example: marketing agencies and/or companies that run our marketing campaigns, IT developers, service providers and hosting providers, third parties that manage promotions or competitions that we may run, third party software companies that provide us with applications on a white label basis, advertising providers and networks, ground agents, site analytics providers, medical service providers and credit card screening companies;
• Airports, immigration / border control and/or other government authorities. Some destinations require airlines, cruise lines and tour operators to provide “Advance Passenger Information” about you to the border/immigration authorities of the country of your travel destination. Advance Passenger Information comprises the basic information contained in your passport that you would be required to present on your arrival. In addition, laws in certain destinations such as the USA and other countries require airlines to provide certain additional advance information about you and your travel arrangements. We will provide this information where we are required to do so.
• Third parties for marketing. We share your information with any selected third party that you consent to our sharing your information with for marketing purposes;
• Courts or advisors. We share your information with other third parties (including legal, accountants or other advisors, regulatory authorities, courts and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law; and
• Third parties which are successors of the business. Your information may be disclosed to any successors of our business, in the event of a re-organisation, merger or sale, for them to use for the purposes as set out in this Privacy Policy.

Where we do share your information with third parties, we will require them to maintain appropriate security to protect your information from unauthorised access or processing, unless we have no ability to do so (for example, where we are sharing information with border agencies or enforcement authorities).

8. MARKETING

When you’ll hear from us

We will keep you up to date with our latest destinations, offers, partnerships, sales, promotions, competitions (or those of other members of the Afro Atlas Group) that we think might be of interest / relevant to you if you have indicated that you are happy to receive marketing communications from us – that is, if you have:

• Purchased services such as a ticket, accommodation, or any other service from us and have not told us that you don’t want to hear from us; or
• Signed up to receive marketing communications from us and have not later told us that you don’t want to hear from us.

Opting out of or withdrawing your consent in relation to marketing

If you no longer want to hear from us, you can opt out or unsubscribe by:

• Following the “unsubscribe” link contained in any marketing communications that you receive from us;
• By Email to: info@afro.travel

Third parties and marketing

We might rely on third parties to help us manage our marketing communications, but we won’t share your information with any third parties for their marketing purposes unless you agree to our doing so.

9. YOUR RIGHTS

Overview of your rights

You have certain rights in respect of the personal information that we hold about you, including:

The right to be informed of the ways in which we use your information, as we have outlined in this Privacy Policy;

The right to ask us not to process your information for marketing purposes;

The right to request access to the information that we hold about you;

The right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;

In certain circumstances, the right to ask us to stop using information about you; and

Please note that we reserve the right to retain certain information for our own record-keeping (for example, to ensure that you do not receive marketing communications that you have opted-out of receiving) and to defend ourselves against any claims. We may also need to send you service-related communications relating to the services that we provide to you even when you have requested not to receive marketing communications.

Your rights under the GDPR

From 25 May 2018, you have certain additional rights in respect of the information that we hold about you, including:

• The right to withdraw consent that you have provided to us to use your personal information;
• The right to object to our using your information on the basis of our legitimate interests (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; and
• The right to receive a copy of any information we hold about you (or request that we transfer this information to another service provider) in a structured, commonly-used, machine-readable format, in certain circumstances; and
• The right to ask us to limit or cease processing or erase information we hold about you in certain circumstances.

How to exercise your rights

• Contacting us. You can exercise your rights by contacting us or by checking the applicable boxes on forms that we use to collect your information, or to tell us that you don’t want to participate in marketing.
• Updating your own details. Alternatively, if you’d prefer not to contact us, you may be able to do it yourself depending on the nature of your request. For example:

- You can update the details we hold about you by logging into your booking via the “Manage your booking” tab on our site and following the instructions to edit your details, or contact us to change details of your booking; and

- If you wish to remove your information from our marketing circulation lists, which include receiving marketing emails, you can unsubscribe by scrolling to the bottom of the email and clicking the ‘unsubscribe’ link.

We will comply with your requests unless we have a lawful reason not to do so. Please be aware that we may need you to provide additional information (such as to confirm your identity and/or to confirm what information you wish to access) in order to process your request.

10. OPERATING WORLDWIDE

Our service providers and suppliers

We are based in Horn of Africa. However, in certain circumstances information that we collect about you will be sent to and held by us in countries where we work with suppliers and service providers that are based in different countries. We will take all steps necessary to ensure that it is adequately protected and used in accordance with this Privacy Policy, including but not limited to relying on any appropriate cross-border transfer solutions.

Destination authorities

As we outline above, in certain circumstances, we are required to share information about you with immigration or other government authorities before we can deliver you to your destination.

12. SAFEGUARDING YOUR INFORMATION

Our security measures

We take security very seriously and we are committed to safeguarding your personal information. We take a number of administrative and technical steps to ensure the security of the information you provide to us.

For example we:

• Ensure the physical security of our offices and other sites;
• Ensure the physical and digital security of our equipment, devices and systems by mandating appropriate password protection, encryption and access restrictions;
• Ensure appropriate access controls so that access to your information is only granted to those of our people that need to use it in the course of their work;
• Maintain internal policies and deliver data protection and confidentiality training to make sure our people also understand their responsibilities in looking after your information and commit to taking appropriate measures to enforce these responsibilities.

How you can help ensure the security of your information

You can also play a part in helping to keep your information safe. Here are a few useful starting points:

• Choose strong passwords and change them regularly;
• Keep your booking references and passwords confidential, and avoid sharing them with anyone else or using your password for multiple accounts
• Log out after each session if you are using a shared computer;
• Inform us immediately if you know or suspect that your password or booking reference has been compromised or if someone may have accessed your account;
• Keep your devices protected by ensuring that you’re using the latest version of your operating system and have suitable anti-virus software, if applicable; and
• Be alert to any potentially fraudulent emails.

Links to other sites and resources

Please note that our website contains certain literature and hyperlinks to websites owned by third parties. This privacy statement covers websites owned and controlled by us only. Links to other websites and any information collected by these sites are not covered by this privacy statement. Be sure to consult the Terms of Use and Privacy Policy of the relevant third party site to understand how that site collects and uses your information and to establish whether and for what purposes they use cookies.

13. DATA RETENTION

We keep your information for as long as is reasonably necessary to enable us to provide you with the services that you have requested from us, to comply with any legal obligations that require us to keep information, or for as long as we reasonably require for our legitimate interests, including for example for the purposes of exercising our legal rights or defending ourselves against claims.

As part of our ongoing data retention policy we look to find ways to reduce the amount of information we hold and the length of time that we need to keep it. For example:

• We try to adopt a paperless approach wherever possible and securely destroy any paper correspondence we receive on a regular basis;
• We keep a list of individuals who no longer wish to be contacted by us indefinitely. We need to keep this information to comply with their wishes not to contact them;
• We may retain any unsuccessful CV’s or job applications that we receive for a period of up to 6 months in case you might be suited to another opportunity that becomes available in the near future.

Afro Atlas Privacy Policy

April 2020