PRIVACY POLICY

Effective date: 2021-05-12

1. Introduction

Welcome to Masav Group,

Contact number: 011 656 1000

Email: info@masavgroup.com

Location: 173 Kelvin Dr, Morningside, Sandton, Gauteng, 2057. South Africa

Masav Group (“us”, “we”, or “our”) own and operates https://www.masavgroup.co.za/ , https://www.atlantiscorporate.co.za/ , http://www.atlantisice.co.za/ , https://www.atlantistravelgroup.co.za/ , http://www.atlantistravelmanagement.co.za/http://www.syvest.co.za/ , https://www.aresprotection.co.za/ , and https://www.nyamaandchips.co.za/ (hereinafter referred to as “Service”).

Our Privacy Policy governs your visit to https://www.masavgroup.co.za/ , https://www.atlantiscorporate.co.za/ , http://www.atlantisice.co.za/ , https://www.atlantistravelgroup.co.za/ , http://www.atlantistravelmanagement.co.za/http://www.syvest.co.za/ , https://www.aresprotection.co.za/ , and https://www.nyamaandchips.co.za/, and explains how we collect, safeguard and disclose information that results from your use of our Service.

This Privacy Policy govern your use of our website located a http://www.masavgroup.co.za/ (together or individually “Service”) operated by Masav Group. This Privacy Policy govern your use of all the websites owned by, belonging to and operating under the Masav Group, located at https://www.atlantiscorporate.co.za/ , http://www.atlantisice.co.za/ , https://www.atlantistravelgroup.co.za/ , http://www.atlantistravelmanagement.co.za/http://www.syvest.co.za/ , https://www.aresprotection.co.za/ , and https://www.nyamaandchips.co.za/

We use your data to provide and improve Service. By using Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions.

Our Terms and Conditions (“Terms”) govern all use of our Service and together with the Privacy Policy constitutes your agreement with us (“agreement”).

This Privacy Notice (“Notice”) sets out how the Masav Group and all entities owned by and operating under the Masav Group processes and protects the privacy of your personal information. 

We need to collect, use and disclose personal information in order to perform our business functions and activities, for 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.

Masav Group and all its entities in South Africa process the personal information of data subjects in accordance with the provisions of the Protection of Personal Information Act No. 4 of 2013 (“POPIA”), as amended.

For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) we are a “data controller” and/or a “Responsible Party” in terms of POPIA for the processing of personal information you provide to us in connection with:

• our provision of all business services and products, tangible and intangible, provided by the Masav Group and all its entities; and
• for the purpose of all our marketing and re-marketing activities above the line, through the line and below the line.

There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Notice. Where this occurs, we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.

2. Definitions

SERVICE means the https://www.masavgroup.co.za/ , https://www.atlantiscorporate.co.za/ , http://www.atlantisice.co.za/ , https://www.atlantistravelgroup.co.za/ , http://www.atlantistravelmanagement.co.za/http://www.syvest.co.za/ , https://www.aresprotection.co.za/ , and https://www.nyamaandchips.co.za/ websites operated by Masav Group.

PERSONAL DATA means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Service or from Service infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

Personal information has the meaning given under POPIA, and, where the GDPR applies, the meaning of personal data given under the GDPR. Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual. 

4.1 Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

4.1.1 Email address

4.1.2 First name and last name

4.1.3 Phone number

4.1.4 Address, Country, State, Province, ZIP/Postal code, City

4.1.5 Identity number and/or Passport number

4.1.6 Payment account information (credit/debit card details, including card type, card number, security number and expiry date)

4.1.7 Loyalty programs

4.1.8 Health information

4.1.9 Cookies and Usage Data

4.1.10 Other details relevant for our Service to operate its business functions for customers, clients, suppliers and third-parties.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link.

In some circumstances, we may collect personal information from you which may be regarded as sensitive information under POPIA. Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, membership of political, professional or trade associations (for use in executing Service business functions), biometric and genetic information, passwords and financial information and health information  Please note that, when necessary, 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.  

