1. OVERVIEW
Your privacy is
very important to PCG TRAVEL and we understand how important it is to you. We
want you to feel safe when visiting our websites or using our services and are
committed to maintaining your privacy when you do. We require our employees,
suppliers and partners to maintain confidentiality in accordance with
applicable data protection laws.
This privacy
notice with our terms and conditions & our cookie policy and any other
documents referred to herein sets out the basis on which we process any
personal data we collect from you, or that you provide to us (“Privacy
Notice”). Please read the following carefully to understand our views and
practices regarding your personal data.
This Privacy
Notice can be changed over time to comply with law or to meet our changing
business requirements. The most up-to-date Privacy Notice can be found on our
website. We will inform you appropriately of any relevant changes to this
Privacy Notice.
For the purposes
of the General Data Protection Regulation, the controller is PCG TRAVEL Doha,
State of Qatar (from now on referred to as "PCG TRAVEL",
"we", or "us").
PCG TRAVEL has
adopted an ‘opt-in' policy where you can decide whether you would like to
receive our newsletters and offers. You may submit a request to withdraw your
consent at any time by contacting PCG TRAVEL .
2. DEFINITIONS
By "Personal
Data" we mean any information relating to an identified or
identifiable natural person.
3. WHEN DOES THIS PRIVACY NOTICE
APPLY?
This Privacy
Notice applies to the processing by PCG TRAVEL of all Personal Data we gather
or use in connection with your relationship with us as a customer or potential
customer of our destination management company when you use our website, (from
now on referred to as our "Website"), services provided by us or
others acting on our behalf and when you interact with us. We will only use
your Personal Data in accordance with this Privacy Notice.
4. WHO IS RESPONSIBLE FOR YOUR
PERSONAL DATA?
4.1 PCG TRAVEL is
responsible for the processing of all Personal Data described in this Privacy
Notice. In this Privacy Notice we explain what Personal Data we process and for
what purposes, and to which persons or entities the Personal Data will be
provided.
4.2 Our Website
may contain links to enable you to visit third-party websites, mobile sites and
mobile applications. Please note that we do not have any control over these and
are not responsible or liable for the protection and privacy of any information
that you provide whilst visiting those sites. Third-party websites, mobile
sites and mobile applications are governed by their own privacy policies and
not this Privacy Notice.
5. HOW WE COLLECT AND RECEIVE PERSONAL
DATA
5.1 We may collect and receive Personal Data directly from
you or from your authorized representative(s) or from third parties (e.g. your
travel agent or our service providers). We may also collect Personal Data of
your relatives or principal where you disclose Personal Data on their behalf,
including when you:
(a) use any of our services, including when you travel or book a
tour, transfer or stop-over with us;
(b) use or access our Website, particularly when completing
the "customer details" section during the course of a booking, even
if you do not complete the booking;
(c) communicate with us such as by email, telephone, in
writing or through our customer services pages or social media platforms.
5.2 We may also collect your Personal Data through our
Website and other channels including PCG TRAVEL’s airport desk and Third party
providers or subcontractors where you have consented to providing your Personal
Data to them or where we subcontract them to assist us in providing services to
you (e.g., transfers or special requests).
5.3 Where you disclose Personal Data on behalf of another
person, you undertake and will ensure that the individual whose Personal Data
is supplied to PCG TRAVEL has authorized the disclosure, is informed of and
consents to the terms and conditions of this Privacy Notice. Where the
disclosure is in respect of a child’s Personal Data, you should do as only as
the parent or legal guardian of that child and enter into relevant contracts on
behalf of that child.
6. WHY DO WE USE YOUR PERSONAL DATA?
6.1
When you interact with PCG TRAVEL (online or offline)
(a)
For answering your questions or responding to your complaints or requests [READ
MORE]
(i) What does this mean?
If you get in touch with us in person, through email, by
telephone, in writing or through our customer care services pages or social
media, your Personal Data is collected only to the extent necessary to reply to
and answer your question or to respond to your complaints or requests (e.g. to
assist you in processing a transaction or to provide technical assistance).
(ii) What are our legal grounds for doing this?
We will process your Personal Data based on the performance
of our service provision contract with you or in our legitimate business
interests in providing customer care to you based on your request.
