As you may know, a new European privacy regulation called General Data Protection Regulation ("GDPR") has come into effect on May 25, 2018. GDPR is designed to unify the current data protection privacy laws throughout the EU, and to enhance the rights of European residents to protect their personal information. The GDPR also applies to any business that offers its products or services to European residents. We collect and use your personal information when you avail our services. For the purpose of the General Data Protection Regulation (“GDPR”), we are the ‘data controller’. Our data protection officer can be contacted at email@example.com
Collection of your personal data :
Personal data means any information about an individual from which that person can be identified, addresses, date of birth, password and payment information. It does not include data where the identity has been removed or otherwise anonymized (anonymous data).
1. We collect your personally identifiable information including but not limited to your
(i) name ;
(ii) e-mail address ;
(iii) contact number ;
(iv) residential address ;
(v) credit/debit/bank account details ;
(vi) internet protocol ("IP") address, in the following circumstances :
A. When you book an expedition
B. When you register with us, make a requisition for information on expeditions or subscribe to our newsletters
How we use personal data :
We use personal information to provide the services that you request. To the extent we use your information including personal information to market our services to you, we will provide you the ability to opt-out of such uses.
We may use your personal information for the following purposes, including but not limited to:
(i) resolve disputes ;
(ii) troubleshoot problems ;
(iii) promote a safe service ;
(iv) collect fees owed to us ;
(v) cater to consumer interests while providing our services,
(vi) inform you about online and offline offers, products, services, and updates;
(vii) customize your experience ;
(viii) detect and protect us against error, fraud and other criminal activity ;
(ix) enforce our terms and conditions ;
(x) conduct research and analysis for improvising customer experience ;
(xi) to conduct periodical audit ;
(xii) contact you to send important information or notices etc. and as otherwise described to you at the time of collection.
Marketing Promotions :
Marketing promotions, research and programs help us to identify your preferences, develop programs and improve user experience. GHE frequently sponsors promotions to give its Users the opportunity to win discounts on expeditions. Personal Information collected by us for such activities may include contact information and survey questions. We use such Personal Information to notify contest winners and survey information to develop promotions and product improvements.
Use of Demographic and Profile Data :
In our efforts to continually improve our product and service offerings, we may, from time to time, collect and analyses demographic and profile data about your activity on our Website. We identify and use your IP address to help diagnose problems with our server, and to administer our Website. Your IP address is also used to help identify you and to gather broad demographic information. We may occasionally ask you to complete optional online surveys, which may require you to provide your contact information and demographic information (like zip code, age, or income level). We use this data to tailor your experience at our Website, providing you with content that we think you might be interested in and to display the relevant content according to your preferences.
With whom we share your Personal Information
We may share the personal information, obtained from you, with our other corporate entities and affiliates to:
1. help detect and prevent identity theft,
2. fraud and other potentially illegal acts ;
3. co-relate related or multiple accounts to prevent abuse of our services;
Those entities and affiliates may not market to you as a result of such sharing of personal information by us, unless you explicitly opt-in. We may disclose personal information in the following circumstances:
1. if required to do so by law or by law enforcement offices for investigating any civil or criminal offences; or
2. if such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal process.
3. to legal, financial or other professional advisors of GHE, or
4. to enforce our terms of the Policy;
5. to respond to claims that an advertisement, posting or other content violates the rights of a third party; or
6. to protect the rights, property or personal safety of the users of our Website, or the general public.
We may share our data, including personally identifiable information about you, with our parent and/or subsidiaries or business partners that are committed to serving your online needs and related services, throughout the world. Such data will be shared for the sole purpose of enhancing your browsing experience. To the extent that these entities have access to your information, they will treat it as protectively as they treat information they obtain from their other members. You should expect that we would share some or all of your information in order to continue to provide the service and the entity with which such information is being shared, will be required to follow this Policy with respect to your personal information.
How long we keep your personal data
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 statutory 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 unauthorized use or disclosure or 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.
We may retain certain information subsequent to the closing of your account, for example if it is necessary to fulfil our legal obligations or to exercise, to maintain security, to prevent fraud and abuse and to defend or enforce our rights.
How we protect your personal data
GHE takes the protection of your Customer Data seriously but, unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Customer Data, we cannot guarantee the security of your Customer Data transmitted through any channel, such as the Website; any transmission is at your own risk.
Notification of Modifications and Changes to the Policy
We reserve the right to change the terms of the Policy from time to time, as seem fit, without any intimation to you, and your continued use of the Website will signify your acceptance of any amendment to these terms. You are therefore advised to re-read the terms of the Policy on a regular basis. Should it be that you do not accept any of the modifications or amendments to the terms of the Policy, you may terminate your use of our services immediately.
Sharing of travelers’ photos and videos
By voluntarily submitting your travel photos or videos to GHE after availing our services, either on our Website or through email or any other medium of communication to us, you grant to GHE, a non-exclusive, perpetual, worldwide, royalty-free, transferable, and sub-licensable, license to edit, telecast, re-run, reproduce, use, syndicate, print and distribute the materials you submit, or any portion thereof, in or in connection with GHE. You represent and warrant to GHE that you have the full legal right, power and authority to grant the aforementioned license to GHE.
Our Website has stringent security measures in place to protect the loss, misuse, and alteration of the information under our control. Whenever you change or access your account information, we offer the use of a secure server. Once your information is in our possession, we adhere to strict security guidelines, protecting it against unauthorized access. As soon as the you declare the intent to avail any of the services offered by us on the Website, we shall transfer the control to a specified and authentic payment gateway that takes your credit card or debit card or other banking information and processes the payment transaction.
Choice to Opt-Out
You can contact us, at firstname.lastname@example.org to unsubscribe to our newsletters, publications or any other material.
Further, please note that all information, including personal information provided by you is voluntary in nature. You may, at any time, withdraw your consent, in accordance with this Policy. However, in the event you withdraw consent to provide information, including personal information, you agree that you will no longer be permitted to use our services.
EU data subject rights
If you are a resident in the EU, you may have certain rights in relation to the Customer Data we hold about you, which we detail below. Some of these only apply in certain circumstances where GHE is holding authority of the data and legally/contractually allowed as per the local laws as set out in more detail below. We also set out how to exercise those rights.
1. Right to information - including contact details to the DPO, the purposes for processing Personal Information and the rights of the individual.
2. Right to access the Personal Information that are processed
3. Right to erasure (” Right to be forgotten”)
4. Right to rectification
5. Right to restriction of processing
6. Right to data portability of the Personal Information supplied to GHE by the EU resident
7. Right to object (opt-out) to processing (unless GHE otherwise has compelling legitimate grounds)
EU residents can exercise these rights by raising a request directly at email@example.com
You further acknowledge that we may provide you certain information (apart from information available on the Website) which is designated confidential by us. You agree that you shall not disclose such confidential information without our prior written consent. Further, your information shall be regarded as confidential and therefore, will not be divulged to any third party, unless if legally required to do so to the appropriate authorities or otherwise permitted in terms of this Policy.
As a user of the Website, you understand and agree that you assume all responsibility and risk for your use of the Website, the internet generally, and the documents you post or access and for your conduct on and off the Website. Your use of site is subjected to our Policy. If you do not agree to this, we kindly request you not to use this portal.