Background and scope
As an ASATA registered South African travel agency, The Travel Connexion (hereinafter referred to as “The Travel Connexion” or “we” or “us” or “our”) needs to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
1. What is Personal Information?
“Personal Information” refers to private information about an identifiable person, which includes your name and surname, age, date of birth, contact details (e.g. your home address, postal address, e-mail address or phone number), physical location, social media account details and profile pictures.
Other information which might be Personal Information may include:
“Access Device and Device event information”: We may collect information such as your IP address, unique device identifier, the nature of the Access Device which you used to access the Website (e.g. a tablet or smart phone), the geographic location from which you accessed our Website (i.e. the geographic location of your Access Device), hardware model and settings, operating system type and version, browser language, system activity, crashes;
2. When will we process your Personal Information?
In addition to paragraph below, Personal Information may be processed by us in several ways, including, when:
- you access, browse or make use of the Website, and/or the Services;
- we provide the Service to you;
- you contact us, by email or telephonically;
- you sign up for our newsletters (“Newsletters”) and/or enter into any competitions which we run; and
- you submit your Personal Information to us for any other reason, or authorise third parties to do so.
3. How we collect your Personal Information
We will only collect personal information in compliance with POPIA. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.
Generally, this collection will occur:
- when you deal with us either in person, by telephone, text message or email;
- when you visit our physical office or website; or
- when you connect with us via social media.
We may collect personal information about you:
- when you purchase or make enquiries about travel arrangements or other products and services;
- when you enter competitions or register for promotions;
- when you subscribe to receive marketing from us (e.g. e-newsletters);
- when you request brochures or other information from us; or
- when you provide information, or use our services, on social media.
Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.
In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveler on the booking.
Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree you have obtained the consent of the other person for The Travel Connexion to collect, use and disclose the other person’s personal information in accordance with this Notice and that you have otherwise made the other person aware of this Notice.
You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.
We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all of your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information relating to you. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you, or a person acting on your behalf, provide to us.
Tracking Technology and Cookies
- A cookie is a small piece of data (an alphanumeric identifier) which our computer system transfers to your Access Device through your web browser when you visit the Website and which is stored in your web browser. When you visit the Website the cookie allows the site to recognise your browser. Cookies may store user preferences and other information.
4. What personal information do we collect?
Personal information generally means information which relates to a living individual who can be identified from that information, that can be used to contact or identify you. Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf.
We therefore typically process the following types of personal information about you:
- contact information (such as name, residential/mailing address, telephone number, email address);
- payment account information (credit/debit card details, including card type, card number, security number and expiry date);
- passport details;
- loyalty program / frequent flyer details;
- health information such as your dietary requirements and health issues (if any); and
- other details relevant to your travel arrangements or required by the relevant travel service provider(s) (e.g. airlines and accommodation or tour providers).
When you contact us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us. We also collect information that is required for use in the business activities of The Travel Connexion, including for example, financial details necessary in order to process various transactions and relevant personal information you may elect to provide to us.
Please note that, when necessary for travel arrangements, we may collect from a responsible adult personal information relating to a child of any age, but we do not knowingly collect any such information directly from children.
To the extent permitted or required under POPIA, you consent to us using and disclosing your information for the purpose for which it was collected. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages or dietary preference, in which case you consent to us using and disclosing that information in connection with facilitating your request. We will not use or disclose sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.
5. How do we use your personal information?
We will only process your information, where:
- you have given your consent to such processing (which you may withdraw at any time);
- the processing is necessary to provide our services to you;
- the processing is necessary for compliance with our legal obligations; and/or
- the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information
Where you contact us in relation to a travel booking or query, the purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services. When you book or otherwise arrange travel related products and services through us, we usually act as an agent for the relevant travel service providers (e.g. for a hotel). In this case, we process your personal information as necessary so as to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Notice and for the travel service provider for whom we act as agent (e.g. to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.
We act as agent for or on behalf of many thousands of travel service providers around the world, so it is not possible for us to set out in this Notice all of the travel service providers for whom we act or their locations. For more information about the disclosure of personal information to travel service providers located overseas, please refer to section 7 below.
The purposes for which we collect personal information further include:
- providing you with services and tools you choose to use
- identification of fraud or error;
- regulatory reporting and compliance;
- developing and improving our products and services and those of our related entities;
- servicing our relationship with you;
- involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided;
- internal accounting and administration;
- to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel; and
- other purposes as authorised or required by law (e.g. to prevent a threat to life, health or safety, or to enforce our legal rights).
