Privacy 1. IMPORTANT INFORMATION AND COMPANY DETAILS
Data Controller Information
- Company Name: AADVARK AFRICA SAFARIS
- Registration: Kenya Tourism Board Licensed Operator
- Address: Visions Plaza, 3rd Floor, Room 17, P.O. Box 64, Athi River, Kenya
- Contact: info@aadvarkafrica.com
Policy Scope and Application This privacy policy applies to:
- All clients and prospective clients
- Website visitors and online service users
- Newsletter subscribers and marketing contacts
- Business partners and supplier contacts
- Employee and contractor data (separate policy applies)
Legal Framework Compliance
- Kenya Data Protection Act 2019
- General Data Protection Regulation (GDPR) for EU residents
- Tourism industry best practices
- International data transfer regulations
Data Protection Principles We process personal data in accordance with principles of:
- Lawfulness, fairness, and transparency
- Purpose limitation and data minimization
- Accuracy and timely correction
- Storage limitation and secure retention
- Integrity, confidentiality, and security
- Accountability and demonstrable compliance
Privacy 2. DATA COLLECTION PRACTICES
Categories of Personal Data Collected
Identity and Contact Information
- Full name and preferred name
- Email addresses (personal and business)
- Telephone numbers (mobile and landline)
- Postal addresses (home and billing)
- Date of birth and nationality
- Gender and marital status
Travel-Related Information
- Passport details and visa information
- Travel preferences and requirements
- Dietary restrictions and allergies
- Medical conditions affecting travel
- Emergency contact information
- Previous travel history with us
Financial Information
- Payment card details (securely processed)
- Billing addresses
- Transaction history
- Payment preferences
- Credit check information (if applicable)
Technical and Usage Data
- IP addresses and device identifiers
- Browser type and version
- Operating system and device specifications
- Website usage patterns and preferences
- Cookie and tracking technology data
- Search queries and interaction data
Communication Records
- Email correspondence
- Phone call recordings (with consent)
- Live chat transcripts
- Feedback and survey responses
- Social media interactions
- Marketing preference settings
Privacy 3. METHODS OF DATA COLLECTION
Direct Collection Methods
Online Platforms
- Website contact forms and booking systems
- Online account creation and management
- Newsletter subscriptions and preference centers
- Survey and feedback form submissions
- Live chat and customer service interactions
Offline Interactions
- Phone conversations and bookings
- Face-to-face meetings and consultations
- Trade show and event interactions
- Paper-based forms and applications
- Referral information from partners
Indirect Collection Methods
Third-Party Sources
- Travel agents and booking partners
- Social media platforms (with permission)
- Marketing partners and affiliates
- Credit reference agencies (for payment verification)
- Public sources and industry databases
Automatic Collection
- Website cookies and tracking pixels
- Analytics tools and user behavior tracking
- Email engagement and delivery statistics
- Device fingerprinting and location data
- Search engine and referral source data
Privacy 4. PURPOSE AND USE OF PERSONAL DATA
Primary Service Delivery
Booking and Reservation Management
- Processing travel bookings and modifications
- Coordinating with suppliers and service providers
- Managing payment processing and invoicing
- Providing booking confirmations and travel documents
- Handling cancellations and refund processing
Customer Service and Support
- Responding to inquiries and providing information
- Resolving issues and handling complaints
- Providing travel assistance and guidance
- Emergency support and communication
- Post-travel follow-up and feedback collection
Communication and Marketing
Service Communications
- Sending booking confirmations and updates
- Providing travel information and itineraries
- Notifying of changes or disruptions
- Emergency communications and alerts
- Post-service feedback requests
Marketing Communications
- Promotional offers and special deals
- Newsletter subscriptions and travel inspiration
- Event invitations and webinar notifications
- Customer satisfaction surveys
- Loyalty program communications
Business Operations
Service Improvement
- Analyzing customer preferences and behavior
- Developing new products and services
- Improving website functionality and user experience
