PRIVACY POLICY

Legal entity: EMT South Africa (Pty) Ltd trading as Explore More Travel

Company registration number: 1950/037811/07

Physical / registered address: 4 Cavendish Place, Claremont, Cape Town, South Africa

Telephone: +27 21 205 8205 Email: info@exploremoretravel.com

Website Terms page: www.exploremoretravel.com/tour-booking-terms-and-conditions/

Privacy / Information Officer contact: Warren Weitsz

ABOUT THIS POLICY

This Privacy Policy explains how Explore More Travel collects, uses, shares, stores and protects personal information. It is intended to meet South African POPIA transparency requirements and, where applicable, recognised international data-protection standards including the EU GDPR and UK GDPR.

1. Who We Are and When This Policy Applies

1.1 Explore More Travel (“EMT”, “we”, “us” or “our”) is a South African tour operator and travel consultancy providing tailor-made travel and destination management services to local and international clients.

1.2 For purposes of the Protection of Personal Information Act 4 of 2013 (“POPIA”), EMT acts as a Responsible Party where it determines why and how personal information is processed.

1.3 This Policy applies to personal information relating to prospective clients, clients, travellers, website visitors, agents, business partners, suppliers and other individuals with whom EMT interacts.

1.4 Where the EU General Data Protection Regulation (“GDPR”), UK GDPR or another mandatory privacy law applies to a particular processing activity, EMT will respect the additional rights and requirements imposed by that law to the extent applicable.

2. The Personal Information We May Collect

2.1 The information we collect depends on the enquiry, booking, service or relationship. It may include:

Identity and travel-document information: name, title, date of birth, nationality, gender where relevant to a booking, passport or identity details, passport issue/expiry information and copies of travel documents where reasonably necessary.
Contact information: email address, telephone number, residential or postal address, country of residence and emergency contact details.
Travel information: destinations, dates, itineraries, flights, accommodation, transfers, activities, golf or safari arrangements, rooming information, loyalty details, travel preferences and special requests.
Financial and transaction information: quotations, invoices, payment confirmations, refunds, credits, transaction records and billing details. Banks and payment providers may separately process payment information under their own privacy and security requirements.
Communications: enquiry forms, emails, messages, booking forms, meeting or call notes, feedback, complaints and other correspondence.
Website and technical information: IP address, browser/device information, website interactions, referring pages and cookie or similar identifiers where used.
Business and supplier information: professional contact details, company details, contracts, commercial correspondence and payment information relating to business partners or Suppliers.

3. Special Personal Information and Children

3.1 Travel arrangements can require information that is more sensitive, including health, accessibility, mobility, allergy or dietary information, religious dietary requirements, or other information reasonably necessary to arrange safe and appropriate travel services.

3.2 EMT will only process special personal information where permitted by law and where it is reasonably necessary for the relevant purpose. We aim to collect only the minimum information needed and share it only with recipients who reasonably need it for the service.

3.3 Where a Traveller is under 18 years of age, EMT may need to process information such as the child’s name, date of birth, passport details, nationality, travel arrangements, special requirements and other information reasonably necessary for the booking. For EMT’s booking process, the child’s required Booking Form and privacy acknowledgement must be completed by a parent or legal guardian who has legal authority to act on the child’s behalf. EMT may request reasonable proof of that authority where necessary. Personal information concerning children will be processed only where permitted by POPIA or other applicable law, including where the prior consent of a competent person or another lawful basis applies.

4. How We Collect Personal Information

4.1 We may collect personal information:

directly from each adult Traveller when they complete EMT’s mandatory individual Booking Form, and directly from you when you contact us, request a quotation, complete an enquiry, confirm travel arrangements, make a payment or communicate with our team;
from a Lead Booker, family member, employer, travel agent, golf club, tour organiser or other person for preliminary enquiry, quotation or booking-planning purposes; however, such information does not replace the requirement for each adult Traveller to complete their own Booking Form;
from a parent or legal guardian completing the required Booking Form and providing information on behalf of a Traveller under 18 years of age;
from travel Suppliers and partners where information is needed to administer, change or support a booking;
from publicly available or business sources where appropriate for a legitimate business purpose; and
automatically through our website and digital services where cookies or similar technologies are used.

4.2 Before individual Booking Forms are completed, a Lead Booker or other authorised person may provide preliminary information about other Travellers so that EMT can prepare quotations, check availability or begin arranging services. That person should ensure they are authorised to provide the information where required and should make the affected Travellers aware of this Privacy Policy.

4.3 Each Traveller aged 18 years or older must personally complete and submit EMT’s required Booking Form. In doing so, the adult Traveller provides their own required personal and travel information and acknowledges this Privacy Policy. A Lead Booker cannot replace this requirement by completing or accepting the form on behalf of another adult Traveller.

