Drive Botswana Ltd

Our promise to you:

Is to hold your data securely;
Share only where you agree;
Use your data to tailor the information we provide you, arrange your travel arrangements and improve our services;
Put you in control by allowing you to update, delete and access your data;

This policy covers how we collect, use, disclose, transfer and store your data.
Please read the following information carefully. If you book on behalf of others, you are responsible for ensuring that the others are aware of the content of this Privacy Policy and are in agreement with you supplying their personal data to use to make a booking or enquiry. By making a booking or an enquiry, you agree to the transfer, storage and processing of it as necessary. We will take all reasonable steps necessary to ensure your data is treated securely and in accordance with this privacy policy but if you do not agree with this policy we cannot accept your booking.

The personal information we collect and when and why we use it

The sort of personal data we collect will be information such as name, address, email address, telephone number, date of birth, and personal travel arrangements. In addition, we may also be required to obtain your passport details and driving license information to pass on to vehicle suppliers

We will need to collect this information to arrange the travel and other services you are requesting. In some cases, we may also need to collect more sensitive personal data such as information concerning medical conditions, disabilities and special requirements such as dietary requests which may disclose your religious beliefs, so as to be able to consider your particular needs in relation to a booking

How we use this personal information

We use your personal information to:
• fulfil our contract with you and/or deal with your booking or intended booking, including processing your booking, sending you your itinerary or other details relating to your booking
• update you on any changes to your travel itinerary
• manage your wider travel or services requirements (for example, liaising with and transferring your data to service providers and/or travel facilitators so that they can facilitate your booking and/or your travel arrangements so any disruption can be minimised), this includes when you book a holiday package, hotel, vehicle or other service which may be provided by us
• process payments for your booking, fulfil requests for refunds and for accounting or audit purposes
• personalise the service and offers you receive (for example, by being aware of previous travel experiences, transactions or preferences, and tailoring the way we provide our products or services to you based on your preferences and profile)
• communicate and interact with you at different times throughout your journey
• communicate with suppliers, accommodation providers and other parties that are part of your journey regarding your experience, preferences, compliments or complaints
• improve the products and services we offer or help us to create new ones
• conduct customer satisfaction surveys so that we can obtain a better understanding of how we can continue to improve the products and services we offer or help us to create new ones. During these surveys we may collect personal information from you relating to your thoughts/comments about your experience with us

If you have any queries about any of our products or services, compliments or complaints, we will need to collect information from you, including your contact details, in order for us to respond to your query or provide you with assistance. We will collect this information when you, send us an email, phone or contact us via another form of communication such as through social media or an online chat tool.

Personal information we collect and use for legal, compliance, regulatory and crime detection and prevention purposes

We process your personal information so that we can meet our legal, compliance and regulatory obligations, for legal purposes, such as to respond to a valid legal claim, summons or regulatory order, and to protect our property, rights and interests as well as the property, rights and interest of other persons.

Personal information we collect and use from third parties

We collect personal information from third parties who you have authorised to provide your personal information to us (for example, this may be your travel agent or another person making a booking on your behalf, your travel companion or your travel coordinator). We also collect personal information from individuals who may refer you as a friend to our products or services. We ask these individuals to confirm that you are happy to hear from us.

Personal information we collect and use when you are making a payment

We collect different personal information depending on your payment method (such as credit card, bank transfer, cash). For example, for credit card payments we may collect the credit card holder name, address, card number, expiry date and CVC code.

Legal basis for using your personal information

We will only collect, process, use, share and store your personal information where we are satisfied that we have an appropriate legal basis to do this.

Sharing your personal information with others

We share your personal information in the manner and for the purposes described below:
• to improve the products and services we offer or help us to create new ones and for the purposes described in this Privacy Notice.
• with third parties who help us manage our business and deliver our products and services. These third parties have agreed to confidentiality obligations and use any personal information we share with them or which they collect on our behalf solely for the purposes of providing the contracted service to us.
• bank and payment providers to authorise and complete payments;
• with governments, government organisations and agencies, border control agencies, regulators, law enforcement and others as permitted or required by law and to generally comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
• with third parties whose products or services you are purchasing through our us, or otherwise such as tourism agencies, hotel, transfer and car hire companies, tour and excursion providers, including if there is a problem with your booking so that we can resolve it with you;

Transferring personal information globally

We sell travel arrangements to Southern Africa, which means your personal information may be transferred and stored in other countries which may be outside your country of residence. Some of these countries are subject to different standards of data protection than your country of residence.

