AFRICAN FAMILY SAFARIS PTY LTD
March 2019, updated 18 April 2023
African Family Safaris Pty Ltd (AFS) is committed to maintaining your privacy. Keeping your data safe and increasing accountability and transparency are important principles to us.
AFS provides travel knowledge and services designed for travel to African destinations.
AFS is based in Bellingen, New South Wales, Australia.
1. Privacy Legislative Framework
AFS will collect, store, use and disclose Personal Information in accordance with the PPIPA, the Privacy Act and any other relevant laws and codes of practice in operation from time to time including the Regulation.
Australian and New South Wales Legislation
When you interact with AFS and use AFS’s websites, mobile websites or mobile applications, your privacy is protected by the Privacy and Personal Information Protection Act 1998 (NSW) (including the Information Privacy Principles (IPPs)) (PPIPA) and Privacy Act 1988 (including the Australian Privacy Principles (APPs)) (Privacy Act).
General Data Protection (GDPR) Regulation
The Regulation applies to the data processing activities of AFS in the European Union as we offer goods and services or monitor the behaviour of individuals in the European Union and United Kingdom via our website, email and phone. AFS arranges travel to Africa as a tourism destination, and promotes conservation efforts to preserve African wildlife and wilderness areas
2. What is Personal Information or Personal Data?
Personal Information is defined by Australian and New South Wales Legislation and Privacy Principles as namely information or any opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.
Personal Information is also defined by the Regulation in which we provide particulars namely:
• any information relating to an identified or identifiable natural person (Article 4 of the Regulation – a name, location data, an online identifier or one or more factors specific to the physical, physiological, mental, economic, cultural or social identity of that natural person, cookie ID, passport information, location data, advertising identifier on phones, IP address, an email address or a telephone number)
• any information relating to an individual, whether it relates to his or her private, professional or public life. It can be anything from a home address, a photo, an email address, bank details, posts on social networking websites, or medical information.
3. Why AFS collects Personal Information
AFS will only collect Personal Information for a lawful purpose which is reasonably necessary for, or directly related to our function or activities in providing travel services and promoting Africa wildlife areas and for obtaining feedback about the effectiveness of our services. AFS will not collect any more information than is necessary for it to fulfill these functions, unless required by law.
AFS, in carrying out its functions and activities, collects Personal Information directly from you through our website www.africanfamilysafaris.com, via email, telephone calls, video calls or in-person meetings, cookies, and from other publicly available sources for various purposes that relate to the development of our understanding of our travellers and their needs.
The provision of your Personal Information on AFS’s website is voluntary and you can opt out at any time. However, if you choose not to provide your Personal Information we may not be able to forward the material that you are requesting or provide you the services you require to travel with us.
AFS conducts a large part of its operations over the Internet and via email. As part of its functions, AFS liases with travellers and prospective travellers to determine their preferences for travel. We use this personal information to complete the logistics of their travel itinerary. We also communicate news and travel deals with our preferred African suppliers that our database may like to hear about.
4. Collection of your Personal Information
AFS’s collection of Personal Information is performed in an open manner and where consent is obtained. AFS will ensure that any Personal Information collected is relevant to AFS’s purpose, is accurate, complete and up-to-date. AFS will collect information directly from you, unless it is reasonably impracticable to do so.
When is your Personal Information is being collected
Your Personal Information is being collected when:
• you provide Personal Information via email, telephone, video call or at an in-person meeting
• provide guest information when travelling on an itinerary that AFS has arranged. (For people who travel with us we collect names, date of birth, email addresses, home addresses, phone numbers, next of kin, pertinent medical and diet information, passport details, relevant flight information and travel insurance information).
• request to be added to an email distribution list
• This list is not exhaustive.
Email addresses are recorded when an email message is sent to AFS or when a user subscribes to an online mailing list. These email addresses are stored electronically in accordance with standards and authorities under the State Records Act 1998 (NSW). An email address is only used for the purpose for which it is provided and is not added to any unauthorised mailing list or disclosed to other organisations unless you request that this to be done. If you have subscribed to one of AFS’s online mailing lists, you can easily remove your email details from the list by unsubscribing. Each mailing list provides clear instructions on how to unsubscribe.
“Pixels” means the use of use of pixels (1 x 1 pixel images that allow services to tell companies how many people have visited their site). When you take a certain action on our website, a request is sent to the server to download the tracking pixel attached to the content you’re interacting with. It’s an invisible process to you but the data collected will help us build content experiences for you. All information collected is de-identified and we will never collect or disclose any personal information.
There are risks associated with the transmission of information over the internet and you should therefore make your own assessment of the risks in the provision of your information to AFS’s website. Where the website contains links to other organisation’s web pages, AFS is not responsible for the information handling practices or privacy policies of those other organisations. AFS’s website may utilise cookies to enhance the user’s experience of the site. A cookie is a small text file that is sent back to your computer’s hard drive from a host website. Cookies record your preferences in relation to your use of a site and provide other information that allows us to recognise you in the future. You can set your browser to notify you when you receive a cookie, giving you the chance to decide whether or not to allow it. However, if you decide to not accept cookies, some of AFS’s web pages may not display properly or you may not be permitted to access certain information. When you access any of the pages on the website, we automatically record information that identifies, for each page accessed:
a. the IP (Internet Protocol) address of the machine which has accessed it
b. your top-level domain name (for example .com, .gov, .au, .uk etc.)
c. the address of your server
d. the date and time of your visit to the site
e. the pages accessed and documents downloaded
f. the previous site visited
g. the type of browser and operating system you have used.