4.4 Where the Traveller is under 18 years of age, the required Booking Form and privacy acknowledgement must be completed by a parent or legal guardian authorised to act on the child’s behalf. The parent or legal guardian is responsible for ensuring that the information supplied is accurate and that any additional parental consent, guardianship, immigration or minor-travel documentation required for the trip is obtained.

4.5 Travellers and parents or legal guardians acting for minors should ensure that personal information supplied to EMT is complete, accurate and kept up to date. Incorrect or incomplete information may affect EMT’s ability to arrange or deliver travel services.

5. Why We Use Personal Information and Our Lawful Basis

5.1 We process personal information only where there is a lawful and legitimate reason to do so. Depending on the circumstances, this may include consent, steps requested before entering a contract, performance of a contract, compliance with a legal obligation, protection of legitimate interests, or another basis permitted by applicable law.

Purpose	Examples	Typical lawful basis
Enquiries and quotations	Understand requirements, prepare proposals, check availability and communicate recommendations.	Requested pre-contract steps, legitimate interests and/or consent where required.
Bookings and travel services	Receive and administer mandatory Traveller Booking Forms; reserve accommodation, flights, transfers, activities, golf, safari and other services; issue itineraries and support travel.	Contractual necessity and legitimate operational interests.
Health, accessibility and emergencies	Arrange special requirements and assist during emergencies or disruptions.	Consent or another lawful ground applicable to special personal information; vital interests where appropriate.
Finance and administration	Invoices, payments, refunds, accounting, tax, fraud prevention and business records.	Contract, legal obligation and legitimate interests.
Customer service and legal matters	Handle complaints, disputes, claims, insurance matters and protect legal rights.	Contract, legal obligation and legitimate interests.
Marketing	Send permitted travel news, destination inspiration and offers.	Consent or the lawful existing-customer basis, where applicable.
Website and security	Operate and secure the website, diagnose issues and understand usage.	Legitimate interests and consent for non-essential cookies where required.

5.2 Where we rely on consent, you may withdraw it at any time. Withdrawal does not affect processing that was lawful before consent was withdrawn, and it does not prevent processing that is permitted on another lawful basis.

6. Who We May Share Information With

6.1 Travel services necessarily involve third parties. We may share relevant personal information, where reasonably necessary and lawful, with categories of recipients including:

hotels, lodges, resorts, villas and other accommodation providers;
airlines, charter operators, transfer companies, vehicle-rental providers and other transport operators;
safari operators, guides, golf courses, activity providers, restaurants and destination-management or ground-handling partners;
travel agents, tour operators and other authorised booking partners;
visa, immigration, insurance or emergency-assistance providers where applicable;
banks, payment processors, accountants, auditors, legal advisers and insurers;
booking, CRM, itinerary, cloud-hosting, email, IT, cybersecurity and other technology providers acting for or with EMT;
government, regulatory, law-enforcement or judicial authorities where disclosure is required or permitted by law; and
another party where you have authorised the disclosure or it is otherwise permitted by law.

6.2 We aim to disclose only the information reasonably necessary for the relevant purpose. Independent travel Suppliers may determine their own processing purposes and may operate under their own privacy policies and applicable laws.

6.3 Where a third-party provider processes personal information on EMT’s instructions as an operator or service provider, EMT will take reasonable steps to require appropriate confidentiality and security protections.

7. International Transfers

7.1 Because EMT arranges international travel, personal information may need to be transferred from South Africa to Suppliers, service providers or authorities in other countries. For example, passport or booking information may need to be sent to an airline, hotel, lodge or ground handler in the destination.

7.2 Where personal information is transferred outside South Africa, EMT will seek to ensure that the transfer is permitted under section 72 of POPIA, which may include adequate legal or contractual protections, the data subject’s consent, contractual necessity or another lawful transfer basis.

7.3 Where the GDPR, UK GDPR or another international privacy regime applies, EMT will use any additional transfer safeguard required by that law where applicable.

7.4 Some travel services cannot reasonably be booked or delivered without providing necessary Traveller information to recipients in the destination concerned.

8. How Long We Keep Personal Information

8.1 EMT retains personal information only for as long as reasonably necessary for the purpose for which it was collected, to provide or support travel services, to comply with legal and financial record-keeping duties, to resolve disputes and claims, to prevent fraud and to protect legitimate legal or business interests.

8.2 Retention periods vary by record type. We determine them by considering statutory retention requirements, contractual obligations, limitation or claims periods, the sensitivity of the information, operational need, whether a booking proceeded, and whether information can be securely deleted or de-identified.

8.3 Sensitive information such as passport copies or medical/special-requirement information should not be retained longer than reasonably necessary for the relevant travel or legal purpose. Booking Forms, Terms and Conditions acceptance records and related acknowledgements may be retained for an appropriate period where reasonably necessary to administer the booking, demonstrate the contractual record, resolve disputes or claims, comply with legal obligations and protect legitimate legal interests.

