Privacy Policy

We collect the following type of Personal information:

• names;
• addresses;
• email addresses;
• telephone numbers;
• date of birth;
• identity numbers;
• payment information (e.g. credit card/debit card/account numbers etc.);
• IP addresses and usage data regarding the use of our Websites and applications by visitors to our Websites;
• correspondence between us;
• other information necessary for making personal travel arrangements. In addition, we may also be required to obtain your passport details to pass to overseas authorities which require Advanced Passenger Information.

Information collected from our Website
When you visit our Websites, our servers automatically record information that your browser sends to our servers. This data may include information such as your device’s IP address, browser type and version, operating system type and version, language preferences or the webpage you were visiting before you came to our Website, pages of our Website that you visit, the time spent on those pages, information you search for on our Website, access times and dates, and other statistics.

Cookies
A “cookie” is a small computer file which is downloaded to your device. It collects information as to how you navigate our Website and the internet and helps us provide better Website Services to you.

Cookies may collect Personal Information about you. Cookies help us remember information about your visit to our Website, like the last webpage that you visited before our Website, and other settings and searches.

Cookies enable us to understand who has seen which webpages 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 make your next visit easier and customise 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 the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. To learn more about cookies and how to manage them, visit internetcookies.org.

In addition to using cookies and related technologies as described above, we also may permit certain third-party companies to help us tailor advertising that we think may be of interest to users and to collect and use other data about user activities on the Website. These companies may deliver ads that might also place cookies and otherwise track user behavior.

Do Not Track Signals
Some browsers incorporate a Do Not Track feature that signals to Websites you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a Website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time. How browsers communicate the Do Not Track signal is not yet uniform. As a result, this Website is not yet set up to interpret or respond to Do Not Track signals communicated by your browser. Even so, as described in more detail throughout this Policy, we limit our use and collection of your Personal Information.

We use your Personal Information to:

• fulfil 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 minimised), this includes when you book a holiday package, hotel, car or other service which may be provided by us or third parties with us;
• process payments for your booking, fulfill requests for refunds and for accounting or audit purposes;
• personalise 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;
• 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 Information from you relating to your thoughts/comments about your experience with us;
• market our products and Services to you;
• if you have any queries about any of our products or Services, compliments or complaints, we will need to collect information from you, including your contact details, in order for us to respond to your query or provide you with assistance.  We will collect this information when you, send us an email, call our customer service centre, visit a local office or contact us via another form of communication such as through social media or an online chat tool;
• manage our business such as for systems testing, IT maintenance or development training, bench-marking and performance measurement; and
• use in connection with your online account as you may authorise or consent to additionally from time to time.

We do not generally collect sensitive Personal Information from you (or those you are booking for), but where we do, we seek to minimise the collection and use of it and handle it with extra care. In some cases, we may also need to collect more sensitive Personal Information such as information concerning medical conditions, disabilities and special requirements such as dietary requests which may disclose your religious beliefs, so as to be able to consider your particular needs in relation to a booking.

Where you (or any passenger travelling) provides us with special categories of Personal Information 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.

We process your Personal Information so that we can meet our legal, compliance and regulatory obligations 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 Information 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.  If you visit one of our local offices, you may be monitored by closed circuit television for security purposes.  In each case, we do so in compliance with applicable laws.

We collect Personal Information from third parties who you have authorised to provide your Personal Information 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, or our promotion partners).  We also collect Personal Information 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.

We collect Personal Information about your children for the purposes of making a booking or use of our Services. A child is a person under the age of 18.  We will only process this information for the purpose of providing our Services and will only do so with the consent of a competent person.  If you are under the age of 18, please do not submit any Personal Information through our Website or Service. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through our Website or Service without their permission. If you have reason to believe that a child under the age of 18 has provided Personal Information to us through our Website or Service, please contact us. You must also be old enough to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf).

We will only collect, process, use, share and store your Personal Information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• we need to use your Personal Information to perform a contract or take steps to enter into a contract with you.  For example, to manage your booking with us, to take payment for your booking, or to complete your travel arrangements;
• we need to use your Personal Information for our legitimate interest as a commercial organisation. For example, we may record calls to our customer service centre 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 Information to comply with a relevant legal or regulatory obligation that we have.  For example, in some countries, we are required to provide Advanced Passenger Information to border control, customs and law enforcement officers at ports of entry and exit on your itinerary; and
• we have your consent to using your Personal Information for a particular activity.  For example, where you consent to us sharing with special offers which we think may be of interest to you.

