Last Updated: May 13, 2020
IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS PRIVACY NOTICE
This website is not intended for children and we do not knowingly collect data relating to children. If you are below the age of 16 then you must have your parent’s or legal guardian’s consent to submit any personal data at all. We will promptly delete any personal information relating to minors where we are informed that parental or guardian consent has been granted. Should you be a concerned parent or guardian of a minor who has submitted their personal data without your consent please write to our Data Protection Officer for assistance.
Our full details are:
Full name of legal entity: GVI World Limited
Name or title of DPO: Laura Dix-Bowler
Email address: [email protected]
Postal address: 1 Emperor Way, Exeter Business Park, Exeter, EX1 3QS
Telephone number: +44 1727 250 250
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
YOUR DUTY TO INFORM US OF CHANGES
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS AND SERVICES
This website and our service may include links to third-party websites, plug-ins and services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Such services may include applications like Zoom or Canvas, as required to deliver the service to you. Please note that your personal data as entered into any such service may be visible to other people using the same service and or other people enrolled for the same or a similar program to you. When you leave our website or use any of these third-party resources and services, we encourage you to read their Privacy Policies.
THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
- Identity Data may include first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
- Contact Data may include email address and telephone numbers.
- Transaction Data may include details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data may include internet protocol (IP) addresses, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites and services.
- Usage Data may include information about how you use our websites, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing from us and our third parties and your communication preferences.
- Special categories of personal data may include health data relevant to your program, criminal history as relevant to your travel program.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may be unable to complete your booking or to provide other services to you. We will notify you if this is the case at the time.
HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when you: apply for our Programs or register on the site or the Service; request marketing to be sent to you; provide any other personal information to us directly by post, phone, email or in person; respond to a survey or enter into our promotions and competitions; engage with us via social media; use the Message Board features of the Service and include personal information directly or indirectly (eg. via a display name).
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below :
- Technical Data from the following parties:
(a) analytics providers such as Google Analytics
(b) advertising networks such as Google Adwords, Facebook and Bing
HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to process your application or complete your booking)), vital interests and where relevant “legitimate interests”.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.:
PROMOTIONAL OFFERS FROM US
You will receive marketing communications from us if you have opted to do so while requesting other information from us or when making a booking.
We will get your express opt-in consent before we share your personal data with any company outside the GVI group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in the footer of all marketing messages. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of booking or enrolling in a program.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes of providing services to you or performing our contract with you.
- Suppliers: such as insurance providers,service providers and other entities we work with in order to fulfill our contract with you.
- Third-party vendors: who provide services or functions on our behalf, such as credit card processing, business analytics, support and fraud prevention. Such vendors are not permitted to share or use the information for any other purpose other than performing the specific functions they provide.
- GVI-controlled entities: such as the various operating entities that provide on-the-ground support at our various global program bases.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
NOTICE FOR CALIFORNIA RESIDENTS
Categories of Personal Information that We Collect
Below are the categories of personal information about California consumers that we collect and disclose for a business purpose. We do not sell personal information.
We collect and disclose for a business purpose the following categories of personal information:
- Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
- Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, financial information relevant to your payments, or medical information relevant to your participation in GVI Online.
- Usage Data, including internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
- Education Information, including information about education history or background.
- Protected Classifications, including characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, and citizenship status.
Categories of Sources of Personal Information
The categories of sources of personal information we collect are described in the section How Is Your Personal Information Collected above.
Purposes for Collecting Personal Information
We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Personal Information above.
Categories of Third Parties with Which Personal Information is Shared
We share personal information identified above with the following categories of third parties:
- Our educational partners,
- Third-party providers that serve business, professional or technical support functions,
- Potential employers (as directed by you), or
- Third parties for legal matters or safety purposes.
California Consumer Rights
California law gives California consumers the right to make the following requests:
- The right to opt-out of sale of your personal information. We do not sell personal information.
- The right to request a copy of the personal information that we have collected about you in the prior 12 months.
- The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
- The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.
You can submit a copy, deletion, or right-to-know request online by emailing [email protected] or by contacting us at 1-888-653-6028.
The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data.
Please note that third parties may, however, collect personal information about your online activities over time and across different websites when you visit our Site or use the Service.
