Snorkeling in Fiji

Privacy Policy

Zegrahm Expeditions (the "Company", "we", "our", or "us") Privacy Policy sets out what information we collect, how we collect it, and what we do with it. Our Privacy Policy applies to you and your use of our website, other applications, platforms or channels, available now or created in the future, which are owned or operated by the Company and through which we make our products and services  available (collectively, the “Sites”). In all your dealings with us you must ensure that others you represent are aware of the content of our Privacy Policy and consent to your acting on their behalf.

INFORMATION ABOUT YOU

Your Information

This refers to a combination of information such as your name, contact details, travel preferences and special needs/disabilities/dietary requirements that you supply us or is supplied to us, including your social preferences, interests and activities and any information about other persons you represent (such as those on your booking). Your information is collected when you request information from us, contact us (and vice versa), make a booking, use our Sites and any other engagement we or our business partners have with you.

We will update your information whenever we can to keep it current, accurate and complete.

Our Use of Your Personal Information

(1) For the purpose of providing you with our services, including your flight, expedition, security, incident/accident management or insurance, etc., we may disclose and process your information to third parties. In order for you to travel abroad, it may be mandatory (as required by government authorities at the point(s) of departure and/or destination) to disclose and process your information for immigration, border control, security and anti-terrorism purposes, or any other purposes which they determine appropriate. Some countries will only permit travel if you provide your advance passenger data (for example Caricom API and US secure flight data). These requirements may differ depending on your destination and you are advised to check. Even if not mandatory, we may exercise our discretion to assist where appropriate.

(2) We may collect, and disclose to others, the information you provide to us and our group companies and brands for business purposes and also third-party companies and our third-party service providers for the purposes set forth below in this Section 2. If you do provide us with your information, we will only share it for the purposes described at the point of collection.  We will not sell, license, transmit or disclose this information outside of the Company for any other purpose unless (a) you expressly authorize us to do so, or; (b) it is necessary to allow our service providers or agents to provide services to you or; (c) Your personal data may be processed on our behalf by our trusted third party suppliers to assist and help us in consumer classification which enables more accurate and relevant marketing. We share your information with any third party that you consent to our sharing your information with for marketing purposes; (d) it is necessary in connection with a sale of all or substantially all of the assets of the Company or the merger of Company into another entity or any consolidation, share exchange, combination, reorganization, bankruptcy or like transaction in which the Company is not the survivor; (e) it is necessary in connection with other business purposes including, without limitation, administration, service, customer care, quality and improvement related activity, business management and operation, risk assessment/management, security, fraud and crime prevention/detection, monitoring, research and analysis, social media, reviews, advertising and marketing, loyalty programs, profiling customer purchasing preferences, activities and trends, dispute resolution/litigation, credit checking and debt collection, or; (f) otherwise as we are required or permitted by law.

If you do not agree to Our Use of Your Information above, we cannot engage/do business with you or accept your booking.

Marketing Material

(1) Using your information, we may from time to time contact you with or make available to you (directly or indirectly) information on offers of goods and services, brochures, new products, forthcoming events or competitions from our holiday divisions and our group companies or third-parties as set above (“Our Use of Your Information”). We will tailor the information you receive or see; this will enable us to make available to you more personalized and relevant communications.  We may use innovative technologies and work with our third-party business partners to achieve this.

(2) We will assume you agree to email when you make an e-booking or provide us with your email in other situations such as in-store, competitions, promotions, prize draws and social media.

(3) If you do not wish to receive such information or would like to change your preferences, please refer to the “Your Rights” section of this Privacy Policy below. 

Your Rights

Upon request via postal mail, e-mail, or telephone, we will provide you a summary of your information retained by the Company. As allowed by law and consistent with our applicable business partner agreements, you may modify, correct, change, or request the Company to delete or update information that you have supplied to us through the Sites by contacting the Company via postal mail to: Zegrahm Expeditions, Legal Department, Travelopia House Crawley Business Quarter, Fleming Way, Crawley, West Sussex RH10 9QL; or, to the extent  available, you can amend your previous preference either: (i) directly on our website(s); (ii) by using our “unsubscribe email” available on every marketing email sent by the Company; (iii) by opting-out of personalized emails; or (iv) by referring to our literature containing instructions on how to opt-out of marketing communications. Once properly notified by you, we will take steps to stop using your information in this way.

Foreign Controls

Our Sites are intended for and directed to consumers in the United States of America. If you are visiting from the European Economic Area (“EEA”) or other regions or countries with laws governing data collection and use that may differ from U.S. law, please note that you are transferring information about you to a country and jurisdiction that does not have the same data protection laws as the EEA or the non-U.S. region or country from which you have transmitted your information. By providing us with your information you consent to: the transfer of information about you, including information to the U.S.; and the use and disclosure of information about you as described in this Privacy Policy.

USE OF TOOLS/"COOKIES" AND LINKS TO OTHER WEBSITES

If our contact and dealing with you is via our Sites, cookies may be used. To find out more about the types of cookies on our Sites, how we use cookies, to disable them or to change your preference and more, please see our Cookies Policy. By using our Sites, you consent to our use of cookies.