- Training staff and enhancing service quality
- Measuring customer satisfaction and loyalty
Legal and Regulatory Compliance
- Meeting tourism industry regulations
- Complying with tax and financial reporting requirements
- Maintaining records for legal proceedings
- Preventing fraud and ensuring security
- Adhering to health and safety regulations
Privacy 5. DATA DISCLOSURE AND SHARING
Service Provider Partnerships
Travel Service Suppliers
- Hotels, lodges, and accommodation providers
- Airlines and transportation companies
- Tour operators and activity providers
- Restaurant and dining service providers
- Insurance companies and assistance services
Business Support Services
- Payment processors and financial institutions
- IT service providers and cloud storage companies
- Marketing agencies and communication platforms
- Legal advisors and professional consultants
- Accounting and auditing firms
Legal and Regulatory Disclosures
Government Authorities
- Tax authorities for financial reporting
- Tourism regulatory bodies for compliance
- Law enforcement agencies for legal investigations
- Immigration authorities for visa processing
- Health authorities for safety and security
Legal Proceedings
- Court orders and legal discovery requests
- Regulatory investigations and audits
- Insurance claims and dispute resolution
- Merger and acquisition due diligence
- Debt collection and recovery proceedings
Consent-Based Sharing
Marketing Partnerships
- Joint marketing campaigns with partner companies
- Referral programs and affiliate arrangements
- Social media integration and sharing features
- Customer testimonials and case studies
- Travel blogger and influencer collaborations
Privacy 6. INTERNATIONAL DATA TRANSFERS
Transfer Mechanisms and Safeguards
Adequacy Decisions
- Transfers to countries with adequate data protection laws
- European Commission adequacy decisions
- Automatic authorization for adequate countries
- Ongoing monitoring of adequacy status
- Alternative mechanisms if adequacy withdrawn
Standard Contractual Clauses
- European Commission-approved contract terms
- Binding obligations for data protection
- Audit rights and compliance monitoring
- Data subject rights and remedy mechanisms
- Regular review and update procedures
Certification Programs
- Privacy Shield and successor frameworks
- Industry-specific certification schemes
- Third-party verification and monitoring
- Annual compliance assessments
- Transparent reporting and accountability
Transfer Impact Assessments
Risk Evaluation Process
- Assessment of destination country laws
- Evaluation of security measures and controls
- Analysis of data sensitivity and volume
- Review of recipient obligations and commitments
- Documentation of safeguards and protections
Ongoing Monitoring
- Regular review of transfer arrangements
- Updates based on legal and regulatory changes
- Incident monitoring and response procedures
- Compliance audits and assessments
- Stakeholder communication and transparency
Privacy 7. DATA SECURITY MEASURES
Technical Security Controls
Encryption and Cryptography
- Data encryption in transit using TLS 1.3
- Data encryption at rest using AES-256
- End-to-end encryption for sensitive communications
- Cryptographic key management and rotation
- Digital signatures and certificate validation
Access Controls and Authentication
- Multi-factor authentication for system access
- Role-based access controls and permissions
- Regular access reviews and recertification
- Privileged account management and monitoring
- Single sign-on and identity federation
Network and Infrastructure Security
- Firewall protection and intrusion detection
- Virtual private networks for remote access
- Security monitoring and incident response
- Regular vulnerability assessments and penetration testing
- Secure software development practices
Organizational Security Measures
Personnel Security
- Background checks for employees handling personal data
- Security awareness training and education programs
- Confidentiality agreements and code of conduct
- Regular security updates and communications
- Incident reporting and response procedures
Physical Security
- Secure office facilities with access controls
- Locked storage for physical documents
- Clean desk policies and secure disposal
- Visitor management and escort procedures
- Environmental monitoring and protection
Vendor Management
- Due diligence and security assessments
- Contractual security requirements and obligations
- Regular audits and performance monitoring
- Incident notification and response procedures