We will only collect sensitive information in compliance with POPIA, with your explicit consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities, unless we are otherwise required or authorised to do so by law. To the extent permitted or required under POPIA, you consent to us using and disclosing your sensitive information for the purpose for which it was collected, you consent to us using and disclosing your sensitive information in connection with the Service executing business functions and to facilitate your requests and requirements of the Service.

We will not use or disclose any sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.

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, letter, email;
• when you visit any of our websites; 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.

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 (see section 14below). 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.

4.2 Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through any device (“Usage Data”).

This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a device, this Usage Data may include information such as the type of device you use, your device unique ID, the IP address of your device, your device operating system, the type of Internet browser you use, unique device identifiers and other diagnostic data.

4.3 Location Data

We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

4.4 Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

4.4.1 Session Cookies: We use Session Cookies to operate our Service.

4.4.2 Preference Cookies: We use Preference Cookies to remember your preferences and various settings.

4.4.3 Security Cookies: We use Security Cookies for security purposes.

4.4.4 Advertising Cookies: Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.

4.5 Other Data

While using our Service, we may also collect the following information: sex, age, date of birth, place of birth, passport details, citizenship, registration at place of residence and actual address, telephone number (work, mobile), details of documents on education, qualification, professional training, employment agreements, NDA agreements, information on bonuses and compenation, information on marital status, family members, social security (or other taxpayer identification) number, office location and other data.

5. Use of Data

Masav Group uses the collected data for various purposes:

5.1 to provide and maintain our Service;

5.2 to notify you about changes to our Service;

5.3 to allow you to participate in interactive features of our Service when you choose to do so;

5.4 to provide customer support;

5.5 to gather analysis or valuable information so that we can improve our Service;

5.6 to monitor the usage of our Service;

5.7 to detect, prevent and address technical issues;

5.8 to fulfil any other purpose for which you provide it;

5.9 to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

5.10 to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;

5.11 to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

5.12 in any other way we may describe when you provide the information;

5.13 for any other purpose with your consent.

6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to – and maintained on – computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside South Africa and choose to provide information to us, please note that we transfer the data, including Personal Data, to South Africa and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Masav Group will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

8.1. Disclosure for Law Enforcement.

Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

8.2. Business Transaction.

If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.

8.3. Other cases. We may disclose your information also:

8.3.1. to our subsidiaries and affiliates;

8.3.2. to contractors, service providers, and other third parties we use to support our business;

8.3.3. to fulfill the purpose for which you provide it;

8.3.4. for the purpose of including your company’s logo on our website;

8.3.5. for any other purpose disclosed by us when you provide the information;

8.3.6. with your consent in any other cases;

8.3.7. if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at info@masavgroup.com.

In certain circumstances, you have the following data protection rights:

10.1. the right to access, update or to delete the information we have on you;

10.2. the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;

10.3. the right to object. You have the right to object to our processing of your Personal Data;

10.4. the right of restriction. You have the right to request that we restrict the processing of your personal information;

10.5. the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;

10.6. the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information; Please note that we may ask you to verify your identity before responding to such requests. Please note, we may not able to provide Service without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the United States of America to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy.

According to CalOPPA we agree to the following:

11.1. users can visit our site anonymously;

11.2. our Privacy Policy link includes the word “Privacy”, and can easily be found on the home page of our website;

11.3. users will be notified of any privacy policy changes on our Privacy Policy Page;

11.4. users are able to change their personal information by emailing us at info@masavgroup.com.

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

 

12. Your Data Protection Rights under the California Consumer Privacy Act (CCPA)

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. To exercise your data protection rights, you can make certain requests and ask us:

12.1. What personal information we have about you. If you make this request, we will return to you:

12.1.1. The categories of personal information we have collected about you.

12.1.2. The categories of sources from which we collect your personal information.

12.1.3. The business or commercial purpose for collecting or selling your personal information.

12.1.4. The categories of third parties with whom we share personal information.

12.1.5. The specific pieces of personal information we have collected about you.

12.1.6. A list of categories of personal information that we have sold, along with the category of any other company we sold it to. If we have not sold your personal information, we will inform you of that fact.

