Privacy Policy

1. Introduction

1.1 Embassy Travel is committed to safeguarding the privacy of our website visitors and customers.

1.2 This policy applies where we are acting as a data controller (responsible party) with respect to the personal data of our website users and travel customers, in other words, where we collect personal data of any kind.

1.3 Embassy Travel uses cookies on this website. Where those cookies are not strictly necessary for the provision of our website, we will ask you to consent to the use of cookies when you first visit our website.

1.4 In this policy, “we”, “us” and “our” refer to Embassy Travel, part of the Singer Group of Companies, and any of its subsidiaries.

1.5 As a general rule we will only process your personal information if this is required to deliver or offer a service or carry out a transaction. We may update this Privacy Policy from time to time if the law or our business practices require it — the version displayed on our website will apply to your interactions with us.

2. What is personal information?

Personal information refers to any information that identifies you or specifically relates to you. Personal information includes, but is not limited to, the following information about you:

• your marital status;
• your national origin;
• your age;
• your language; birth place; education;
• your financial history (like your income, third party payments made on your behalf and the like);
• your identifying number (like an employee number, identity number or passport number);
• your e-mail address; physical address; telephone number;
• your biometric information (like fingerprints, your signature or voice);
• your race; gender; sex; pregnancy status; ethnic origin; social origin; colour; sexual orientation;
• your physical health; mental health; well-being; disability; religion; belief; conscience; culture;
• your medical history; criminal history; employment history;
• your personal views, preferences and opinions;
• your confidential correspondence;
• another’s views or opinions about you.

Personal information includes special personal information, as explained in Section 4 below.

3. How we use your personal data

3.1 In this Section we have set out:

• (a) the categories of personal data that we may process
• (b) the purposes for which we may process your personal data
• (c) the legal bases of the data processing

3.2 We may process data about your use of our website www.embassytravel.co.za and services (usage data). This usage data may include the following: your IP address, your geographical location, browser type and version, operating system, length of website visit, referral source, page views and website navigation, as well as information about timing, frequency and the pattern of your service use. The source of the usage data is our website analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is so that we may monitor and improve the user experience of our website and our services.

3.3 We may process your (booking data) which may include your name and email address. The source of this booking data is you (upon booking a service with us). This data may be processed for communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.4 We may process your personal information included in your booking on our website (“profile data”). The profile data may include the following: your name, address, telephone number, email address, gender, date of birth. The profile data will be processed for the purposes of providing you with the best possible experience when using our service. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.

3.5 We may process information contained in any enquiry or email you submit to us regarding our services (“enquiry data”). The enquiry data may be processed for the purposes of modifying our website information to ensure better user experience and clearer information. The legal basis for this processing is to improve user experience.

3.6 We may process information relating to transactions, including purchases of our services and payments made through our website (“transaction data”). This transaction data may include the following: your contact details, your card details and the details of the transaction itself. The transaction data may be processed for the purpose of fulfilling your booked travel services and keeping proper transaction records. The legal basis for this processing is the deliverance of services and proper administration of our website and business.

3.7 We may process information that you provide to us for the purpose of subscribing to our email updates and/or newsletter (“notification data”). The notification data may be processed for the purposes of sending you the relevant updates regarding your booking and/or newsletters (if subscribed). The legal basis for this processing is consent.

3.8 We may process information relating to any communication that you send to us via our website or directly via email (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. (When using the website contact forms, our website will generate the metadata associated with any communications made.) The correspondence data may be processed for the purposes of communicating with you and accurate record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with customers/subscribers.

3.9 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of any legal claims against Embassy Travel or its partners, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, specifically the protection and assertion of our legal rights, your legal rights and the legal rights of all others involved.

3.10 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance, managing associated risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, specifically the proper protection of our business (and our customers) against risks.

3.11 In addition to the above specific purposes for which we may process your personal data set out in this Section 3, we may also process your personal data where it is necessary for compliance with a legal obligation to which we are subject, or in order to protect yours or other customers’ vital interests.

3.12 Embassy Travel asks that you do not supply any other person’s personal data to us, unless we prompt you to do so (for example when booking travel on behalf of another traveller).

