We are committed to safeguarding your privacy.
This policy applies where we are acting as a Data Controller with respect to your personal data; in other words, where we determine the purposes and means of the processing of that personal data.
In this policy, “we”, “us” and “our” refer to Nomad Advisors Ltd, for “theHotel” Zanzibar White Sands Luxury Villas & Spa.
1. HOW WE USE YOUR PERSONAL DATA.
1. In this Section 1 we have set out:
1. the general categories of personal data that we may process;
2. the purposes for which we may process personal data; and
3. the legal bases of the processing.
2. We may process data about your use of our website and services (“usage data“).The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services.
3. We may process your service data (”service data“).The service data may include your email address, first name, last name, title,phone number, address, state, province, postal code, and city. The source of the account data is your booking. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you.
4. We may process information contained in any enquiry you submit to us regarding goods and/or services (”enquiry data“).The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you.
5. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (”transaction data“). The transaction data may include your contact details, your card details, payment detail sand the transaction details. The
transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business and your booking.
6. We may process information contained in or relating to any communication that you send to us (”correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping.
7. In addition to the specific purposes for which we may process your personal data set out in this Section 1,we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or inorder to protect your vital interests or the vital interests of another natural person.
8. Please do not supply any other person's personal data to us, unless we prompt you to do so.
2. PROVIDING YOUR PERSONAL DATA TO OTHERS.
1. We may disclose your personal data to any member of our group of companies this means our subsidiaries, our ultimate holding company and all its subsidiaries insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.
2. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage,managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. We may disclose Email Contact data to Mailchimp insofar as reasonably necessary for email purposes.
4. Financial transactions relating to our website and services may be handled by our payment services providers,Direct Pay Online We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
6. In addition to the specific disclosures of personal data set out in this Section 2, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
3. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA.
1. In this Section 3, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
2. We have offices and facilities in Gibraltar. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
3. The hosting facilities for our website are situated in Gibraltar. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
4. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.
4. RETAINING AND DELETING PERSONAL DATA.
1. This Section 4 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. We will retain your personal data as follows for a minimum period of one year following the transaction date .
4. Notwithstanding the other provisions of this Section 4, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
5. THIRD-PARTY SERVICE PROVIDERS.
1. We work with third party service providers (“Service Providers”) to provide application development, hosting,maintenance, payment and other services for us. These third parties may have access to or process your information as part of providing those services for us. Generally, the information provided to and gathered by these Service Providers are limited to that which is reasonably necessary for them to perform their functions, and we require them to agree to maintain the confidentiality of such information.
6. DATA CONTROLLER AND DATA PROCESSOR.
1. We do not own, control or direct the use of any of the information stored or processed by the Service Providers.Only they are entitled to access, retrieve and direct the use of such information depending on the service that they provide. A service provider isn't aware of what information is actually being stored or made available by another third-party service provider, and does not directly access such information or data except as authorized by you or as necessary to provide the services.
2. Because we do not collect or determine the use of any personal data by the Service Provider, and because we do not determine the purposes for which such personal data is collected, the means of collecting such personal data, or the uses of such personal data, were not acting in the capacity of data controller in terms of the GDPR and do not have the associated responsibilities under the GDPR. We should be considered only as a processor on behalf of our Service Providers and users as to any information containing personal data that is subject to the requirements of the GDPR. Except as provided in this Policy, we do not independently cause information containing personal data stored in connection with the Services to be transferred or otherwise made available to third parties, except to third party subcontractors who may process such data on our behalf in connection without Services. Such actions are performed or authorized only by you.
The Service Provider is the data controller under the GDPR for any information containing personal data. This means that you or the relevant user controls the manner such personal data is collected and used as well as the determination of the purposes and means of the processing of such personal data.
4. A user who seeks to access,correct, amend, delete inaccurate data or withdraw consent for further contact should direct his query to the Service Provider.
1. We may update this policy from time to time by publishing a new version on our website.
2. You should check this page occasionally to ensure you are happy with any changes to this policy.
3. We will notify you of changes to this policy by email or through the private messaging system on our website
8. YOUR RIGHTS.
1. In this Section 8, we summarized the rights that you have under data protection law. Some of the rights are
complex, and not all of the details have been included in our summaries.Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
2. Your principal rights under data protection law are:
1. the right to access;
2. the right to rectification;
3. the right to erasure;
4. the right to restrict processing;
5. the right to object to processing;
6. the right to data portability;
7. the right to complain to supervisory authority;
8. the right to prevent automated decision-marking and
9. the right to withdraw consent.
3. You have the right to confirmation as to whether or not we process your personal data and, where we do,access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data.Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
5. In some circumstances, you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment,exercise or defence of legal claims.
6. In some circumstances, you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person;or for reasons of important public interest.
7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10. To the extent that the legal basis for our processing of your personal data is:
1. consent; or
2. that the processing is necessary for the performance of a contract to which you are party or in order to take stepsat your request prior to entering into a contract,
3. and such processing is carried out by automated means, you have the right to receive your personal data from using a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
13. You may exercise any of your rights in relation to your personal data by written notice to us in addition to the other methods specified in this Section 8.
9. ABOUT COOKIES.
1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
2. Cookies may be either“persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. COOKIES THAT WE USE.
1. We use the following cookies for the following purposes:
11. COOKIES USED BY OUR SERVICE PROVIDERS.
12. MANAGING COOKIES.
1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
2. Blocking all cookies will have a negative impact upon the usability of many websites. If you block cookies, you will not be able to use all the features on our website.
13. SPECIAL NOTE REGARDING CHILDREN.
1. Our services are not intended for children or minors under the age of 18 years without the permission of a parent or guardian. Children under such age must not use the services offered on it to submit any individually identifiable information about themselves without the permission of and direct supervision by their parents or legal guardians.
2. If you believe that a child has submitted personally identifiable information on or through the services without the consent and supervision of a parent or guardian, please contact us so that we can take appropriate action.
14. GOVERNING LAW AND JURISDICTION.
15. OUR DETAILS.
1. This website is owned and operated by Nomad Advisors Ltd..
2. We are registered in Gibraltar under registration number
106047, and our registered office is at Hadfield House,
Library Street, Suite 7
3. Our principal place of business is at Paje beach, Zanzibar, Tanzania.
4. You can contact us:
1. by post, to Hadfield House,Library Street, Suite
3. by telephone, on +44 207 1932716; or by email, using