PRIVACY POLICY
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privacy policy

This Privacy Policy sets out how we, Lewa Wilderness Trails Ltd (trading as Lewa Wilderness), collect, store and use information about you when you use or interact with our website, https://www.lewawilderness.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from July 2018.

CONTENTS

  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Information we collect when you interact with our website
  • Information collected or obtained from third parties
  • Our use of automated decision-making and profiling
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • California Do Not Track Disclosures
  • Copyright
  •  

SUMMARY

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: Lewa Wilderness Trails Ltd
  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us, providing information through our contact form or by subscribing for our newsletter),
    • from your use of our website, using cookies, and
    • occasionally, from third parties.
  • Information we collect: name, email address, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on and the geographical location from which you accessed our website (based on your IP address).
  • How we use your information: for administrative and business purposes (particularly to contact you), to improve our business and website, to advertise our services, to analyse your use of our website, and in connection with our legal rights and obligations.
  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, where required by law or to enforce our legal rights and obligations.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
  • Use of automated decision-making and profiling: we use automated decision-making and profiling through our use of remarketing advertisements and web analytics. For further information, please see the main section below entitled Our use of automated decision-making and profiling.
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business) and certain additional factors described in the main section below entitled How long we retain your information. For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary.
  • Use of cookies: we use cookies on our website including essential, functional, analytical and advertising cookies. For more information, please visit our cookies policy here: https://www.lewawilderness.com/cookies-policy
  • Transfers of your information outside the European Economic Area: In certain circumstances, we will transfer your information outside of the European Economic Area, including to the United States of America. Where we do so, we will ensure appropriate safeguards are in place, including, for example, that the third parties we use who transfer your information outside the European Economic Area have self-certified themselves as compliant with the EU-U.S. Privacy Shield.
  • Your rights in relation to your information
    • to access your information and to receive information about its use
    • to have your information corrected and/or completed
    • to have your information deleted
    • to restrict the use of your information
    • to receive your information in a portable format
    • to object to the use of your information
    • to withdraw your consent to the use of your information
    • not to have significant decisions made about you based solely on automated processing of your information, including profiling
    • to complain to a supervisory authority
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.
  •  

OUR DETAILS

The data controller in respect of our website is Lewa Wilderness Trails Ltd of C/O Lewa Wildlife Conservancy, Private Bag, Isiolo 60300, Kenya. You can contact the data controller by writing to Lewa Wilderness, C/O Lewa Wildlife Conservancy, Private Bag, Isiolo 60300, Kenya or sending an email to [email protected].

If you have any questions about this Privacy Policy, please contact the data controller.

INFORMATION WE COLLECT WHEN YOU VISIT OUR WEBSITE

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

WEB SERVER LOG INFORMATION

We use a third-party server to host our website called GreenGeeks, the privacy policy of which is available here: https://www.greengeeks.com/legal/privacy Our website server automatically logs the IP address you use to access our website as well as other information about your visit such as the pages accessed, information requested, the date and time of the request, the source of your access to our website (e.g. the website or URL (link) which referred you to our website), and your browser version and operating system.

Our server is located in the Europe. However, GreenGeeks also backs-up data outside of the European Economic Area (EEA) and your data will be transferred and stored on Amazon Web Services (AWS) servers in the United States of America. Their privacy policy is available here: https://aws.amazon.com/privacy/?nc1=f_pr

For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

Use of website server log information for IT security purposes

Our third-party hosting provider collects and stores server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber-attacks, by detecting unusual or suspicious activity.

Unless we are investigating suspicious or potential criminal activity, we do not make, nor do we allow our hosting provider to make, any attempt to identify you from the information collected via server logs.

Legal basis for processing: compliance with a legal obligation to which we are subject (Article 6(1)(c) of the General Data Protection Regulation).

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interests: we have a legitimate interest in using your information for the purposes of ensuring network and information security.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are data files which are sent from a website to a browser to record information about users for various purposes.

We use cookies on our website, including essential, functional, analytical and advertising cookies. For further information on how we use cookies, please see our cookies policy which is available here: https://www.lewawilderness.com/cookies-policy

You can reject some or all of the cookies we use on or via our website by changing your browser settings but doing so can impair your ability to use our website or some or all of its features. For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

INFORMATION WE COLLECT WHEN YOU CONTACT US

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

EMAIL

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).


Legitimate interest(s):
 responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

We use a third-party email provider to store emails you send us. Our third-party email provider is GreenGeeks. You can access GreenGeeks’ privacy policy here: https://www.greengeeks.com/legal/privacy

Emails you send us will be transferred and stored within the European Economic Area on our third-party email provider’s servers in Germany.

CONTACT FORM

When you contact us using our contact form, we collect the following information: your name, email address and any information you include in the message field. We also collect any other information you provide to us when you complete the contact form, including any optional information, such as your telephone number.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

If you do not supply the optional information required by our contact form, such as phone number, then we will not be able to respond to your enquiry by phone.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).
Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Messages you send us via our contact form will be stored the European Economic Area on our third-party email provider’s servers in Germany. For further information, please see ‘Email’ above.

We also back up emails on our third-party servers in the Europe provided by GreenGeeks. You can access their privacy policy here: https://www.greengeeks.com/legal/privacy. However, Flywheel also backs-up data outside of the European Economic Area (EEA) and your data will be transferred and stored on Amazon Web Services (AWS) servers in the United States of America. Their privacy policy is available here: https://aws.amazon.com/privacy/?nc1=f_pr.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

PHONE

When you contact us by phone, we collect your phone number and any information provide to us during your conversation with us.

Legal basis for processing: our legitimate interests (Article 6(1)(f) of the General Data Protection Regulation).

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract (Article 6(1)(b) of the General Data Protection Regulation).

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

Transfer and storage of your information

Information about your call, such as your phone number and the date and time of your call, is processed by our third-party telephone service provider and stored in the United Kingdom.

POST

If you contact us by post, we will collect any information you provide to us in any postal communications you send us.

Legal basis for processing: our legitimate interests (Article 6(1)(f)