(iii) Which Personal Data do we use for this purpose?
We may use your Personal Data including special categories
of Personal Data; for example full name, contact details, email address,
country of primary residence, gender, date of travel, origin, special requests
such as wheelchair assistance, your health information (if needed), your
correspondence with PCG TRAVEL about your question and all other Personal Data
necessary to answer your question.
6.2
For the performance of a contract
(i) What does this mean?
When you book products and services (including tours,
transfers or stop-overs) with us offered through our website, we process your
Personal Data for administrative purposes such as:
(a) administrating your bookings;
(b) delivery of our products and services, including
stop-overs, hotels, transfers, tours and transit tours.
We also use your Personal Data in order to deliver products
or services that we have agreed to provide to you, such as stop-overs, hotels,
transfers, tours and transit tours. As part of our service to you we provide
you with informational emails regarding the relevant service.
By using our services, our website and by providing any
Personal Data to us, you agree to your Personal Data being sent to and
processed in countries outside of your country of residence, and for
individuals resident in the European Economic Area ("EEA"), this
includes transfers outside of the EEA. Some of these countries may not have
data protection laws that provide an equivalent level of data protection as the
laws in your country of residence. Please refer to Clause 8 of this Privacy
Notice for more details.
When you make a booking, you will be provided with a
booking reference. Disclosing your booking reference to other persons may allow
them to access your booking details through our system.
(ii) What are our legal grounds for doing this?
We will process your Personal Data based on our contract
with you and any other contracts that you have with our Third party service
providers. We will also process your personal data on the basis of our
legitimate interests in offering a wide variety of services to you to enhance
your travel experience. If you provide Personal Data on behalf of someone else
(e.g., making a booking on behalf of an adult or a child), you enter into a
contract on behalf of that child or adult.
(ii) Which Personal Data do we use for this purpose?
We process your personal details such as name and date of
birth, gender, nationality, contact details such as address and email address,
payment and credit information and other data you have provided us during the
booking process.
6.3
For the development and improvement of our products and/or services
(i) What does this mean?
It’s important for us to uphold the PCG TRAVEL brand. In
order to achieve this, we use your Personal Data so that we can assess, Analysis
and improve our services to you.
For this purpose, we keep track of how often you read our
newsletters, visit our website, which pages you click on and what services you
purchase through our website.
We also regularly use surveys to find out whether you are
satisfied with our service. These surveys are conducted through our website. We
use your responses to surveys for quality assessments and to improve your
customer experience.
(ii) What are our legal grounds for doing this?
We will process your Personal Data based on the performance
of our contract with you or in our legitimate business interests in enhancing
our services to you.
(iii) Which Personal Data do we use for this purpose?
For this purpose, we use your contact details such as your
nationality, email address, name, age and any correspondence with us. In
addition, we may use the Personal Data you entered into the Website or based on
the functionalities of the Website and the technical data from your device such
as its IP-address, the pages you visited on our websites, your click-through
and surf behaviour and the length of your session.
If you choose to participate in our surveys, we can ask you
to provide us with Personal Data, such as age group, gender and preferences in
terms of choice of services and experiences. We can also use the Personal Data
that you have provided in the survey for this purpose.
6.4
For compliance with law and to monitor and investigate compliance
(i) What does this mean?
PCG TRAVEL needs to comply with certain legal obligations
and monitors its Website and IT systems to check compliance with PCG TRAVEL’s
internal policies and regulations. During monitoring activities, your Personal
Data can be accessed and viewed by PCG TRAVEL or PCG TRAVEL group IT systems
personnel or by third party regulators or government authorities.
(ii) What are our legal grounds for doing this?
We will process your Personal Data based on:
(a) our legitimate business interests in maintaining
adherence to our company policies and the standards which we uphold for our
employees, suppliers and partners; and
(b) our legal obligation to comply with the applicable laws
and regulations.
(iii) Which Personal Data do we use for this purpose?
For this purpose, any Personal Data that is stored on our
IT systems can be accessed and viewed by PCG TRAVEL or PCG TRAVEL group IT
systems personnel or by third party regulators or government authorities for
compliance purposes. The Personal Data that is accessed and viewed will not be
stored for compliance purposes, unless we need them to further investigate
6.5
Your choices
(a) If you participate in Contests, to manage your
participation
(i) What does this mean?