4. Special personal information

4.1 Special personal information is personal information about your race, ethnic origin, trade union membership, health, biometric information, or criminal behaviour and any alleged commission of an offence.

4.2 We may process your special personal information only where:

• you have consented to the processing;
• the information is being used for any human resource or payroll requirement;
• the processing is needed to create, use or protect a right or obligation in law;
• the processing is for statistical or research purposes and all legal conditions are met;
• the special personal information was made public by you;
• the processing is required by law; or
• health information is processed, and the processing is to determine your insurance risk, or to comply with or enforce an insurance policy (for example, in relation to travel insurance).

5. Marketing communications

5.1 We will use your personal information to market our products and services to you. We will do this in person, by post, telephone, or electronic communication such as SMS, email and fax.

5.2 If you are not our customer, or in any other instances where the law requires, we will only market to you by electronic communication with your consent.

5.3 In all cases you can request us to stop sending marketing communications to you at any time.

6. Providing your personal data to others

6.1 We may disclose your personal data to our insurers and/or professional advisers where it is deemed reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing associated risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.

6.2 We may disclose your booking data to third party travel suppliers — such as airlines, hotels, tour operators, car hire companies and other subcontractors — insofar as reasonably necessary for the delivery of a service being provided by Embassy Travel.

6.3 Financial transactions relating to your booking through our website are almost always handled by our nominated payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your deposits, and payments, refunding payments and for dealing with complaints or queries relating to payments and refunds.

6.4 We may also disclose your personal data to:

• other members of the Singer Group of Companies or appointed third parties (like its authorised agents, partners, contractors and suppliers) for any of the purposes identified in this Privacy Policy;
• our employees, as required by their employment conditions;
• attorneys, tracing agents, debt collectors and other persons that assist with the enforcement of agreements;
• law enforcement and fraud prevention agencies and other persons tasked with the prevention and prosecution of crime;
• regulatory authorities, industry ombudsmen, governmental departments, local and international tax authorities and other persons the law requires us to share your personal information with;
• trustees, executors or curators appointed by a court of law or legal authority;
• courts of law or tribunals that require the personal information to adjudicate referrals, actions or applications; and
• participating partners in any customer loyalty programme, where relevant to your participation.

6.5 In addition to the specific disclosures of personal data mentioned in this Section 6, we may disclose your personal data where it is necessary for compliance with a legal obligation to which we are subject, or in order to protect yours or any other parties’ vital interests. We may also disclose your personal data where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out of court procedure.

7. International transfers of your personal data

7.1 We will only transfer your personal information to third parties in another country in any one or more of the following circumstances:

• where the transfer is necessary to enter into or perform under a contract with you, or a contract with a third party that is in your interest (such as booking accommodation or transport abroad);
• where you have consented to the transfer;
• where it is not reasonably practical to obtain your consent, and the transfer is in your interest; or
• where your personal information will be adequately protected under the other country’s laws or an agreement with the third party recipient.

7.2 This transfer will take place within the requirements and safeguards of the law. Where possible, the party processing your personal information in the other country will agree to apply the same level of protection as available by law in South Africa, or if the other country’s laws provide better protection, those laws would be agreed to and applied.

8. Retaining and deleting personal data

8.1 This Section 8 sets out our data retention policies and procedure, which are designed to help ensure that we comply with legal obligations in relation to the retention and deletion of your personal data.

8.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that particular purpose or those purposes.

8.3 We will retain your personal data as follows:
8.3.1 Booking and travel data shall be retained at least until the end of your booked trip and for a further period thereafter as needed to meet our legal, tax, accounting and reporting obligations.

8.4 We will otherwise retain your personal information for as long as:

• the law requires us to keep it;
• a contract between you and us requires us to keep it;
• you have consented for us to keep it;
• we require it to achieve the purposes listed in this Privacy Policy;
• we require it for statistical or research purposes;
• a code of conduct requires us to keep it; or
• we require it for our lawful business purposes.

8.5 Notwithstanding the other provisions of this Section 8, we may retain your data where such retention is necessary to comply with a legal obligation to which we are subject, or in order to protect yours or another party’s vital interests.

