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Privacy Policy


INTRODUCTION  

Welcome to our Privacy Policy. The terms “we”, “us”, “our”, and “GVI” refer to GVI World Limited, a limited company, and its subsidiaries and corporate affiliates, including Experiential Education Limited, Bushwise Field Guides and entities duly licensed to use the GVI brand.

This privacy policy is referenced in our Website Terms of Use available on this site. GVI respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

  1. IMPORTANT INFORMATION AND WHO WE ARE

 

PURPOSE OF THIS PRIVACY NOTICE  

This Privacy Policy aims to give you information on how GVI collects and processes your personal data through your use of this website, including any data you may provide through this website when you download content, sign up to our newsletter or apply to join a program.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

 

CONTROLLER   

GVI is made up of different legal entities. This Privacy Policy is issued on behalf of the GVI Group so when we mention GVI, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the GVI Group responsible for processing your data. The company controlling your data when you enquire about or purchase a GVI travel program will be Experiential Education Limited a UK registered company with offices and operations in the United Kingdom, South Africa and in all locations where its travel programs are available. The company controlling your data when you enquire about or purchase a Field Guide related course will be Bushwise Field Guides (Pty) Ltd, a South Africa registered company. GVI World Limited is the processor and responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights , please contact the DPO using the details set out below.

 

CONTACT DETAILS  

Our full details are:

Full name of legal entity: GVI World Limited 

Name or title of DPO: Laura Dix-Bowler

Email address: dpo@gviworld.com  

Postal address: 1 Emperor Way, Exeter Business Park, Exeter, EX1 3QS

[Telephone number:] +44 1727 250 250

 

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES  

This version was last updated on 21 May 2018 

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

THIRD-PARTY LINKS  

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the Privacy Policy of every website you visit.

 

 

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

 

  • Identity Data may include first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
  • Contact Data may include email address and telephone numbers.
  • Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
  • Technical Data may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Usage Data may include information about how you use our website, products and services.
  • Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Special categories of personal data may include health data relevant to your program, criminal history as relevant to your travel program.

 

 

IF YOU FAIL TO PROVIDE PERSONAL DATA  

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may be unable to complete your booking. We will notify you if this is the case at the time.

 

 

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including through:

 

  • Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • apply for our programs;
  • request marketing to be sent to you;
  • provide any other personal data to GVI directly by post, phone or email

 

  • Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties [and public sources] as set out below :
  • Technical Data from the following parties:

(a)  analytics providers such as Google Analytics

(b)  advertising networks such as Google Adwords, Facebook and Bing

 

 

  1. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by Contacting us.

 

 

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA  

We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to process your application or complete your booking)), vital interests and where relevant “legitimate interests”.

.

MARKETING  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

PROMOTIONAL OFFERS FROM US   

You will receive marketing communications from us if you have opted to do so while requesting other information from us or when making a booking.

 

THIRD-PARTY MARKETING  

We will get your express opt-in consent before we share your personal data with any company outside the GVI group of companies for marketing purposes.

 

OPTING OUT  

You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in the footer of all marketing messages.  Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of booking onto a program.

 

COOKIES 

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy

 

CHANGE OF PURPOSE  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes of providing services to you or performing our contract with you.

  • Suppliers: such as insurance providers, and other entities we work with in order to fulfill our contract with you.
  • Third-party vendors: who provide services or functions on our behalf, such as credit card processing, business analytics, support and fraud prevention. Such vendors are not permitted to share or use the information for any other purpose other than performing the specific functions they provide.
  • GVI-controlled entities: are the various operating entities that provide on-the-ground support at our various global program bases.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

 

  1. INTERNATIONAL TRANSFERS

As an international travel company and tour operator, GVI has operations in various locations across the world including all the places where our programs are based. As part of the process of processing your application for a program and performing our contract with you your personal data may be transferred outside the European Economic Area (EEA). This could include places whose laws may provide for a lesser standard of protection for your personal data than that provided under European Law. In order to meet the data protection standards of European Law we will only transfer your data using one of the safeguards listed below.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it via at least one of the following safeguards:

  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Transfers to suppliers and partners based outside the EEA may also be required such as when GVI assists with visa applications and renewals. Certain licences, permissions and authorisations required in order to participate in our programs and or enter certain controlled areas (such as national parks, partner schools and dive locations) will require a transfer of your personal data to relevant external suppliers and partners. Suppliers and partners are required to adhere to the same standards as GVI when dealing with personal data.

 

 

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

 

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 

  1. YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

 You have the right to:

 

    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

    Object to processing of your personal data where we are relying on a legitimate interest (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 as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please Contact us.

 

NO FEE USUALLY REQUIRED  

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

WHAT WE MAY NEED FROM YOU  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

TIME LIMIT TO RESPOND  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

 

  1. GLOSSARY

 

LAWFUL BASIS   

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.