Affiliates
We may disclose information about you to our affiliates for the purpose of being able to offer you related or additional products and Services. Any information relating to you that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Policy.

We also share this information with third party service providers (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. We share your Personal Information in the manner and for the purposes described below:

• to improve the products and Services we offer or help us to create new ones and for marketing, profiling and analytics as detailed below, and for the purposes described in this Policy.
• with third parties who help us manage our business and deliver our products and Services. These third parties have agreed to confidentiality obligations and use any Personal Information we share with them or which they collect on our behalf solely for the purposes of providing the contracted service to us.  These third parties include service providers who help manage our IT and back-office systems, detect fraudulent transactions and security incidents, provide customer service centre support, manage communications and tailor marketing and advertising;
• verify payments such as banks and payment card companies;
• provide internet services;
• host our facilities and conduct research that assists us with understanding consumer interests.
• with third party advertising and social media websites to provide advertising;
• bank and payment providers to authorise and complete payments;
• with governments, government organisations and agencies, border control agencies, regulators, law enforcement and others as permitted or required by law, in relation to Advanced Passenger Information or such other legal requirements as 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;
• to assist us in processing your payment information securely. Such third-party processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies;
• with third parties whose products or Services you are purchasing through our Website or offices, or otherwise such as airlines, tourism agencies, hotel, transfer and car hire companies, tour and excursion providers or to travel agents, including if there is a problem with your booking so that your travel agent can resolve it with you.

How we use Personal Information to keep you up to date with our products and Services
We may use Personal Information 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 Information in your social media account to 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.

How you can manage your marketing preferences
To protect your privacy and to ensure you have control over how we manage marketing with you and provided that you have indicated that you would like to receive it:

• we will take steps to limit direct marketing to a reasonable level;
• only send you communications which we believe may be of interest or relevance to you and at all times in line with your permissions, which, as appropriate, may include:
  • telling you about developments in the products and Services available through us and those of our carefully selected partners (provided that we will communicate these to you in conjunction with our own marketing);
• allowing third parties to send you marketing or updates relating to their products or services;
• you can click the “unsubscribe” link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us or changing your account settings which will remove you from the relevant marketing list; and
• if you do not want to be served with our advertisements within social media or other digital website, you can manage your preferences within these websites.

If you unsubscribe completely from our marketing communications, we may be unable to notify you of tailored offers to meet your needs. If you do unsubscribe from marketing communications, you will still receive operational and service messages from us regarding your booking including where you may not have completed a booking (such as abandoned cart emails or pop-up notices), and responses to your enquiries made to us.

Analytics
We aggregate Personal Information and remove any identifying elements in order to analyse patterns and improve our marketing and promotional efforts, to analyse Website use, to improve our content and products and Services, to customise 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 webpage you just came from,
• which webpage you next go to,
• what browser you are using, your device ID and your IP address.

This collective data helps us to determine how much our customers use parts of our Website, and do research on our users’ demographics, interests, and behaviour to better understand and serve you. One of the ways we do this is by installing and using Cookies on your browser or device.

If you use buttons on our Website linked to social media or similar sites (for example, “Like” and/or “Share” buttons), content from our Website may be sent back to those sites and, depending on your privacy settings, may be privately or publicly visible (for example, to friends, followers or generally to anyone who has access to your profile page).

Personalisation of our offerings
We use Personal Information 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 behaviours to personalise our offerings for you.  This includes:

• 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 personalise the Service and offers you receive from us, including with invitations to special events;
• to provide you with tailored content online and optimise your experience of our Website;
• to provide you with tailored advertisements on other website you visit and social media and digital 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; and
• to authenticate logins on our Website and detect and prevent fraud.

We sell travel arrangements to people and companies around the world, which means your Personal Information may be transferred and stored in other countries which may be outside your country of residence.  Some of these countries are subject to different standards of data protection than your country of residence.

We will take appropriate steps to ensure that transfers of Personal Information are in accordance with applicable law, and we only transfer Personal Information to another country where:

• a European Commission adequacy decision has been granted; and
• we have put in place appropriate safeguards in respect of the transfer, for example we have entered into EU standard contractual clauses and required additional safeguards with the recipient, or the recipient is a party to binding corporate rules approved by an EU or UK supervisory authority.