If you give us your consent to do so, we can send you
emails with invitations to participate in prize contests, events, competitions
and/or games of chance (collectively “Contests”). If you choose to participate
in any Contest, we need your Personal Data to allow you to participate, to
administer the Contest, where you are a winner to inform you of this, to
process the delivery of and distribution of the prizes and to measure the
response to Contests.
(ii) What are our legal grounds for doing this?
We will process your Personal Data based on the terms and
conditions of the Contest. If you decline to provide this information, we will
not be able to register or enter you into the relevant Contest or award you a
prize if you have been successful.
(iii) Which Personal Data do we use for this purpose?
Where we are the organizer or sponsor of the Contest, we
process your name, address, email address, passport copy, your country of
residence, proof of residence, age verification documentation, personal
identification documentation, signature and your entries in the Contest. Please
refer to the terms and conditions of the relevant Contest
for specific details of the Personal Data processed. In
accordance with the terms and conditions of the relevant Contest we may also
share your Personal Data with third party sponsors of prizes in order to
administer the prizes to you.
(b) Only if you subscribe to our mailing list, for sending
you relevant information about PCG TRAVEL
(i) What does this mean?
We will occasionally inform you about our special offers,
news and new products and may invite you to participate in Contests via the
email address you provide us. You will only receive our newsletters if you
subscribe to this mailing list.
(ii) What are our legal grounds for doing this?
We will ask for your consent to send you personalized
newsletters.
(iii) Which Personal Data do we use for this purpose?
We process your name and email address, your preferences
and interests, (including those that you have actively shared with us, but also
those inferred through your registered interactions with our website), (please
see our Cookie Policy for more information), shopping history (both online if
you link your purchases to your profile, and offline when making an offline
purchase), and the links you click on in our emails.
7. COOKIES
Cookies are small
files of information which save and retrieve information about your visit to
our website – for example, how you entered our site, how you navigated through
the site and what information was of interest to you. Read more about how we
use cookies in our Cookie Policy which is available on our website.
8. WHO HAS ACCESS TO YOUR PERSONAL
DATA?
8.1
Access to your Personal Data within PCG TRAVEL Group
As a global organization, data we collect may be
transferred internationally throughout PCG TRAVEL . We may disclose your
Personal Data to our shareholders and any member of our group for business and
administrative purposes.
Within the PCG TRAVEL group, we may share your Personal
Data in order to offer you a complete package of services and products such as
hotel bookings or meet and greet services. We may send the Personal Data stored
in this Website to countries whose data protection laws may not be as extensive
as those in the EEA. PCG TRAVEL or PCG TRAVEL employees are authorized to
access Personal Data only if necessary to serve the applicable purpose and to
perform their jobs.
8.2
Access to Your Personal Data by Third Parties
When you make a booking or other purchase, we use support
and other functions which may require the transfer of your Personal Data to and
from countries outside of your country of residence from time to time,
including outside of the EEA.
To provide you with our services, we may be required to
disclose certain of your Personal Data in the following cases:
(a) to you or those acting on your behalf. Where local
regulations require, we may obtain your consent in writing for the purpose of
allowing anyone else to act on your behalf;
(b) to third parties including, partners connected with PCG
TRAVEL, other service providers including those who are acting as our agent or
sub-contractor, including, without limitation, hoteliers, insurance companies,
medical assistance providers, credit card and credit reference agencies, data
processing service providers and our legal and other professional advisors;
(c) to third parties in connection with a proposed or
actual financing, securitization, insuring, merger, restructure, sale,
acquisition, assignment or other disposal of all or part of our business or
assets or the assets of any affiliate or to anyone whom we may transfer our
rights and/or obligations for the purposes of evaluating and performing the
proposed transaction;
(d) to third parties, including law enforcement officials,
law courts and government and regulatory authorities: (a) if we believe
disclosure is required by any applicable law, regulation or legal process (such
as to respond to subpoenas or judicial orders); or (b) to protect and defend
our rights, or the rights or safety of third parties, including to defend
against legal claims; and/or
(e) where you have made a booking, to customers under the
same booking as you.