We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law, and we only transfer personal information to another country where:
• we are satisfied that adequate levels of protection are in place to protect your information; and
• the transfers are fully managed to protect your privacy rights and interests and are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.

To this end:
• where we transfer your personal information outside our company or to third parties (who help us to provide our products and services), we obtain contractual commitments from them to protect your personal information; or
• where we receive requests for information from law enforcement or regulators, we carefully review and validate these requests before any personal information is disclosed.

In the event your personal information is transferred to a foreign jurisdiction, it may be subject to the laws of that jurisdiction and we may be required to disclose it to the courts, law enforcement or governmental authorities in those jurisdictions.
You have a right to contact us for more information about the safeguards we have put in place to ensure the adequate protection of your personal information when this is transferred as mentioned above.

How we protect and store your personal information

Protection of your personal information

We have implemented and maintain appropriate technical and organisational security measures, policies and procedures designed to protect the personal information that you share with us and safeguard the privacy of such information. For example, the measures we take include:
• placing confidentiality requirements on our staff members and service providers;
• destroying or permanently anonymising personal information if it is no longer needed for the purposes for which it was collected; and
• following security procedures in the storage and disclosure of your personal information to prevent unauthorised access to it; and

Storage of your personal information

We keep your personal information for as long as is reasonably necessary for the purposes for which it was collected. For example, to manage bookings and provide you with any relevant products or services, as explained in this Privacy Notice. We will ensure that it is disposed of in a secure manner. In most cases we will destroy your data 7 years after collection in order to comply with UK HMRC rules. Where no booking is made, data will be removed not more than 12 months after collection

In some circumstances we may store your personal information for longer periods of time, for example, where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements. In specific circumstances we may store your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or if we reasonably believe there is a prospect of litigation relating to your personal information or dealings.

Legal rights available to help manage your privacy

You have certain rights in relation to your personal information:

In order to exercise your rights, we may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.

You can exercise your rights by emailing us or by sending us a communication. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request within 30 days or inform you if we require further information in order to fulfil your request.

We may not always be able to fully address your request, for example, if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Right to access personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: the source of your personal information; the purposes, legal basis and methods of processing; the data controller’s identity; and the businesses or categories of businesses to whom your personal information may be transferred.

Right to rectify or erase personal information

You have a right to request that we provide you with a copy of your personal information that we hold and you have the right to be informed of: the source of your personal information; the purposes, legal basis and methods of processing; the data controller’s identity; and the businesses or categories of businesses to whom your personal information may be transferred.

Right to object to the processing (including direct marketing) of your personal information

You have a right to request that we rectify inaccurate personal information. We may seek to verify the accuracy of the personal information before rectifying it.

You can also request that we erase your personal information in limited circumstances where:
• it is no longer needed for the purposes for which it was collected; or
• you have withdrawn your consent (where the data processing was based on consent); or
• following a successful right to object ; or
• it has been processed unlawfully; or
• the personal information must be erased for compliance with a legal obligation under European Union or Member State law to which we are subject.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary:
• for compliance with a legal obligation; or
• for the establishment, exercise or defence of legal claims.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction

You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the European Union.

We may redact data transfer agreements to protect commercial terms.

Right to restrict the processing of your personal information

You can ask us to restrict your personal information, but only where:
• its accuracy is contested, to allow us to verify its accuracy; or
• the processing is unlawful, but you do not want it erased; or
• it is no longer needed for the purposes for which it was collected, but we still need it to establish, exercise or defend legal claims; or
• you have exercised the right to object, and verification of overriding grounds is pending.

We can continue to use your personal information following a request for restriction, where:
• we have your consent; or
• to establish, exercise or defend legal claims; or
• to protect the rights of another natural or legal person.

You have a right to lodge a complaint with the Information Commissioners Office if you have concerns about how we are processing your personal information.

If you have any concerns regarding data that we hold, please contact the Data Controller at info@drivebotswana.com