To this end:

• where we transfer your Personal Information outside our company or to third parties (who help us to provide our products and Services), we obtain contractual commitments from them to protect your Personal Information; or
• where we receive requests for information from law enforcement or regulators, we carefully review and validate these requests before any Personal Information is disclosed.

In the event your Personal Information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction, and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.

You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your Personal Information when this is transferred as mentioned above.

Protection of your Personal Information
We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the Personal Information 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 anonymising Personal Information if it is no longer needed for the purposes for which it was collected;
• following security procedures in the storage and disclosure of your Personal Information to prevent unauthorised 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 industry standard encryption.

Information Security
We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorised access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that:

• there are security and privacy limitations of the Internet which are beyond our control;
• the security, integrity, and privacy of any and all information and data exchanged between you and our Website cannot be guaranteed; and
• any such information and data may be viewed or tampered with in transit by a third-party, despite best efforts.

Data Breach
In the event we become aware that the security of the Website has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will notify affected individuals. When we do, we will post a notice on the Website.

Storage of your Personal Information
We keep your Personal Information for as long as is reasonably necessary for the purposes for which it was collected. For example, to manage bookings and provide you with any relevant products or Services, as explained in this Policy.

We will ensure that it is disposed of in a secure manner. In most cases we will destroy your data after the applicable legal data retention periods have expired.

In some circumstances we may store your Personal Information 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 Information 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 Information or dealings.

You have certain rights in relation to your Personal Information.

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 Information to you.

You can exercise your rights by emailing us at marketing@seoloafrica.com, or by sending us a communication at Little Swift, Portion 41, Remhoogte, Skeerpoort 0232, North West. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request within 30 days or inform you if we require further information in order to fulfill your request.

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.

Right to access Personal Information
You have a right to request that we provide you with a copy of your Personal Information that we hold and you have the right to be informed of:

• the source of your Personal Information;
• the purposes, legal basis and methods of processing;
• the data controller’s identity; and
• the businesses or categories of businesses to whom your Personal Information may be transferred.

Right to rectify or erase Personal Information
You have the right to request that we rectify inaccurate Personal Information. We may seek to verify the accuracy of the Personal Information before rectifying it. You can also request that we erase your Personal Information 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; or
• the Personal Information must be erased for compliance with a legal obligation to which we are subject.

In some instances, we cannot comply with your request to erase Personal Information if the processing of your Personal Information is necessary:

• for compliance with a legal obligation; or
• for the establishment, exercise or defense of legal claims

Right to object to the processing (including direct marketing) of your Personal Information
You can object to any processing of your Personal Information which has our legitimate interests as its legal basis.

You can request that we stop contacting you for marketing purposes.

You can request that we not transfer your Personal Information to unaffiliated third parties for the purposes of direct marketing or any other purposes.

If you have joined our mailing list, you can manage your marketing preferences automatically by clicking the “unsubscribe” link that you will find at the bottom of our emails which you receive from us, or you can unsubscribe by contacting us at the email address provided above.

Right to obtain a copy of Personal Information safeguards used for transfers outside your jurisdiction
You can ask to obtain a copy of, or reference to, the safeguards under which your Personal Information is transferred outside to.

We may redact data transfer agreements to protect commercial terms.

You can ask us to restrict your Personal Information, but only where:

• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your Personal Information following a request for restriction, where:

• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

You have a right to lodge a complaint with the relevant supervisory authority if you have concerns about how we are processing your Personal Information.  In South Africa, you may lodge a complaint with the Information Regulator:

Website:  www.inforegulator.org.za
Email: popiacomplaints@inforegulator.org.za
Address: JD House, 27 Stiemens Street, Braamfontein, Johannesburg, 2001
Postal: P O Box 31533, Braamfontein, Johannesburg, 2017.

We would, however, appreciate the chance to deal with concerns before you approach the regulatory bodies above, so please contact us in the first instance.

If you have any concerns regarding data that we hold, please contact our Information Officer, Ms J Kingsley, or our Deputy Information Officer, Ms J Shirley:

Telephone: +27 11 467 1886
Email Address: info@seoloafrica.com
Website: www.seoloafrica.com