Our Sites may contain links to third party websites or micro-sites not controlled or owned by us. For example, reference sites or ancillary products and services sites or websites owned by our sister companies. It is your responsibility to check the status of these sites before using them. Please read their applicable terms and conditions carefully.

CHILDREN UNDER 13

Our Sites are not directed to persons under the age of 13. We do not collect information from children under 13 other than as when necessary to comply with the law or for safety reasons. If you are under the age of 13, you must ask your parent or guardian to assist you in using our Sites. Furthermore, we may restrict entries to any contests, sweepstakes or promotions to entrants who are at least 18 years of age.

California Residents – Your Privacy Rights

 

This section is applicable to residents of California. If you are a resident of California, you have certain rights described below.

1.      Rights Provided by California Civil Code Section 1798.83

A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by mailing us at Zegrahm; Attn: Legal Department, D S T House, St Mark's Hill, Surbiton KT6 4BH, United Kingdom, or emailing us at datateam@exodus.co.uk. Please note that we are only required to respond to two requests per California Customer each year under Code Section 1798.83.

2.      Rights under the California Consumer Privacy Act

This section of our Privacy Policy provides California residents with a comprehensive description of our online and offline practices regarding the collection, use, disclosure, and sale of personal information and the rights of California consumers regarding their personal information under the California Consumer Privacy Act (“CCPA”). “Personal Information” under this section has the same meaning as defined in the CCPA. This section applies to all California residents (but not including legal entities, such as companies). The section will not apply, however, if we do not collect any Personal Information about you or if all of the information we collect is exempt from the statute (for example, the CCPA does not protect information that is already protected by certain other privacy laws, and it does not protect information that is already publicly available).

With whom do we share your information?

The above sections describe how we collect, use, and disclose your Personal Information.

Sale of Personal Information

We do not sell your Personal Information.

You have a right to access and disclosure.

You have the right to request disclosure about what categories of Personal Information we have used or disclosed for a business purpose about you and the categories of third parties to whom the Personal Information was used or disclosed. Additionally, you have the right to request disclosure of specific pieces of information. Below is a full list of the information that you can include in your request.

The categories of Personal Information that we have collected about you:

  • The categories of sources from which we have collected the information
  • The business or commercial purpose for collecting or selling the Personal Information
  • The categories of third parties with whom we share Personal Information
  • The specific pieces of Personal Information we have collected about you
  • The categories of Personal Information that we have disclosed about you for a business purpose
  • The categories of Personal Information that we have sold about you, as well as the categories of third parties to whom we sold the information

When you make a request under your Right to Know, you can expect the following:

  1. We will verify your identity in order for us to verify that you are who you say you are.
  2. We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at datateam@exodus.co.uk.
  3. We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  4. In certain cases, a Request to Know may be denied, for example, if we cannot verify your identity or if providing you the information could create an unreasonable risk to someone’s security (for example, we do not want very sensitive information disclosed inappropriately). If we deny your request, we will explain why we denied it. If we deny a request, we will still try to provide you as much of the information as we can, but we will withhold the information subject to denial.

If you would like to exercise your right to request disclosure, please contact us using the information below under “How to contact us”. Our privacy team will examine your request and respond to you as quickly as possible.

You have a right to request deletion.

You have the right to request that we delete any Personal Information about you that we have collected from you. Please note that there are exceptions where we do not have to fulfil a request to delete information, such as when the information would create problems with the completion of a transaction or compliance with a legal obligation.

If you would like to exercise your right to request disclosure, please contact us using the information below under “How to contact us”. Our privacy team will examine your request and respond to you as quickly as possible.

When you make a request for deletion, you can expect the following:

  1. After you request deletion, you will need to confirm that you want your information deleted.
  2. We will verify your identity.
  3. We will confirm our receipt of your request within 10 days. If you have not received a response within a few days after that, please let us know by contacting us at the webpage listed below.
  4. We will respond to your request within 45 days. If necessary, we may need an additional period of time, up to another 45 days, but we will reply either way within the first 45-day period and, if we need an extension, we will explain why.
  5. In certain cases, a request for deletion may be denied, for example, if we cannot verify your identity, the law requires that we maintain the information or if we need the information for to provide you with a service you requested. If we deny your request, we will explain why we denied it and delete any other information that is not protected from deletion. 

You have a right to non-discrimination.

We will not discriminate against you (e.g., by denying you goods or services or providing a different level or quality of goods or services) for exercising any of the rights afforded to you.

SECURITY STATEMENT

No data transmissions over the Internet are completely secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us over the Internet. You transmit such information at your own risk. Once we receive your transmission, we make reasonable efforts to ensure the security of our systems. We use reasonable efforts to protect your information from unauthorized access, disclosure, alteration, or destruction. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach or other unintended, unauthorized or criminal activity.

CHANGES TO THIS POLICY

Any changes to this Policy will be either posted on our website, brochure and/or made available on request. In the event we materially change the way in which we use your information, we will provide you with at least 30 days’ notice and ask you to affirmatively accept the changes. 

Last updated: 1 July 2018