General Data Protection Regulation (GDPR), Article 13 and 14 of Regulation EU 2016/679.
What is the purpose of this notice?
This Privacy Notice provides mandatory information as required under Articles 13 and 14 of the European General Data Protection Regulation (GDPR) regarding the transparency of personal data processing by BEARING TRUE SOUTH PC when using this website.
This document has been designed in relation to the statutory requirements with regards to our obligations to the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).
What personal data does BEARING TRUE SOUTH collect?
In the course of providing its Services, BEARING TRUE SOUTH collects, uses, and discloses personal data. Personal data is any information that can be used to identify you or that we can link to you. You, as a traveler or user of the Services, may be asked to provide certain personal data when you use our Services. The provision of personal information is voluntary but mandatory in order for us to fulfill the service. Depending on our websites and services, we might collect personal data, such as:
Names, contact and personal information of the travelers or person making an online travel booking (work and home/mobile phone, email, address, gender, age, nationality);
Travel documentation (e.g. passport/visa/drivers license number, expiration dates, citizenship, date of birth, gender);
Payment data on a safe server; and
Logins, user IDs, passwords, IP addresses, and browsing information.
Other personal data supplied by you via email/contact forms, affiliations requests, Job requests, Curriculum Vitae and by registering to our communities, social media or newsletters.
How does BEARING TRUE SOUTH collect personal data?
Directly from you when you access various parts of our Website and Services, including when you communicate with us via email, phone, video call or other channels;
From other sources, for instance, the company which you are an employee of or are otherwise traveling on behalf of ("Company"), including such Company's third parties who may send us your personal data on your or your Company's behalf; and from the network of websites accessible through or utilized by our Services and our company, including third party suppliers and our partners, subcontractors, and agents. This includes personal data we collect automatically through our websites, for instance by using cookies and similar technologies.
The provision of personal information is voluntary.
How does BEARING TRUE SOUTH use personal data?
BEARING TRUE SOUTH limits the use of personal information to the purposes identified in this Policy and for which the individual has provided implicit or explicit consent. We retain personal information for only as long as it is necessary to fulfill the stated purposes, except with the consent of the individual or as required by law.
BEARING TRUE SOUTH uses personal data to:
Provide its Travel Services and fulfill its obligations to travelers or companies representing the travelers (e.g. complete and administer travel reservations, assist in managing the travel, provide reporting, provide notices about your account and the Services, inform you of updates to our website and other changes to our products or Services).
Communicate with you, for instance by email, post, phone or via our website in order to provide you with customer service.
Understand how our websites are used and provide a customized experience as you use our Services, such as by providing interactive or personalized elements on our Services and providing you with content based on your interests (see our Cookies policy for more information).
Fulfill a request made by you or your Company (e.g. reporting, questions, or other requests about your personal data).
Send you newsletters, marketing emails, and other information or materials that may interest you, as well as showing personalized advertisements. Where required, we will obtain your consent before sending such marketing messages or showing personalized advertisements.
Carry out our obligations and enforce your, our, or other's rights as we believe reasonably necessary (e.g. billing and collection, fraud prevention, comply with legal obligations, and respond to legal proceedings or requests from legal authorities and law enforcement or other third parties).
Who does BEARING TRUE SOUTH disclose personal data to and why?
Personal data collected is shared with or disclosed to:
BEARING TRUE SOUTH and its partners, subcontractors, and agents as necessary to fulfill and support the Services, including bookings and assistance, ticket insurance, responding to requests, and assessing or offering promotions.
Third party service providers you or your Company request we send personal data to (e.g. providers who secure compensation for delayed, canceled services on behalf of travelers; safety and tracking information providers;).
Third party service providers to complete travel arrangements and reservations and fulfill the Services (e.g. ground transportation companies, hotels, sailboat charterers, destination management companies, and other related travel suppliers for booking/ticketing purposes; industry reporting authorities; equipment and technology vendors, including, without limitation, online booking tool providers; visa and passport providers; credit card companies and payment collection and processing companies).
How does BEARING TRUE SOUTH store and protect personal data?
BEARING TRUE SOUTH has adopted the following principles to govern its collection and processing of Personal Data:
Personal Data shall be processed lawfully, fairly, and in a transparent manner.
The Personal Data collected will only be those specifically required to fulfill travel, accommodation, or other travel-related requirements. Such data may be collected directly from the Data Subject or provided to BEARING TRUE SOUTH via their affiliates or partners. Such data will only be processed for that purpose.
Personal Data shall only be retained for as long as it is required to fulfill contractual requirements, operate trips or fulfill services.
Personal Data shall be adequate, relevant, and limited to what is necessary for relation to the purposes for which they are collected and/or processed. Personal Data shall be accurate and, where necessary, kept up to date.
