EAST AFRICA SHUTTLES PRIVACY POLICY
Introduction
This Privacy Policy describes how East Africa Shuttles Ltd collects, uses, and shares information about you when you visit and interact on our website (mobile and desktop) collectively, “Site” or other means connected to the Sites (such as contacting our customer service team via chat or email).
Below is a summary of our privacy practices.
1. Collection
We may collect information about you, such as your name, phone number, and email address, through your use of the Site.
2. Use
We may use your information to provide the requested services, maintain and improve the Site.
3. Sharing
We may share your information with suppliers, service providers, and our affiliates.
4. Cookies
We may use cookies and similar technologies to help provide our Site, understand and customize your preferences
5. Marketing Use
The information you supplied, will not be used by us for marketing purposes.
6. International Transfers
We maintain appropriate protections for cross-border transfers as required by law for international data transfers.
7. Information from Other Partners
We may collect information from affiliated entities, business partners, or other third party providers.
8. Security
We maintain reasonable security measures to protect your information and require our service providers to do the same.
9. Data Subject Rights
You may exercise certain rights of access, correction, deletion of your information.
10. Updates to Privacy Policy
We will notify you of any material changes by posting the updated version of this Privacy Policy and taking other steps as needed.
11. Third Party Links
We may provide links to Third Party Websites that are not owned or controlled by us, and are governed by separate user terms and privacy statements.
12. Additional Considerations
Information related to minors, policy language, and Terms of Use.
13. Contacting Us
Please contact us with any questions about this Privacy Policy or our privacy practices.
Our full Privacy Policy is available as follows.
1. Information We Collect
We collect information about you that you provide to us when using the Site, such as your name, address, phone number, credit card details, e-mail address, accommodation name, accommodation location and/or length of stay, and your account password for accommodation reservations.
By visiting our Site, we may also automatically collect certain usage information, such as your IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device’s operating system, application version, language settings, and pages that have been shown to you. If you are using a mobile device to access mobile optimized Site, we might also collect information that identifies your mobile device, such as the device ID, location of the device (with your consent), and device-specific settings and characteristics.
If you participate in an East Africa Shuttles program, there may be limited additional information that we may collect from the accommodation about your stay. For example, when you make a reservation, our system registers through which means and from which websites you have made your reservation. We may also collect certain information through cookies, tags, and similar technologies as detailed below.
– If you need to get in touch with our customer support team, or reach out to us through other means (such as through social media, or communicating with your accommodation through us), we will collect information from you there too.
– Where you submit reviews regarding your accommodation or other ancillary services available on our website through us, we will collect information from you included in your reviews, including your first name and country of residence.
– You can decide to participate in our referral programs or other promotions, and doing this will also mean providing us with personal data. In addition to that, you can provide us with feedback or ask for help with using the Sites or our various communications platforms.
– Where you are making a booking with other guests whose details you provide to us as part of your reservation, or if you make a booking on behalf of someone else, it is your responsibility to ensure that the person or people you have provided personal information about are aware that you have done so, and have understood and accepted how East Africa Shuttles uses their information (as described in this Privacy Policy).
– Accommodation partners may share information about you with us too – this may happen if you have questions about your pending booking or if disputes arise regarding your booking.
Special categories of personal information
Certain types of personal data, such as religion or health-related information, are considered sensitive and may require additional protection under applicable laws. Although we do not ordinarily collect sensitive personal data as part of standard accommodation bookings, there may be a need to from time to time, collect such information e.g. as contained in a government-issued identification document or medical certificate if such information is supportive of a transaction or request that you ask us to perform on your behalf such as a cancellation or amendment of your booking. You may also elect to provide us with other information which may imply or suggest information like religion, health or other information, such as when specifying your dietary needs. Such collection and processing of such sensitive personal data will be in line with what is set out in this privacy statement.
Where required by law, we rely on the following legal bases to process personal information:
– Necessity to Perform Contract with You – we need to process your information in order to provide our travel reservation services to you, answer questions and requests from you, and provide customer support;
– Our Legitimate Interests – we process your information for security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; to customize and provide our reservation travel services to you; and to respond to lawful requests, court orders, and legal process;
– Compliance with Legal Obligations – we need to process your information to comply with relevant laws and regulatory requirements;
– Consent for Special Categories of Personal Data and Non-Essential Cookies – we rely on your consent to collect sensitive personal data and to use/allow non-essential cookies.
