GDPR Policy

In accordance with the General Data Protection Regulation and related UK data protection legislation, we are committed to protecting the confidentiality and security of the information that you provide to us.

This Privacy Notice is designed to help you understand how we collect and use your information.

If you have any questions or queries about this policy please contact us.

Who we are “Penado” and the “Penado Group” (also referred to in this Notice as “we”, “us”, or “our”) includes Penado International, Penado UK, and Penado Kenya.

How to contact us For any questions or concerns relating to this Privacy Policy or our data protection practices, or to make a subject access or any other request regarding the information we hold, please contact us at:

The Penado Group 85 Timpson Road Portsmouth Hampshire PO1 4JR

Tel: 07961 626 884 email: office@penado.org Website: penado.org

Why we need and how we use your personal information We only collect, use and store your information where we have lawful grounds and legitimate business reasons to do so.

We collect, use and store your personal information in order to fulfil requests for quotes, products and services as part of our tour travel business. It may also be used to verify your identity, to administer payments. If you pay by instalments your information may also be used to arrange credit.

The use of your data is essential for us to book travel tickets and/or excursions. We may also use it to keep our records up to date, to notify you about changes to our service and to help us in developing new products and services.

If you do not provide the information required we are unlikely to be able to arrange your tour and may not be able to provide certain services to you.

We may monitor calls, emails, text messages and other communications with you. When you contact us we may keep a record of that correspondence and any information provided to us during that or any subsequent communication.

Marketing We would like to keep you updated about our relevant products and services by email, SMS and/or telephone. If we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes we will only do so with your consent. Your consent will be obtained specifically at the appropriate time.

If you have already consented and wish us to stop using your information for this purpose or any other purpose then please contact us.

Website The Penado Group is committed to protecting the privacy of users of this website. This statement sets out our policy regarding the collection and use of personally identifiable information, such as name, e-mail and telephone numbers, or other personal details, via the website. Please read this policy to understand how your personal information is collected and used. We will process any personal data you provide in accordance with the Data Protection Act 1998. This statement sets out our current policy which may be subject to change.

Information collected General visitor information such as Internet Protocol addresses and statistics (such as which pages are accessed and when) which are not linked to personally identifiable information is provided to us via our Internet Service Provider. Personal information such as name, e-mail and/or postal address is collected only when you contact us using any of the e-mail links to contacts provided on the site. The nature of information requests and any survey information volunteered may also be collected via this (or other forms) in the future.

Disclosure of information to third parties The Penado Group will not disclose any of your personally identifiable information to any party outside the company, except when we have your permission to do so, or when it is required by law.

Disclaimer We cannot guarantee that data transmission over the Internet is 100% secure. The Penado Group is committed to protecting the privacy of your information, but we cannot guarantee the security of any information you transmit to us, therefore you do so at your own risk.

Nature of personal information Personal data is any information that may identify a living individual. We collect personal information such as name, contact details, and other personal details, depending on the nature of the tour and other services we offer.

Sharing information We will only supply your personal information to other parties where such a transfer is a necessary part of the activities that we undertake, where you give us consent or where we are required to do so by law or regulation (e.g. where the disclosure is necessary for the purposes of the prevention and/or detection of crime).

As an intermediary, we must disclose personal information to third parties, in order to provide our products and services and to enable you to participate in specific tours.

We may also disclose your information to service providers engaged to perform services on our behalf. Such service providers are contractually restricted from using or disclosing the information we give them except as necessary to perform services on our behalf or to comply with legal requirements.

We only share your information if we are satisfied that our partners or suppliers have sufficient measures in place to protect your information in the same way that we do.

We may also disclose personal information to new owners of our business in the event that we are subject to a merger or acquisition. Disclosure may also be made to enable company audits, regulatory inspections or to investigate a complaint, suspicion of fraud or a security threat.

We never share your information outside our organisation for marketing purposes.

You understand that we may disclose the information you provide to relevant other parties for the purposes described in this Notice.

Transfer of personal data outside the UK Certain personal information held on our Information Technology systems may be transferred across geographical borders in accordance with applicable law. By providing us with your information, you consent to the collection, international transfer, storage, and processing of your information. These transfers are governed by the European Union (EU) standard contractual clauses or equivalent data transfer agreements to protect the security and confidentiality of personal information.

How long we keep information about you We will keep your information for as long as it is required to enable us to provide our services to you. Once we decide that we no longer need your information it will be securely and confidentially destroyed.

Your data protection rights You have certain legal rights under UK data protection law and regulations, summarised as follows: • The right to be informed about our data processing activities, including through Privacy Notices such as this. • The right of access to the personal information we hold about you. To request a copy of this information you must make a subject access request in writing to us. • The right of rectification. You may ask us to correct any inaccurate or incomplete data within one month. • The right to erasure and to restrict processing. You have the right to have your personal data erased and to prevent processing except where we have a legal obligation to process your personal information. You should bear in mind that by exercising this right you may hinder or prevent our ability to provide products and services. • The right to data portability. On your request, we will provide you with your personal data in a structured format. • The right to object. You have particular rights in relation to automated decision making and profiling to reduce the risk that a potentially damaging decision is taken without human intervention. You can object to your personal data being used for profiling, direct marketing or research purposes. If you want to invoke any of these rights please write to us:

The Penado Group 85 Timpson Road Portsmouth Hampshire PO1 4JR

email: office@penado.org

Withdrawal of consent Where you have provided your specific consent to the use of personal data, you may withdraw that consent by contacting us:

The Penado Group 85 Timpson Road Portsmouth Hampshire PO1 4JR

email: office@penado.org

How to make a complaint If you wish to make a complaint about how we hold or use your data, please contact us:

The Penado Group 85 Timpson Road Portsmouth Hampshire PO1 4JR

email: office@penado.org

If you are dissatisfied with how we deal with your complaint, you may contact the Information Commissioner’s Office:

The Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF Phone: 08456 30 60 60 Website: ico.org.uk