- Business continuity and disaster recovery planning
Privacy 8. DATA RETENTION POLICIES
Retention Principles and Criteria
Legal and Regulatory Requirements
- Tax records: 7 years minimum retention
- Payment card data: Limited retention per PCI DSS
- Health and safety records: 10 years minimum
- Employment records: As required by labor law
- Contract and agreement records: Duration plus 6 years
Business and Operational Needs
- Active client relationships: Duration of relationship plus 3 years
- Inactive client data: 5 years from last interaction
- Marketing communications: Until consent withdrawal
- Website analytics: 26 months maximum
- Customer service records: 3 years from resolution
Data Category-Specific Retention
Financial and Payment Data
- Transaction records: 7 years for tax compliance
- Payment card data: Minimal retention, secure deletion
- Billing and invoicing: 7 years regulatory requirement
- Refund and credit records: 7 years for auditing
- Financial reporting data: Permanent retention
Communication and Marketing Data
- Email marketing lists: Until consent withdrawal
- Communication preferences: Until account closure
- Customer service inquiries: 3 years maximum
- Feedback and survey responses: 5 years for analysis
- Social media interactions: Platform-dependent
Secure Disposal Procedures
- Digital data: Cryptographic erasure and overwriting
- Physical documents: Secure shredding and destruction
- Storage media: Physical destruction or degaussing
- Backup systems: Automated purging procedures
- Third-party disposal: Certified destruction services
Privacy 9. YOUR PRIVACY RIGHTS
Information Access Rights
Right to Access
- Request copies of personal data held
- Information about processing purposes and legal basis
- Details of data recipients and transfer locations
- Retention periods and deletion criteria
- Source of data if not directly collected
Right to Rectification
- Correct inaccurate or incomplete personal data
- Update contact information and preferences
- Amend travel requirements and restrictions
- Verify identity before making corrections
- Notification to third parties of corrections
Data Portability and Control
Right to Data Portability
- Receive personal data in structured, machine-readable format
- Transfer data to another service provider
- Applies to data processed by consent or contract
- Technical feasibility considerations apply
- Security measures maintained during transfer
Right to Erasure (Right to be Forgotten)
- Request deletion of personal data when no longer necessary
- Withdraw consent for consent-based processing
- Object to processing for legitimate interests
- Challenge unlawful or excessive processing
- Legal retention requirements may override requests
Processing Restriction and Objection Rights
Right to Restrict Processing
- Suspend processing while verifying data accuracy
- Maintain data without active processing
- Limited to storage and specific authorized uses
- Notification before lifting restrictions
- Alternative to deletion in certain circumstances
Right to Object
- Object to processing based on legitimate interests
- Opt-out of direct marketing communications
- Object to profiling and automated decision-making
- Compelling legitimate grounds may override objections
- Immediate cessation for marketing objections
Rights Exercise Procedures
Request Submission Process
- Submit requests through designated contact channels
- Provide sufficient information for identity verification
- Specify the rights being exercised and scope
- Include relevant account or reference numbers
- Allow reasonable time for processing (30 days standard)
Identity Verification Requirements
- Government-issued photo identification
- Account verification through security questions
- Email confirmation from registered addresses
- Phone verification for account holders
- Additional verification for sensitive requests
Response and Appeal Process
- Acknowledgment within 72 hours of receipt
- Substantive response within 30 days (extendable to 90 days)
- Clear explanation if request is declined
- Information about complaint and appeal rights
- Free of charge unless requests are excessive
Privacy 10. DEFINITIONS AND GLOSSARY
Key Privacy Terms
Personal Data Any information relating to an identified or identifiable natural person, including:
- Direct identifiers (names, ID numbers, email addresses)
- Indirect identifiers (IP addresses, device IDs, location data)
- Special category data (health, biometric, genetic information)