– Protect Vital Interest – we may need to process your information in case of emergency involving an individual’s life or health.
2. How We Use the Information We Collect
We may use information collected through the Site to:
– Provide you with the requested services, such as creating a user account, processing and confirming your reservation, and communicating with you about services requested (e.g., pre-reservation or post booking chat support (excluding credit card number), special request, cancellations, rewards
– Conduct surveys or provide you with information about our services on our Site or on other websites you may visit
– Maintain and improve the Site, tailor the user experience, and for internal training
– Protect the security of you and the Site
– Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands
When you make a reservation on one of our business partners’ websites or apps, we may also receive certain information such as your name and reservation information, including the accommodation reserved, in order to process your reservation and identify which channel your reservation has originated from.
During calls with our customer support team, live listening may be done or calls may be recorded for quality and reference purposes which includes the usage of the recordings for the handling of claims, training and fraud detection purposes. If you would prefer that your call was not recorded, you can opt out by stating this, or by hanging up. Call recordings are kept for a limited amount of time and automatically deleted thereafter, unless East Africa Shuttles has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.
Please note that the confirmation emails and text messages sent after your booking, as well as the guest review emails sent after your departure, are not marketing messages. These messages are part of your accommodation reservation process. Respectively, they contain information for you to check in at your booked accommodation, and tools to optionally rate that accommodation after your stay.
As mentioned above, if you are completing the booking for another person who will stay at the reserved accommodation, you also have the option to insert the guest’s email address for the purpose that the guest will receive the reservation confirmation and a separate invitation to complete a guest review.
Communications on the Site
We offer you and accommodation partners various means to communicate about accommodations and existing reservations, directing the communications through the Site. You can contact us with questions about your reservation or about your accommodation via the Site, and via other channels that we may make available.
We may access communications and may use automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you or, accommodation partners, us, or others. Note, all communications sent or received using the Site’s communication tools will be received and stored by us. Business partners through whose platform you made the reservation and accommodation partners may choose to communicate with you directly via email or other channels that we do not control.
3. Sharing Your Information
In connection with your visit to our Site and use of our services, we may share your information as follows:
– Travel Suppliers such as accommodation properties (e.g., the specific accommodation that you have requested us to reserve) and/or third party accommodation suppliers who fulfil your travel reservations. These suppliers may contact you as necessary to obtain additional information about you, facilitate your travel reservation including communicating with you prior to arrival about your upcoming stay, or respond to a review you may submit in accordance with their own independent privacy policies.
– Third Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process personal information for purposes such as credit card and payment processing, business analytics or customer service to facilitate the delivery of online services and/or fraud prevention. Our third party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
– Business Partners with whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your personal information with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
– Our Affiliated Group Companies – our affiliated (group) companies’ employees who have access to this information with our permission and who need to know or have access to this information to perform the service requested by you (including customer services) and internal (audit/compliance) investigations.
– Where Required or Permitted by Law – such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of East Africa Shuttles, our users, or others.
– Business Reorganization – such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.
We provide appropriate protections for such sharing as required by applicable law to prohibit third parties from using your information for their own purposes, and to address the security and confidentiality of your information. Except as disclosed in this Privacy Policy or as required or permitted by applicable law, we will not disclose your information to third parties without your consent.
4. Cookies
Our Site uses and allows third parties to place cookies (session and persistent), pixels/tags, SDKs, application program interfaces (“APIs”), and other technologies (collectively, “Cookies”) on our Site that collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the Site to you, such as to keep you logged in while your visit our Site, while other Cookies are used to provide you with a better user experience, such as:
– To personalize the Site by remembering information about your activities on the Site (e.g., the language you selected or your log-in details). We may also use Cookies together with other automatically collected usage information to recognize a user across different devices, sessions or browsers (including when they have not logged-in) so as to deliver tailored information;
– Perform website analytics, such as impression reporting, demographic reporting and interest reporting. This may include the recording of mouse clicks, movements, page scrolling and restricted text entered into our Site forms through selected third parties but we will take sufficient precautions to ensure that personal information will not be collected during such recordings e.g. through the adoption of irreversible masking. Website analytics is used to improve our Site and services;
Your Choices
Please review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Cookies. If you disable or delete certain Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.