12.1.7. A list of categories of personal information that we have disclosed for a business purpose, along with the category of any other company we shared it with.

Please note, you are entitled to ask us to provide you with this information up to two times in a rolling twelve-month period. When you make this request, the information provided may be limited to the personal information we collected about you in the previous 12 months.

12.2. To delete your personal information. If you make this request, we will delete the personal information we hold about you as of the date of your request from our records and direct any service providers to do the same. In some cases, deletion may be accomplished through de-identification of the information. If you choose to delete your personal information, you may not be able to use certain functions that require your personal information to operate.

12.3. We don’t sell or rent your personal information to any third parties for any purpose. We do not sell your personal information for monetary consideration. However, under some circumstances, a transfer of personal information to a third party, or within our family of companies, without monetary consideration may be considered a “sale” under California law. You are the only owner of your Personal Data and can request disclosure or deletion at any time.

If you submit a request to stop selling your personal information, we will stop making such transfers.

Please note, such request, may impact your experience with us, and you may not be able to participate in certain programs or membership services which require the usage of your personal information to function. But in no circumstances, we will discriminate against you for exercising your rights.

To exercise your California data protection rights described above, please send your request(s) by email: info@masavgroup.com.

Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

13. Your Data Protection Rights under the Protection of Personal Information Act (POPIA)

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 4 (“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);
⚬ publishers, printers and distributors of marketing material;
⚬ event and expo organisers;
⚬ marketing, market research, research and analysis and communications agencies;
⚬ mailing houses, freight services, courier services; and
⚬ external business advisers (such as lawyers, accountants, auditors and recruitment consultants);

• our related entities and brands;
• 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, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant parties.

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.

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, SMS, MMS and iM) 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, participate in market research or receive other types of communication from us, please refer to the “Feedback / Complaints / Contact” section below. You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM or other form of electronic marketing. Please also see the “Your rights” section of this Notice to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes.

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. We will provide you with copies of the relevant safeguard documents on request.

It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) 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.

If you wish to make a Subject Access Request to:

• access, update, modify, rectify, erase, object to, or obtain a copy of the personal information that we hold on you; or
• restrict or stop us from using any of the personal information which we hold on you, including by withdrawing any consent you have previously given to the processing of such information; or
• where any personal information has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such personal information in a suitable machine-readable format or have that personal information transmitted by us to another controller/Responsible Party you can request this by contacting us as set out in section 14 below. You will receive acknowledgement of your request and we will advise you of the timeframe within which you will receive your information pack.

We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests.

We reserve the right to deny you access for any reason permitted under applicable laws. Such exemptions may include national security, corporate finance and confidential references. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by POPIA, will note your request and the denial of same in our records. 

You have the right to lodge a complaint with a relevant supervisory authority.

Further correspondence regarding your request should only be made in writing to the Masav Group Head Office, located at 173 Kelvin Drive, Johannesburg, Gauteng. 

Please note that, if you request that we restrict or stop using personal information we hold on you, or withdraw a consent you have previously given to the processing of such information, this may affect our ability to provide services to you or negatively impact the services we can provide to you.

You must always provide accurate information and you agree to update it whenever necessary.  You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it is not correct.

You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated above in section 1.

In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of personal information.

To the extent permissible by law, we reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal information, and for any additional copies of the personal information you request from us.

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.

In detail: Where you contact us, the purpose for which we collect your personal information is generally to provide you with advice and/or to assist you with related products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Notice (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc.).

When you contact us to use our products and services through us, we usually act as an agent for the relevant service providers. 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 service provider for whom we act as agent.

We may therefore share your information with our service providers. Please note that these service providers also may use your personal information as described in their respective privacy policy and may contact you as necessary to obtain additional information about you, to facilitate the Service, or provide you with your requested services. We encourage you to review the privacy policies of any third-party travel service providers whose products you purchase through us. We will provide you with copies of all relevant service provider terms, conditions and privacy policies on request.