Where permitted by POPIA, we may use your personal information to send you targeted marketing activities relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information. These may include, but are not limited to, mail outs, electronic marketing and notifications as described below, and telephone calls). We will only use your personal information to send electronic marketing materials to you (including e-newsletters, email,) if you have opted-in to receive them or not opt-ed out of receiving them, depending upon the applicable law. You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of our consultants to do so for you.
Should you no longer wish to receive promotional/marketing material from us, or receive other types of communication from us, please unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email.
6. Is personal information disclosed to third parties?
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Notice and, in particular, as set out below, and in accordance with POPIA. Note that, in this Notice, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.
Your personal information may be disclosed to the following types of third parties:
- our contractors, suppliers and service providers, including without limitation:
- in each of the circumstances set out in section 5 (“How do we use your personal information?”);
- suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting providers we may use);
- event and expo organisers;
- mailing houses, freight services, courier services; and
- external business advisers (such as lawyers, accountants and auditors);
- travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
- any third party to whom we assign or novate any of our rights or obligations;
- financial institutions such as banks, when processing financial transactions;
- a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);
- your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;
- a person who can verify to us that they have a relationship with you (e.g. a family member) where you are not contactable, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
- as required or authorised by applicable law, and to comply with our legal obligations;
- customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
- government agencies and public authorities to comply with a valid and authorised request, including a court order or other valid legal process;
- various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
- enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
When you engage us to book flights on your behalf, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant airline. This enables airlines to advise passengers of irregular flight operations and disruptions (e.g. flight cancellations, schedule changes) directly.
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including applicable privacy / data protection laws).
On our websites, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with us. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.
7. Is personal information transferred overseas?
We may disclose your personal information to certain overseas recipients, as set out below. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards as required by POPIA. It is possible that information will be transferred to an overseas recipient located in a jurisdiction where you will not be able to seek redress under POPIA and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by POPIA we will not be liable for how these overseas recipients handle, store and process your personal information.
i. Travel service providers located overseas
In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers. We deal with many different travel service providers all over the world, so the location of a travel service provider relevant to your personal information will depend on the travel services being provided. The relevant travel service providers will in most cases receive your personal information in the country in which they will provide the services to you or in which their business or management is based.
ii. Our third party service providers located overseas
We may also disclose your personal information to third parties located overseas for the purpose of performing services for us, including the storage and processing of such information. Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of your travel booking and/or to enable the performance of administrative and technical services by them on our behalf.
We deal with many different service providers all over the world, so it is not possible for us to set out in this Notice all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please contact us accordingly.
8. Security of information
We are committed to safeguarding and protecting personal information and although absolute security cannot be guaranteed on the Internet, we take reasonable technical and organisational security measures to protect your Personal Information against accidental or intentional manipulation, loss, misuse, destruction or against unauthorised disclosure or access to the information we process online.
We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.
9. Retention of your Personal Information
- We may retain all Personal Information that we collect from you so long as it remains necessary for the purposes for which it was collected unless there is a valid technical, legal or business reason for us to delete, destroy or de-identify it.
- Further, we may keep some of your Personal Information for as long as we are required by law, a code of conduct or we reasonably need it for lawful purposes related to our functions and activities; we reasonably need it for evidentiary purposes or you agree to us keeping it for a specific period.
10. Keeping your Personal Information updated and correct
To the extent required by law, we will take steps to ensure that your Personal Information is accurate, complete, not misleading, and up to date having regard to the purpose for which the information was collected or used.
You must let us know if you believe any information we have about you is incorrect, incomplete, misleading or out of date, by notifying us at the contact details set out below You may request that your Personal Information be deleted if it is no longer required for the purposes for which it was collected or required by us in terms of any applicable law.
11. Social Media Integrations
Our websites and mobile applications may use social media features and widgets (such as “Like” and “Share” buttons/widgets) (“SM Features”). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.
12. Linked Sites
14. Feedback / Contact
You can direct any questions or complaints about the use or disclosure of your personal information to the contact information below.
We will investigate all complaints promptly and diligently to address your concerns and resolve any disputes quickly.
Address: 172 Burwood Road, Lansdowne, 7780
This Privacy Notice was last updated on 30 June 2021