- Online identifiers and digital footprints
- Inferred data and profiles derived from personal information
Data Processing Any operation performed on personal data, including:
- Collection, recording, and storage
- Organization, structuring, and retrieval
- Use, analysis, and consultation
- Disclosure, transmission, and sharing
- Alignment, combination, and profiling
- Restriction, erasure, and destruction
Legal Basis for Processing Legitimate grounds for processing personal data:
- Consent: Freely given, specific, informed agreement
- Contract: Necessary for contract performance
- Legal Obligation: Required by law or regulation
- Vital Interests: Protecting life or physical safety
- Public Task: Performing official functions
- Legitimate Interests: Balanced against individual rights
Data Protection Roles
Data Controller Entity determining purposes and means of processing:
- AADVARK AFRICA SAFARIS for client and marketing data
- Responsible for compliance and data subject rights
- Determines retention periods and security measures
- Liable for processing activities and violations
- Must maintain records of processing activities
Data Processor Entity processing data on behalf of controller:
- IT service providers and cloud storage companies
- Payment processors and booking platforms
- Marketing agencies and communication services
- Must follow controller instructions and contracts
- Limited liability for processing activities
Data Subject Individual whose personal data is being processed:
- Clients, prospective clients, and website visitors
- Newsletter subscribers and marketing contacts
- Employees, contractors, and business partners
- Has specific rights regarding their data
- Can exercise rights and lodge complaints
Privacy 11. POLICY UPDATES AND AMENDMENTS
Policy Review and Update Schedule
- Annual comprehensive policy review
- Quarterly assessment of regulatory changes
- Ad hoc updates for significant business changes
- Emergency updates for security incidents
- Stakeholder input and feedback integration
Change Notification Procedures
Significant Changes
- Email notification to all active clients
- Website banner announcements for 30 days
- Social media posts and newsletter inclusions
- Direct communication for material changes affecting rights
- Minimum 30 days notice period before implementation
Minor Updates
- Website posting with effective date
- Next scheduled communication inclusion
- Version control and change tracking
- Archive of previous policy versions
- Clear indication of modification dates
Consent and Continued Use
- Continued service use constitutes acceptance
- Explicit consent required for material changes
- Opt-out procedures for objectionable changes
- Grace period for service discontinuation
- Alternative arrangements for objecting users
Privacy 12. CONSENT AND AGREEMENT
Consent Mechanisms
Booking and Registration Consent
- Explicit consent checkbox during booking process
- Separate consent for marketing communications
- Granular consent options for different purposes
- Clear explanation of consent implications
- Easy withdrawal mechanisms provided
Ongoing Consent Management
- Preference center for consent updates
- Regular consent refresh and confirmation
- Automatic consent expiration for inactive accounts
- Clear records of consent history and changes
- Respect for withdrawn consent immediately
Special Category Data Consent
- Explicit consent for health and medical information
- Clear explanation of necessity and use
- Option to decline and alternative arrangements
- Enhanced security and access controls
- Limited retention and automatic deletion
Privacy 13. CONTACT INFORMATION
Data Protection Contacts
Primary Contact
- General Privacy Inquiries: privacy@aadvarkafrica.com
- Response Time: 48 hours for acknowledgment
- Business Hours: Monday-Friday, 8:00 AM – 6:00 PM EAT
- Mailing Address: Visions Plaza, 3rd Floor, Room 17 P.O. Box 64, Athi River, Kenya
Data Protection Officer
- Email: info@aadvarkafrica.com
- Responsibilities: Privacy compliance, rights requests, breach response
- Availability: Monday-Friday, 9:00 AM – 5:00 PM EAT
Rights Request Processing
- Dedicated Email: info@aadvarkafrica.com
- Identity Verification: Required for all requests
- Processing Time: 30 days standard, 90 days maximum
- Appeal Process: Available for declined requests
Emergency and Breach Reporting
- Breach Notification: info@aadvarkafrica.com
- Response Team: Available within 2 hours
- Escalation Procedures: Defined response protocols
- Regulatory Notification: Within 72 hours of discovery