The information collected during each visit to our website is aggregated with similar logged information and used to manage its website services and identify patterns of usage of the sites. This will assist us in improving AFS’s website. AFS will not disclose or publish information that identifies individual computers, or potentially identifies sub-groupings of addresses, without consent or otherwise in accordance with the PPIPA.
How will your Personal Information be stored?
This data is stored internally, at AFS offices and held securely and accessible by AFS staff only. Information is stored using Apple Mac, Microsoft and Google Systems and software. For event attendees and persons travelling on an AFS itinerary, data is accessible by affiliated suppliers, in connection with the activity they are undertaking.
AFS takes all reasonable steps to:
• protect the security and integrity of any Personal Information held, be it stored in electronic or hard copy format.
• Ensure that the quality of Personal Information is as reasonable in the circumstances and that the Personal Information that AFS collects is accurate, up-to-date and complete.
• As are reasonable in the circumstances, ensure that the Personal Information that AFS uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up-to-date, complete and relevant.
• Ensure that you have access to and ability to correct Personal Information.
How long will your Personal Information be stored?
AFS will store your information as per the mandatory data retention laws in Australia, or as otherwise required by law. If your personal information is sensitive, the retention time will be as appropriate. Should you provide consent for a longer retention period, we will hold your data in line with your consent.
Once it is no longer necessary to retain the information, we will dispose of it in a secure manner.
5. Processing and Use of Personal Information within AFS
The Regulation will directly affect the processing of personal data of European Union citizens resident in the European Union, including those in the United Kingdom.
The processing of any personal data belonging to European Union citizens or others resident in the European Union will be subject to the Regulation no matter where the data is stored or processed.
AFS will only use, communicate or handle Personal Information for the primary purpose for which the information was collected, or in circumstances where you consent to other use of your Personal Information. This includes processing for:
• the performance of a contract.
• compliance with a legal obligation.
• protect the vital interests of the data subject or of another natural person.
the performance of a task carried out in the public interest or in the exercise of official authority vested in AFS.
• the purposes of the legitimate interests pursued by AFS or by a third party unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data, in particular if the data subject is a child.
Examples of data processing:
• access to/consultation of a contacts database containing personal data
• sending promotional emails
• posting/putting a photo of a person on a website
• storing IP addresses or MAC addresses
AFS will need to comply with certain principles as follows:
Process the data in a manner that is lawful, fair and transparent.
Use the data for legitimate purposes.
Limit the use only to what is necessary.
Process the data in a way that maintains its accuracy.
Store the data for no longer than necessary.
Process the data in a secure fashion.
6. Disclosure of Personal Information to third parties
AFS will not disclose your Personal Information to anyone without your consent unless legally required to do so. For guests travelling on an AFS itinerary, your relevant personal information is shared with the specific African suppliers that will be executing your travel plans on the ground in Africa.
The circumstances in which AFS will collect, use and disclose more extensive information than stated above in the following circumstances:
a. unauthorised attempts to access files which are not publically available
b. unauthorised tampering or interference with files on the listed websites
c. unauthorised attempts to index the contents of the listed websites
d. attempts to intercept messages of other users of the listed websites
e. communications which are defamatory, abusive, vilify individuals or groups or which give rise to a suspicion that an offence is being committed
f. attempts to otherwise compromise the security of the web server, breach the laws of the State of New South Wales or Commonwealth of Australia, or interfere with the use of the our website by other users.
AFS reserves the right to make disclosures to relevant authorities where the use of the listed websites raises a suspicion that an offence is being, or has been, committed. In the event of an investigation, AFS will provide access to data to any law enforcement agency that may exercise a warrant to inspect our logs. AFS may initiate proceedings in relation to any loss or damage suffered as a result of unauthorised use of information or any of the above circumstances. Disclosure may also occur where it is lawfully authorised or required under any act, other law or statutory agency or foreign body. AFS does not have any responsibility for privacy policies or practices of third party sites linked to from the listed websites.
8. Access, accuracy and amendments – your rights
AFS takes all reasonable steps to ensure the Personal Information it collects is accurate, complete and up-to-date. Accordingly and as required by the PPIPA, you can access any of your Personal Information that we hold, except in the circumstances set out in appropriate legislation. If you would like to access or update your Personal Information, or if you would like to know more about the Personal Information that we may hold on you please e-mail us at email@example.com.
If you wish to make a complaint in relation to privacy, you may do so by contacting:
The Privacy Officer
Phone: +61 405 454 9211
Or to The Privacy Commissioner, via www.ipc.nsw.gov.au
Under the Regulation, you have certain rights including:
• Right of Access
• Right of Erasure
• Right to Rectification
• Right to Object
• Rights in relation to automated decision making and profiling
If you wish to exercise any of these rights, please contact the following:
The Privacy Officer
Phone: +61 405 454 9211
9. Conclusion and Other
AFS provides this privacy management plan in compliance with the PPIPA (Privacy Management Plan). This Privacy Management Plan sets out how AFS complies with the PPIPA.
Due to the developing nature of privacy principles for online communication, this policy may be modified or expanded in light of new developments or issues that may arise from time to time. The amended policy will be posted to our website and will operate from the time it is posted.