PRIVACY POLICY
Travelers Information
Trini Riddim Privacy Policy Notice
USER INFORMATION
Privacy Policy page is a guide to explain how and when Trini Riddims Cultural Tours collects and uses personal information. This Privacy Policy works in conjunction with other important guidelines. Therefore, it should be viewed along with our Travel Information guide, Cookies Policy and our terms and conditions guidelines. In order for us to serve you in the best ways possible with updated information about what is required before and during your travel and vacation perio
Updated April 5, 2023
PRIVACY INTRODUCTION
Welcome to the TRINI RIDDIM CULTURAL TOURS privacy notice. TRINI RIDDIM CULTURAL TOURS respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you provide personal data to us via our website or by other means (such as over the telephone or email) and the policy tells you about your privacy rights and how the law protects you.
By using the TRINI RIDDIMS website (www.triniriddim.com or contacting us (via our website or by other means), you consent to the data practices described in this statement.
You have the right to deny consent to us processing your personal data. However, without your consent, we won’t be able to make the necessary arrangements to provide the travel services that you request.
You also have the right to withdraw your consent at any time. However, this may prevent us from providing the travel service you have booked, we will be required to treat any withdrawal of consent as a cancellation of your booking and the cancellation policy in our Booking Terms and Conditions will become payable.
1. IMPORTANT INFORMATION AND WHO WE ARE
(A) PURPOSE OF THIS PRIVACY NOTICE
This privacy notice aims to give you information on how TRINI RIDDIM CULTURAL TOURS collects and processes your personal data, including any data you may provide through this website (www.triniriddim.com) or through any other means (such as over the telephone or by email).
This website is not intended for children and the only circumstances in which we collect data relating to children, is when you make a booking of travel services and you have children in your party.
It is important that you read this privacy notice together with any other privacy notice (such as the TRINI RIDDIM CULTURAL TOURS COOKIES POLICY) we may provide on specific occasions about how we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
(B) CONTROLLER
TRINI RIDDIM MEDIA is the controller and responsible for your personal data (collectively referred to as TRINI RIDDIM, TRINI RIDDIMS CULTURAL TOURS, “we”, “us” or “our” in this privacy notice). We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
CONTACT DETAILS FOR PRIVACY MANAGER
Full name of legal entity:
TRINI RIDDIM MEDIA
Name or title of data privacy manager:
Attn: Privacy Manager
Address:
Building 3, 43-45A Pelican Extension Road, Port of Spain 230914 Trinidad
Email:
Telephone number:
1(868) 686 8200
You have the right to make a complaint at any time to the Data Protection Act, Chap. 22:04 of the Laws of the Republic of Trinidad and Tobago (‘Data Protection Act’), the Trinidad and Tobago supervisory authority for data protection issues (https://agla.gov.tt ). We would, however, appreciate the chance to deal with your concerns before you approach the AGLA so please contact us in the first instance
(C) CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY
TO INFORM US OF CHANGES
This document was created on 28th August 2022.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change, during the course of your relationship with us.
(D) THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. 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. When you leave our website, we encourage you to read the privacy notice of every website you visit.
2. 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 as follows:
(A) IDENTITY DATA
This includes data relating specifically to your identity, such as your first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender.
(B) CONTACT DATA
This includes data relating to how you may be contacted, such as your billing address, delivery address, email address and telephone numbers.
(C) FINANCIAL DATA
This includes data relating to your means and methods of payment, such as your bank account and payment card details.
(D) TRANSACTION DATA
This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of services you have purchased from us.
(E) TECHNICAL DATA
This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
(F) USAGE DATA
This includes information about how you use our website, products and services.
(G) MARKETING AND COMMUNICATIONS DATA
This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.
(H) AGGREGATED DATA
We collect, use and share data such as statistical or demographic data for some purposes. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this privacy notice.
(I) SPECIAL CATEGORIES OF PERSONAL DATA
We collect the following special categories of personal data about you. We collect and process the data below only where it is strictly necessary to do so in order to deliver the travel service that you have purchased.
Details about your:
- dietary requirements which may disclose your religious or philosophical beliefs;
- marital status or relationship and
- health condition.
3. HOW YOUR PERSONAL DATA IS COLLECTED
We use different methods to collect data from and about you through:
(A) DIRECT INTERACTIONS
You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, social media, email or otherwise. This includes personal data you provide when you:
- make a booking of travel services;
- subscribe to our newsletter or other publications;
- request our brochure be sent to you;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback.
(B) AUTOMATED TECHNOLOGIES OR INTERACTIONS
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.
We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookies policy for further details.