9. Security of Personal Information

9.1 EMT takes reasonable and appropriate technical and organisational measures to protect personal information against loss, damage, unauthorised destruction, unlawful access, unauthorised processing, alteration and disclosure.

9.2 Safeguards may include access controls, password and authentication measures, role-based permissions, secure cloud systems, endpoint/security software, backups, staff confidentiality obligations, staff training, secure disposal and incident-response procedures.

9.3 No electronic or physical security system can guarantee absolute security. EMT therefore reviews safeguards and responds to identified risks as reasonably required.

10. Personal Information Breaches

10.1 If EMT becomes aware of a compromise affecting personal information, we will assess, contain and manage the incident and take the notification steps required by applicable law.

10.2 Where POPIA requires notification, EMT will notify the Information Regulator and affected data subjects as soon as reasonably possible after discovery of the compromise, subject to any lawful delay or direction.

11. Direct Marketing

11.1 EMT will not treat acceptance of a booking or these travel Terms and Conditions as blanket consent to electronic marketing.

11.2 Electronic direct marketing will be sent only where permitted by law, including where appropriate consent has been obtained or where the recipient qualifies as an existing customer for EMT’s own similar services under applicable law.

11.3 Marketing communications will provide a reasonable method to opt out. You may also ask us to stop electronic marketing at any time by contacting us at the details in clause 16.

11.4 Opting out of marketing does not prevent EMT from sending operational communications necessary to administer an enquiry, booking, payment, disruption or other existing service relationship.

12. Cookies and Website Technologies

12.1 Our website may use cookies and similar technologies for essential functionality, security, preferences, analytics and, where used, marketing or advertising purposes.

12.2 Strictly necessary cookies may operate without consent where permitted by law. Where consent is required for non-essential cookies, EMT will seek to provide a suitable method to accept, reject or manage those cookies before they are activated.

12.3 Third-party website services may process information under their own privacy terms.

13. Your Privacy Rights

13.1 Subject to applicable law and any lawful limitations, you may have the right to:

ask whether EMT holds personal information about you and request access to it;
request correction or updating of inaccurate or incomplete information;
request deletion or destruction where legally permitted;
object to certain processing and object to direct marketing;
withdraw consent where processing is based on consent;
request information about recipients or categories of recipients who have received your personal information;
lodge a complaint with the Information Regulator or another competent supervisory authority; and
where the GDPR, UK GDPR or similar law applies, request restriction, erasure, portability or exercise other rights provided by that law.

13.2 Adult Travellers ordinarily exercise their own privacy rights in relation to their personal information. Where the data subject is under 18 years of age, an appropriately authorised parent, legal guardian or other competent person may exercise applicable rights on the child’s behalf where permitted by law. We may need to verify identity and authority before acting on a request. A request may also be limited where EMT is legally required or entitled to retain information, or where another person’s rights or confidential information would be affected.

14. Automated Decision-Making

14.1 EMT does not ordinarily make decisions that produce legal or similarly significant effects on Travellers solely through automated processing. If this changes, affected individuals will be provided with the information and rights required by applicable law.

15. Third-Party Websites and Services

15.1 Our website, itineraries and communications may contain links to independent third-party websites or services. EMT does not control their privacy practices and recommends reviewing the relevant provider’s privacy information before supplying information directly to them.

16. Contacting EMT About Privacy

16.1 Questions, objections, access/correction requests or other privacy concerns may be directed to EMT’s Information Officer:

Information Officer: Warren Weitsz

Privacy / POPIA email: warren@exploremoretravel.com

Physical address:4 Cavendish Place, Claremont, Cape Town, South Africa

Telephone: +27 21 205 8205

General email: info@exploremoretravel.com

17. PAIA and Formal Access to Records

17.1 A request for formal access to records may be dealt with under POPIA and/or the Promotion of Access to Information Act 2 of 2000 (“PAIA”), as applicable.

18. Information Regulator (South Africa)

18.1 If you believe your personal information has been processed unlawfully, you may contact EMT first so that we can investigate the issue. You also have the right to lodge a complaint with the Information Regulator (South Africa).

Information Regulator (South Africa)
Woodmead North Office Park
54 Maxwell Drive
Woodmead, Johannesburg, 2191
South Africa
Telephone: 010 023 5200 | Toll Free: 0800 017 160
General enquiries: enquiries@inforegulator.org.za
POPIA complaints: POPIAComplaints@inforegulator.org.za

19. Changes to This Privacy Policy

19.1 EMT may update this Privacy Policy to reflect changes in law, our business, technology, Suppliers or processing activities. The current version and last-updated date will be published on our website.

19.2 Where a change materially affects how we use personal information and applicable law requires additional notice or consent, EMT will take the steps required by that law.