We act as agent for or on behalf of many service providers around the world, so it is not possible for us to set out in this Notice all of the service providers for whom we act or their locations. If you have any concerns regarding the transfer of your personal information to a service provider, please contact us for further information.

The purposes for which we collect personal information further include:

• providing you with services and tools you choose to;
• identification of fraud or error and credit checks;   
• regulatory reporting and compliance;   
• developing and improving our products and services and those of our related entities;   
• servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences;  
• involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided;   
• to facilitate your participation in loyalty programs;   
• for research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and other areas utilized by our entities and use of our websites;   
• internal accounting and administration;
• to comply with our legal obligations and any applicable customs/immigration requirements; 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, SMS, MMS and iM) 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, participate in market research or receive other types of communication from us, please contact us. You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM or other form of electronic marketing. Please also see the “Your rights” sections (section 10; 11; 12; and 13) of this Notice to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes.

 

14. Service Providers and 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 this notice;
⚬ 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);
⚬ publishers, printers and distributors of marketing material;
⚬ event and expo organisers;
⚬ marketing, market research, research and analysis and communications agencies;
⚬ mailing houses, freight services, courier services; and
⚬ external business advisers (such as lawyers, accountants, auditors and recruitment consultants);

• our related entities and brands;
• all 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 acting on your behalf only in the capacity to facilitate the service you have requested of the Service;
• 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;
• 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 the us and/or the entities to operate or conduct business function on your behalf, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant parties. This enables those parties to advise us on operations and disruptions 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.

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas service providers. We deal with many different 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 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. 

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. We will provide you with copies of the relevant safeguard documents on request.

It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) 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.

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 use key service providers located 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. 

 

 

15. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

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.

If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them.

 

Similarly, your interactions with the SM Features may be recorded by the third party. In addition, the third party company may send us information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to you via the third party social media platform.

 

You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third party social media platform.

Your interactions with these SM Features are governed by the privacy policy of the third party company providing them. For more information about the data practices of these third party companies, and to find out more about what personal information is collected about you and how the third party uses such personal information, please refer to their privacy policy directly.

16. IP addresses

When you access our website, use any of our mobile applications or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet. 

We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (e.g. to better tailor our marketing and advertising materials, provided you have opted in to receive electronic marketing).

17. Tracking Technologies / Cookies

We may use third-party web analytics services on our websites and mobile apps, such as those listed in our Cookies Policy. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.

For information regarding our use of cookies and tracking technologies, refer to our Cookies Policy on our website.

18. Linked Sites

Our websites may contain links to third party websites over which we have no control. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policies of any linked third party websites you visit as their privacy policy and practices may differ from ours.

19. CI/CD tools

We may use third-party Service Providers to automate the development process of our Service.

20. Advertising

We may use third-party Service Providers to show advertisements to you to help support and maintain our Service.

21. Behavioral Remarketing

We may use remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

 

22. Payments

We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy.

 

These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover.

 

PCI-DSS requirements help ensure the secure handling of payment information.

23. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party’s site.

We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

For example, the outlined privacy policy has been made using PolicyMaker.io, a free tool that helps create high-quality legal documents. PolicyMaker’s privacy policy generator is an easy-to-use tool for creating a privacy policy for blog, website, e-commerce store or mobile app.

24. Children’s Privacy

Our Services are not intended for use by children under the age of 18 (“Child” or “Children”).

We do not knowingly collect personally identifiable information from Children under 18. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

 

 

25. Changes to This Privacy Policy

We are committed to safeguarding and protecting personal information and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal information provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal information transmitted, stored or otherwise processed.

 

Masav Group has implemented various physical, electronic and managerial security procedures in order to protect the personal information it holds from loss and misuse, and from unauthorised access, modification, disclosure and interference.

 

Masav Group regularly reviews security technologies and will strive to protect your personal information as fully as we protect our own confidential information.

 

Masav Group is not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.

We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

26. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: info@masavgroup.com.

This Privacy Policy was created for Masav Group and all websites and entities managed by the Masav Group by PolicyMaker.io on 2021-05-12, and is effective as of 2021-05-12.