The Data Subject has the right to request from BEARING TRUE SOUTH access to and rectification or erasure of their personal data, to object to or request the restriction of processing concerning the data, or to the right to data portability. In each case, such a request must be put in writing.
The Data Subject has the right to make a complaint directly to a supervisory authority within their own country.
Personal Data shall only be processed based on the legal basis except where such interests are overridden by the fundamental rights and freedoms of the Data Subject which will always take precedence. If the Data Subject has provided specific additional Consent to the processing, then such consent may be withdrawn at any time (but may then result in an inability to fulfill travel requirements).
BEARING TRUE SOUTH will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision-making processes.
How long does BEARING TRUE SOUTH keep my personal data?
What about links to third party websites and services?
Does BEARING TRUE SOUTH collect personal data of children?
BEARING TRUE SOUTH does not collect personal data directly from children. Individuals under 18 years of age should not use our Services to submit any personal data about themselves. However, if a booking includes children, we will collect their name, surname and gender as well as any other information required to operate the itinerary or provide our services, just as for any other traveler.
What are my rights with respect to my personal data?
As a Data Subject, you have rights under the GDPR. BEARING TRUE SOUTH will always fully respect your rights regarding the processing of your personal data, and has provided below the details of the person to contact if you have any concerns or questions regarding how we process your data, or if you wish to exercise any rights you have under the GDPR.
You may choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details or to provide false details, your experience with some or all of our Services may be affected.
To the extent required by applicable law, you have the right to access your personal data and confirm the processing of your personal data. Also, where applicable, you have the right to rectify inaccuracies or errors, erase, restrict the processing, object to processing, and withdraw consent to the processing of your personal data, and where applicable, the right to data portability of your personal data.
How can I exercise my rights or make complaints?
BEARING TRUE SOUTH will strive to maintain an accurate and complete record of your personal information for the purposes identified in this Policy. If you believe your personal information may be inaccurate, you may contact us to access your personal information and take steps to verify, update, correct, erase it.
BEARING TRUE SOUTH will respond to your requests to the email address or phone number that you have registered with us or we otherwise have on file for you or any other suitable method. Depending on your request, we may review the request with you and/or your Company to assist in resolving and responding to the request.
We will provide a response within 30 days of receiving an access request.
We are committed to working with you to obtain a fair resolution of any complaint or concern you may have about our use of your personal data. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority in your country (if one exists in your country).
Personal Data: (Article 4 of the GDPR) personal data means any information relating to an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing: (Article 4 of the GDPR): means any operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.
Legal Basis for Processing: (Article 6 of the GDPR): At least one of these must apply whenever personal data is processed: 1. Consent: the individual has given clear consent for the processing of their personal data for a specific purpose. 2. Contract: the processing is necessary for compliance with a contract. 3. Legal obligation: the processing is necessary to comply with the law (not including contractual obligations). 4. Vital interests: the processing is necessary to protect someone's life. 5. Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law. 6. Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual?s personal data which overrides those legitimate interests.
Consent: the individual has given clear consent for the processing of their personal data for a specific purpose.
Contract: the processing is necessary for compliance with a contract.
Legal obligation: the processing is necessary to comply with the law (not including contractual obligations).
Vital interests: the processing is necessary to protect someone's life.
Public task: the processing is necessary to perform a task in the public interest, and the task or function has a clear basis in law.
Legitimate interests: the processing is necessary for the legitimate interests of the Data Controller unless there is a good reason to protect the individual's personal data which overrides those legitimate interests.
Data Controller: (Article 4 of the GDPR): this means the person or company that determines the purposes and the means of processing personal data.
Data Processor: (Article 4 of the GDPR): means a natural or legal person, public authority, agency or any other body which processes personal data on behalf of the controller.
Data Subject Rights: (Chapter 3 of the GDPR) each Data Subject has eight rights. These are:
- The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- The right of access; this is your right to see what data is held about you by a Data Controller.
- The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
- The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ?the Right to be Forgotten?. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
- The right to restrict processing; this gives the Data Subject the right to ask for a temporary halt to the processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
- The right to object; the Data Subject has the right to object to the further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
- Rights in relation to automated decision making and profiling; Data Subjects have the right not to be subject to a decision based solely on automated processing.
Cookies and other web technologies.
Bearing True South uses an email delivery and marketing company to send emails. Pixel tags and cookies are used in those email messages and at our websites to help us maximize the effectiveness of our marketing and our websites. A "cookie" is a small amount of information that a web server sends to your browser that stores information about your account, your preferences and your use of our websites. Pixel tags and web beacons are tiny graphic images placed on website pages or in our emails that allow us to determine whether you have performed specific actions. The data on your use of our site may be linked to the personal Information you have chosen to share with us when you register.
Most internet browsers automatically accept cookies. However, you can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the sites you visit. If you decide not to accept our cookies, your ability to use some features on our site may be impaired.