9. How we secure your personal information

9.1 We will take appropriate and reasonable technical and organisational steps to protect your personal information according to industry best practice. Our security measures (including physical, technological and procedural safeguards) will be appropriate and reasonable. This includes the following:

• keeping our systems secure (like monitoring access and usage);
• storing our records securely;
• controlling access to our buildings, systems and/or records;
• safely destroying or deleting records; and
• working towards compliance with recognised international security standards.

10. Amendments

10.1 We may update this policy from time to time by publishing a new version on our website.

10.2 You should check this page occasionally to ensure you are happy with any changes to this policy.

10.3 We may notify you of changes to this policy by email.

11. Your rights

11.1 In this Section 11, we have summarised your rights under data protection law. Some of the rights are complex, and not all the details have been included in our summary. You should therefore read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

11.2 Your principal rights under data protection law are:

• (a) the right to access;
• (b) the right to rectification;
• (c) the right to erasure;
• (d) the right to restrict processing;
• (e) the right to object to processing;
• (f) the right to data portability;
• (g) the right to complain to a supervisory authority; and
• (h) the right to withdraw consent.

11.3 You have the right to confirmation as to whether we process your personal data and, where we do, access to this personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. To obtain a copy of your personal data simply email us at reservations@embassytravel.co.za and we will begin the process of supplying this data to you.

11.4 You have the right to have any inaccurate personal data about you rectified and, considering the purposes of the processing, to have any incomplete personal data about you completed.

11.5 In some circumstances you have the right to the erasure of your personal data. Those circumstances include: the personal data is no longer necessary for the purposes of which it was collected or otherwise processed, you withdraw consent to consent-based processing, you object to the processing under certain rules of applicable data protection law, the processing is for direct marketing purposes; and the personal data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information, for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

11.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances include: you contest the accuracy of the personal data, processing is unlawful but you oppose erasure, we no longer need the personal data for the purposes of our processing but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another natural or legal person; or for reasons of important public interest.

11.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

11.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose immediately.

11.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

11.10 To the extent that the legal basis for our processing of your personal data is:

• (a) consent; or
• (b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

11.11 If you believe that our processing of your personal information infringes data protection laws (in South Africa, the Information Regulator), you are legally within your right to lodge a complaint with a supervisory authority responsible for data protection in your jurisdiction.

11.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.

11.13 You may exercise any of your rights in relation to your personal data by written notice to us.

12. About cookies

12.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by that browser. The identifier is then sent back to the server each time the browser requests a page from the server.

12.2 Cookies may be “persistent” cookies or they may be “session” cookies. A persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before this expiry date. A session cookie on the other hand, will expire at the end of the user session, when the web browser is closed.

12.3 Cookies do not typically contain any information that would personally identify a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.

13. Cookies that we use

13.1 We use cookies for the following purposes:

• (a) Authentication – we use cookies to identify you when you visit our website and as you navigate our website. Cookies used for this purpose are: Session Cookies
• (b) Analysis – we use cookies to help us to analyse the use and performance of our website and services, as well as understanding actions taken while browsing. Cookies used for this purpose are: Persistent Cookies

14. Cookies used by our service providers

14.1 Our service providers use cookies and those cookies may be stored on your computer when you visit our website.

14.2 We use Google Analytics and other analysis software to analyse the use of our website. These analytical software or service providers gather information about web use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website and browsing behaviours. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

15. Managing cookies

15.1 Most browsers allow you to refuse cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain relevant information about blocking and deleting cookies via these links:

• (a) Chrome
• (b) Firefox
• (c) Opera
• (d) Internet Explorer
• (e) Safari
• (f) Edge

15.2 Blocking all cookies will have a negative impact upon the usability of many websites.

15.3 Blocking cookies on our website will mean that you may not be able to use all features.

16. Our details

16.1 This website is owned and operated by Embassy Travel, part of the Singer Group of Companies.

16.2 You can contact us:

• (a) by calling us on +27 21 424 1111
• (b) using our website contact form
• (c) by email at reservations@embassytravel.co.za