As an international travel company and tour operator, GVI has operations in various locations across the world including all the places where our programs are based. As part of the process of processing your application for a program and performing our contract with you your personal data may be transferred outside the European Economic Area (EEA). This could include places whose laws may provide for a lesser standard of protection for your personal data than that provided under European Law. In order to meet the data protection standards of European Law we will only transfer your data using one of the safeguards listed below.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it via at least one of the following safeguards:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. Transfers to suppliers and partners based outside the EEA may also be required such as when GVI assists with visa applications and renewals. Certain licences, permissions and authorisations required in order to participate in our programs and or enter certain controlled areas (such as national parks, partner schools and dive locations) will require a transfer of your personal data to relevant external suppliers and partners. Suppliers and partners are required to adhere to the same standards as GVI when dealing with personal data.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances you can ask us to delete your data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data.
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
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We may collect information about your computer including, where available, your IP address, operating system and browser type for system administration as part of our audit trail process. Most web browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that. You are not obliged to accept cookies and you can adjust your browser's setting to prevent it from accepting cookies on your computer - go to www.allaboutcookies.org for instructions on how to disable cookies. However, you may not be able to take full advantage of our Websites if you do so.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the normal operation of our Site.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We uses Google Analytics, which sets a first-party cookie in order to anonymously identify when users return to specific websites.
Google uses the information sent with this cookie to store a history of website pages visited in a user's session. This data will not be used to associate any part of your identity, anonymous or not, with any other data held by Google.
Further information about how to opt-out of this cookie can be found at https://www.google.com/intl/en/policies/privacy/partners/
From time to time, advertisers may include digital assets which set cookies on an advertiser's domain or on the domain of our Website. These cookies will only store anonymous information about your interaction with a specific advert and will not be used to personally identify you.
We may also share anonymised behavioural data with advertising partners, to improve the quality and relevance of our advertising. This means that when you are on other websites, you might be shown advertising based on your behaviour on our Website. We may also show you advertising on our site based on your behaviour on other sites.
You may find out more information, including how to opt-out of these cookies being set in your browser by visiting http://www.youronlinechoices.com/uk/your-ad-choices
Google Advertising cookies
We use Google Double Click to serve advertisements. Advertisements are received from Google Double Click servers to your browser along with a cookie to anonymously identify you as you visit websites which serve advertising from Google Double Click servers.
In addition to providing website usage data as described above, Google Analytics may also collect anonymous demographic data such as age, gender and interests by placing a Google DoubleClick cookie in your browser. This data is aggregated and anonymised and helps us understand the types of users who visit our site. This cookie may also help us serve advertising tailored to your interests and preferences when you visit our sites or other sites that we advertise on.
More information about this cookie, including how to opt-out of receiving the cookie can be found at http://www.google.com/settings/ads/onweb/
If you opt out of this cookie, you will still see advertising when you visit our sites, but the content of the ads may not be as relevant to you.
We use Facebook technologies such as the Facebook Pixel to show you interest-based marketing content from our brands and selected advertisers if you have viewed a GVI website. Data collected by the Facebook Pixel may also be anonymised and used in aggregate to help improve the quality and effectiveness of our websites and marketing efforts.
You can find out more about Facebook Advertising and manage your Facebook Advertising settings or opt-out of Facebook interest-based advertising at https://www.facebook.com/ads/about/
Facebook Like Button cookies
When you create or log in to an account on http://www.facebook.com cookies are stored on your computer in order to remain logged-in to your facebook account when visiting http://www.facebook.com again.
The Facebook Like Button used on our Website is hosted by Facebook and your browser therefore sends this cookie data to Facebook when creating the button inside your browser. This data is used by Facebook in order to associate the Facebook Like Button with your Facebook account. This information is not accessible to us, and is not sent to us by Facebook.
Twitter Share Button
When you create or log in to an account on http://www.twitter.com cookies are stored on your computer in order to remain logged-in to your twitter account when visiting http://www.twitter.com again. The Twitter Share Button used on our Website is hosted by http://www.twitter.com and your browser therefore sends this cookie data to Twitter when creating the button inside your browser. This data is used by Twitter in order to associate the Twitter Share Button with your Twitter account. This data is not accessible to us, and is not sent to us by Twitter.
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) the site may not perform as expected.
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