All references in this Policy to Evolution Travel Network Limited, “the Company” “we”, “us”, “our” and like terms should be interpreted accordingly.
This Policy governs your personal information which is processed as part of your relationship with us and, its collection, which shall include legal and regulatory compliance, personnel, security and operations management. It is important to us that you understand how we handle your personal information.
Kindly read this Policy carefully before sharing information with us. By using this website, you are agreeing to the terms of this Policy, our use, sharing and disclosure of information.
Who Are We?
Which Personal Information do we collect?
We collect two types of personal information: personal information that can be used to identify you and non-personal information.
Personal Information is that type of information relating to an identified or identifiable natural person, whom the latter can be identified, directly or indirectly, in particular reference to an identifier. This personal information is that which you voluntarily provide to us, for instance when you inquire about our products and services.
We may collect the following information:
- Name & Gender
- Marital status
- Date of Birth
- Identification Number
- Residential Address
- Telephone number
- Credit Card and payment information
- Mailing address & Email address
- Cookies and similar technologies
In the process of collection of personal information, you should be aware that there may be instances in which the personal information provided by yourself to us is considered as “Special Category Data” which may include among others, personal information for the determination of the individual’s racial or ethnic origin, political opinions, religious beliefs, physical or mental health or judicial data.
Procedure for the collection of Your Personal Information
Your personal information may be collected or accessed in a number of ways including:
- Directly from yourself (whether directly or verbally)
- Generated by us in correspondence etc.
- Received by third parties in relation to the services provided by ourselves following your permission, which may be obtained directly from you or indirectly through your actions. In such instances, we will make sure that such third parties are entitled to disclose such information to us.
Collection, Use and Disclosure
We may collect Non-personal information to analyse trends and to gather other demographic information. Personal information is collected for our legitimate purposes and for any purposes we may disclose to you at the time of collection. We will make sure that your personal information is processed fairly and lawfully, and only to the extent necessary as may be allowed in terms of law, or in terms of our agreement or our terms and conditions. Personal Information may be processed:
- to provide you with our services requested and, any ancillary services related thereto;
- to communicate with you and to fulfil your requests for our products or services;
- to improve our products or services where possible;
- for customer service purposes;
- for marketing and promotional purposes, including remarketing;
- to conduct research;
- to provide information that we believe may be of interest to you;
- to enforce the legal terms that govern your use of our Website, and/or for the reasons specific to the type of collection of information.
Disclosure of Your Personal Information
Your personal information may be disclosed with our employees, our subsidiary companies and any other third parties which may require such information in order to be able to assist us in handling the relationship which we have with you. When we share your personal information with such third parties, we make sure that such parties make use of this data in a manner which ensures safety and security to your personal data. We will not sell or rent your personal information to third parties for marketing purposes without your consent.
We may further disclose personal information when lawfully requested by public authorities including information based on law enforcement requirements such as credit card processing and fraud prevention.
Restriction of Processing of Personal Information
We recognise your right to restrict the processing of personal information where one of the following applies:
- You contest the accuracy of the personal information for a period, enabling you to verify the accuracy of the personal information or;
- The processing is unlawful, and you oppose the erasure of the personal information and request the restriction of personal information or;
- We no longer need the personal information for the purposes of processing or;
- You have objected to processing pending the verification whether our legitimate grounds override yours;
When your consent is required for the collection, processing and disclosure of personal information, we will ensure that such consent is freely given and is unambiguous. Furthermore, subject to legal or contractual restrictions, you may withdraw your consent to the processing of your personal information. Any communications with respect to such withdrawal or variation of consent shall be in writing and addressed at email@example.com.
Accuracy, Access and Rectification of Your Personal Information
We will employ reasonable means to keep your personal information accurate, complete and up to date for its intended use, however you must immediately inform us, if and when, your personal information changes.
In so far as your personal information in concerned, you shall have the right to receive confirmation that your personal information is being processed and may request access to the said personal information. You may further request a copy of such information obtained by ourselves - such request may be made verbally or by electronic means. We will provide a copy of such in a commonly used electronic form.
Provided however, your right of access to personal information is not absolute. Where applicable law or regulatory requirements allow us to refuse to provide such personal information we shall reserve our right not to respond. Where it is impossible to provide you with access to your personal information, we will provide reasons as to why this is not possible, subject to any legal or regulatory restrictions.
You may review your personal information which we hold on yourself in order for you to be able to verify the lawfulness of the processing carried out by ourselves. When you become aware of any inaccurate or incompleteness in their personal information, you are to inform the Company for rectification. Where it results that there is inaccurate information, we will amend such information with the alternative text that you believe that it is accurate. Furthermore, we shall take all the necessary steps to inform any relevant third parties which hold the inaccurate information to rectify accordingly.
Your Right of Erasure
Unless we are obliged by law to retain your personal information, you may ask to have your information concerning you to be erased and on such demand, we will take all the necessary measures in order to erase all personal information concerning you without undue delay.
International Transfer of Personal Data
Where we allow contractors or third parties to process your personal information outside the European Economic Area, we will make sure that there are the proper safeguards in place so as to ensure that your personal information is subject to the same standards, security and protection as when processing your personal information inside the European Economic Area.
Protection, Storage and Retention of Personal Information
Safeguarding the privacy of your personal data is of utmost importance to us. Personal Information is retained on our servers in Germany and in other European countries. We will use appropriate administrative, technical and physical measures to safeguard your personal information against loss, misuse, theft, modification, disclosure or destruction. These include internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data. We restrict access to personal information to Evolution Travel Network Limited’s employees and contractors who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.
We will retain your personal information for as long as we believe that such information is necessary to fulfil the purposes for which the personal information was collected, except as otherwise allowed or required by applicable laws and regulatory requirements.
When we consider that such personal information is no longer required, we will remove any details that will identify you or destroy any records in relation to yourself.
You may sign up for our periodical newsletter by opting in to receive such newsletter via our website, and by further confirming your consent to such newsletter by clicking on a link which is sent to you via email. You may decide to unsubscribe to our newsletter at any time by selecting the ‘unsubscribe’ icon on our website. We may also send you transactional, technical or other service notifications from time to time.
Links to other Websites
When you access other websites from hyperlinks on our website, we have no control over the content of those websites.
Changes to this Policy
Please note that this policy may change from time to time. All updates will be published on the Website and, if the changes are significant, the changes will be posted on the Website and on this page thirty days prior to taking effect. Each version of this policy will be identifiable at the top of this document by its effective date and version number. We encourage you to refer to this policy periodically.
How to Contact Us
If you have any concerns with regards to our privacy methods and processes, you have the right to contact us by e-mail to make a complaint at firstname.lastname@example.org. Your concerns will be dealt within the shortest time possible. In case you are not satisfied with our response, you may contact the Information Commissioner’s Office in the United Kingdom. You can find the details on how to do this at https://ico.org.uk/