In addition, your Personal Data may be processed and stored
by these Third party service providers in order to perform the air transport or
other contract.
Organizations that are based outside of the EEA may not be
subject to the same level of controls in regard to data protection as exist
within the EEA. When third parties are given access to your Personal Data, we
will take the required contractual, technical and organizational measures to
ensure that your Personal Data is only processed if necessary for the relevant
purpose. We use reasonable efforts to ensure that third parties will only
process your Personal Data in accordance with applicable law.
Please note that third parties have their own privacy
policies. We suggest that you review those policies if your travel plans
include third party services.
8.3
The use of your Personal Data by our data processors
When a third party
processes your Personal Data based on PCG TRAVEL’s instructions, it acts as a
data processor. We enter into an agreement with the relevant data processor for
the processing of your Personal Data. In this agreement, we include obligations
to ensure that your Personal Data is processed by the data processor solely to
provide services to us and to ensure that the data
9. HOW DO WE KEEP YOUR DATA SAFE?
Safeguards
PCG TRAVEL has taken adequate safeguards to ensure the confidentiality and
security of your personal data. We are committed to ensuring that your Personal
Data is secure. In an effort to prevent unauthorized access to, or disclosure
of, your Personal Data, we have put in place physical, technical, and
administrative safeguards to protect your Personal Data against accidental or
unlawful destruction or accidental loss, damage, alteration, unauthorized
disclosure or access, as well as all other forms of unlawful processing
(including, but not limited to, unnecessary collection) or further processing.
In order to protect the security of your information, where necessary, we use
encryption technology when processing Personal Data.
Children
Except for required passenger details, we do not
intentionally gather Personal Data about children. We are not able to identify
the age of persons who access and use our website or subscribe to our
newsletters. If you believe we have inadvertently collected Personal Data about
your child or if the child has provided us with Personal Data without parental
or guardian consent,
the parent or guardian should contact us, and we will erase
the Personal Data and where relevant unsubscribe the child.
Retention
We will retain Personal Data for as long as it is necessary
to fulfil the purpose for which it was collected, the legal or business
purposes of PCG TRAVEL as described in this Privacy Notice and in line with our
data retention policies, or as required by relevant laws.
When erasing Personal Data, we will take commercially
reasonable and technically possible measures to make the Personal Data
irrecoverable or irreproducible in accordance with the applicable laws.
10. CONTACT US – UNSUBSCRIBING FOR
NEWSLETTERS
If you no longer
want to receive our newsletters, you can unsubscribe at any time by clicking
the ‘unsubscribe’ link in any email containing our newsletter, which will be
effective immediately.
When raising a
request to unsubscribe by e-mail, call or post, it may take up to 30 working
days to process your request and to update our systems to remove your email
address from our mailing list.
After processing
your request, PCG TRAVEL will not send you any further newsletters, our special
offers or news via email and you will be marked as unsubscribed in our mailing
list.
11. FOR DATA PRIVACY MATTERS CONTACT
OUR DATA PROTECTION OFFICER
You can request access, rectification, review of processing, restriction or
erasure of your Personal Data that PCG TRAVEL processes at any time. In certain
circumstances you will also have the right to data portability, meaning that
you have the right to receive your personal data in a structured, commonly used
and machine-readable format to transmit the data to another controller. We will
not charge a fee to respond to your request unless the request may be deemed as
manifestly unfounded or excessive. Any request must include the following
information: your name and address and any other information which may identify
you. Where your request relates to a booking, please provide your booking
reference, the dates on which the service took place and any other relevant
information that will assist us in identifying your booking.
If you added
information to your PCG TRAVEL account about yourself, then you can also access
your relevant PCG TRAVEL account profile to access, correct or remove it
yourself.
We will make
reasonable efforts to revise any Personal Data that is incorrect, and to update
or change your information or preferences, as permitted by law. It may take
several weeks to implement the changes.
If you feel that
we do not comply with applicable privacy rules you have the right to lodge a
complaint with a competent data protection authority. Should you have any
questions about the processing of your Personal Data or this Privacy Notice,
please send an email to info@pcgtravel.com