To learn more about certain Cookies used for interest based advertising (including through cross-device tracking) and to exercise certain opt-out choices you may have regarding Cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, or European Interactive Digital Advertising Alliance.
You may need to make such choices on each browser and device you may use to exercise choice regarding certain Cookies.
5. Using Information for Marketing Purposes
The information you supplied, will not be used by us for marketing purposes.
6. International Transfers
In connection with the purposes described above, your information may be stored in locations outside of your home country, which may have different standards of data protection than your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers, including information transferred to third parties.
7. Information from Other Partners
On occasion, affiliated entities, business partners, or other third party providers may share information with us. We may collect information such as your username, and other information made available to us via such services. In general, your ability to provide such information is through the service provider themselves and you can change those settings in your account settings of the relevant service provider. In general, we may work with our partners to improve and personalize your use of our website in accordance with this policy.
8. Protecting Your Information
We maintain reasonable physical, electronic, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access.
Data Retention
We will retain your information for the period necessary to provide and secure our Sites and services, and to exercise our legal rights and comply with our legal or regulatory obligations. When East Africa Shuttles no longer needs to use your information, we will – unless we need to keep your information to comply with applicable legal or regulatory obligations or the information is required to carry out corporate tasks and conduct our business – remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.
9. How You Can Access or Change Your Information
You can easily correct your account name, the booking holder name (subject to the cancellation policy attached to the booking) and contact number at any time by signing in to your account on the website. Alternatively, please contact us via our Customer Support page to exercise any of the following rights:
– Access: You are entitled at any time to obtain information about your personal information that we store, in accordance with applicable law and without any fee. However, in exceptional cases we ask you to pay reasonable fees before we provide the information if permitted by applicable law.
– Rectification: You may request that we rectify any of your personal information that is incomplete or incorrect.
– Deletion: You may request that we delete your account.
– Restrictions of Processing: You may ask us to cease processing of your personal information for example if you have objected to the processing and the existence of legitimate grounds is still under consideration.
– Right to Revoke Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn.
– Data Portability: If applicable, you may request us to send you your personal information which we store, in a commonly used and machine readable format which shall be decided at our sole discretion.
To protect your privacy and security, we will verify your identity before responding to such request, and your request will be answered within a reasonable timeframe. We may not be able to allow you to access certain personal information in some cases e.g. if your personal information is connected with personal information of other persons, or for legal reasons. In such cases, we will provide you with an explanation why you cannot obtain this information. We may also deny your request for deletion or rectification of your personal information due to statutory provisions, especially those affecting our accounting processes, processing of claims, for fraud detection or prevention purposes, and mandatory data retention, which may prohibit deletion or anonymization.
10. Updates to Privacy Policy
On occasion, East Africa Shuttles may revise this Privacy Policy to reflect changes in the law, our information collection and use practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect or use your information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. East Africa Shuttles will also prominently post such material changes prior to implementing the change, and ask for your consent if required by law.
11. Links to Third Party Websites
We may provide links to other websites that are not owned or operated by us (“Third Party Websites”). When you use a link online to visit a Third Party Website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third Party Website before providing any information on that website.
12. Additional Considerations
A Special Note About Minors
Our Site is not directed to minors under the age of 18. However, minors can normally accompany their parent(s) or legal custodian(s) who have booked an accommodation, unless prohibited by an accommodation property’s policies.
Language
This Privacy Policy has originally been drawn up in the English language. In case of conflict between the English language version and a translated version, the English language version shall prevail.
Terms of Use
Please review the East Africa Shuttles Terms of Use for more details on using our Site. This Privacy Policy forms an integral part of our Terms of Use.
13. Contacting Us
If you have any questions about this Privacy Policy or our privacy practices, you may reach out to us through the following channels or by sending a registered letter to the address at:
East Africa Shuttles Ltd,
P.O. Box ,
Portal Place, 4th Fl, Suite 410, Muindi Mbingu St,
Nairobi, Kenya