(C) THIRD PARTIES
We may receive personal data about you from various third parties as set out below:
Technical Data from the following parties:
- analytics providers such as Google based outside Trinidad and Tobago;
- fonts providers such as Google based outside Trinidad and Tobago;
- Internet security providers such as Cloudflare based outside Trinidad and Tobago;
- Providers of software to create and manage your website such as WordPress based outside Trinidad and Tobago;
- advertising networks such as Facebook based outside Trinidad and Tobago;
- search information providers such as Google and Bing based outside Trinidad and Tobago;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services; and
- Identity and Contact Data from data brokers or aggregators.
4. 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 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.
(A) PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal data where more than one ground has been set out below.
Activity
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer.
(a) Identity; (b) Contact.
Performance of a contract with you.
To process and deliver your booking including:
Manage payments, fees and charges;
Collect and recover money owed to us.
(a) Identity; (b) Contact; (c) Financial; (d) Transaction; (e) Marketing and Communications.
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
To manage our relationship with you including:
Notifying you about changes to our terms or privacy policy;
Asking you to leave a review or take a survey
(a) Identity; (b) Contact; (c) Profile; (d) Marketing and Communications.
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to recover debts due to us).
(c) Necessary to comply with a legal obligation.
To enable you to partake in a prize drawing, competition or complete a survey.
(a) Identity; (b) Contact; (c) Profile; (d) Usage; (e) Marketing and Communications.
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).
To administer and protect our business and this website including: troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data.
(a) Identity; (b) Contact; (c) Technical.
(a) Necessary for our legitimate interests (for running our business, provision administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise);
(b) Necessary to comply with a legal obligation.
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you.
(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences.
(a) Technical (b) Usage
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform ourmarketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you.
(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile
(a) Performance of a contract with you;
(b) Necessary for our legitimate interests (to develop our products/services and grow our business)
(B) MARKETING
You will receive marketing communications from us if you have requested information from us or purchased services from us and, in each case, you have not opted out of receiving that marketing.
(C) THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any company for marketing purposes.
(D) OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data that you have provided to us as a result of a purchase of travel services or other such transactions.
(E) COOKIES
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.
(F) 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.
5. DISCLOSURES OF YOUR PERSONAL DATA
We may have to share your personal data with the parties set out below for the purposes set out in the table in Section 4a above.
- Internal Third Parties as set out in the Glossary;
- External Third Parties as set out in the Glossary;
- Specific third parties; and/or
- Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
6. INTERNATIONAL TRANSFERS
Your Personal Information may be transferred, stored, accessed, and processed in any country where we engage service providers, and by using our services you consent to the transfer of information to countries outside of your country of residence, which may have data protection rules that are different from those of your country.
EUROPEAN RESIDENTS: Transfers of Data Outside Europe
Please note that if you are resident in the UK, European Union or European Economic Area (“EEA”) we hold your personal information outside of the EEA. For instance, your personal information may be held by us in Trinidad and Tobago.
We may also need to transfer your personal information to service providers and other third parties outside of the EEA. Countries outside of the EEA may not have the same level of privacy laws as exist in the UK, United States and the EEA. We will take reasonable steps to ensure that your privacy rights are protected.
For all other transfers of data that are unrelated to the provision of travel services to you, whenever your personal data is transferred outside the EEA, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented:
- 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
7. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.
8. DATA RETENTION
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 addition to the above, by law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data. (See Request erasure below for further information) 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.
9. YOUR LEGAL RIGHTS
TO INFORM US OF CHANGES
Under certain circumstances, you have rights under the 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 your personal data.
- 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 the processing of your personal data.
- You have the right to 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 your personal data.
- This enables you to ask us to suspend the processing of your personal data in the following scenarios;
- if you want us to establish the data’s accuracy;
where our use of the data is unlawful but you do not want us to erase it;
- 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
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use i
- Request transfer of your personal data.
- 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.
- Right to withdraw consent.
- You have the right to 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 at: [email protected].
(A) FEES
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.
(B) INFORMATION REQUEST
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.
(C) RESPONSE TIME
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.
10. GLOSSARY
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.
Any information regardless of their nature, and format, relating to an identified or identifiable person
Personal data which reveal the racial or ethnic origin, political opinions, religious or philosophical beliefs or union membership of the person concerned or relating to his health, including his genetic data
The legal standard used by a court used to determine if a company has a relevant stake in the processing of personal data.
The processing of 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.
The processing of your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Someone who is not one of the main people involved in a business agreement. For us, third parties may include, but is not limited to:
- hotels/guesthouses, restaurants, tour providers, and all other suppliers of travel services;
- Service providers acting as processors based in the US and Trinidad and Tobago who provide IT and system administration services; and/or
- Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the US or Trinidad and Tobago who provide consultancy, banking, legal, insurance and accounting services.