What is the purpose of this policy?
Fajga Travel processes daily tours and activities and we are committed to protecting your privacy. This notice sets out details of the information that we collect about you, how we process it, to whom we disclose it, and your rights under data protection law in relation to our processing of your data.
This policy covers personal data that is collected through our Platform, through our mobile sites and applications, and through booking engines that are integrated into third party websites. Although you should bear in mind that where you access our booking engine on a third-party website, this data protection notice only applies to information we collect through your use of the booking engine, and does not apply to data collected or held by the operator of the third party website.
Who controls the use of your personal data?
When this data protection notice mentions “we”, “us”, “our” or “Fajga Travel” we are referring to Fajga Travel SARL . This is Morocco company that operates the booking platform that allows you to make reservations, and is in charge of the processing of your personal data.
You can contact us using the details at the end of this notice with regards to any queries in relation to the processing of your personal data.
What personal data is collected?
In order for us process your booking we will ask you for certain information, such as your name, your email address, your payment information and booking details. We also collect certain information from the device you use to access our website, such as your IP address, what browser you use and what type of device you are using. In addition to the information that we collect ourselves, we sometimes receive information that is collected on our behalf by third parties, such as when you see a Fajga Travel advert displayed on a third party site.
Information that you give to us:
Most of the personal data that we collect about you will be information that you have given to us yourself. This might include:
• Account – If you set up an account with us, we will store details of your username and password, your settings preferences (e.g. language, currency and distance units), your past trips and any wish lists that you create.
• Booking Details – When you make a booking we will ask you for information that we need in order to process the booking. This will include your name, email address, nationality, gender, mobile number and your payment details.
• Queries and Complaints – If you contact our Customer Service team with a query or a complaint, we will record details of the query or complaint and how it is dealt with on our systems.
• Reviews – If you leave a review in relation to a trip, this will be linked to your Fajga Travel account, which means we will treat it as containing your personal data.
• Email Marketing – When we collect your email address we will record your preferences regarding receipt of marketing emails from us in relation to our own products and services and those of third parties.
Personal information that we collect automatically:
When you use our websites, mobile apps or booking engines we use various technologies to automatically capture details about the device you are using and how you interact with our platforms. This information includes:
• Device Details – We automatically collect details about the device you are using, including its IP address, its device ID, the browser you are using, and the operating system that the device uses.
• How You Interact With Our Site – We record details about how you use our websites and mobile apps, like the date and time that you visit, what pages you visit, how long you stay on the pages, where you have clicked on a page, and details of any crashes or system bugs you might encounter.
• How You Got Here – Where we can, we record how you arrived on our website (e.g. from a search engine, or by clicking on one of our adverts).
Personal information we receive from other sources:
Although we mainly collect information directly from you, there are circumstances where we collect information from third party sources. These circumstances include:
• Affiliates – We operate an affiliate program under which third parties advertise our website on our behalf. If you click on one of those advertisements you are directed to our website using a technology that allows us to understand which affiliate referred you. We then track if you make a booking, and if you do we attribute that booking to the affiliate for the purposes of paying them a commission. However, we don’t provide the affiliate with any personal information in relation to you.
• Property – If there are any issues with your trip, the trip provider might contact us with information about the issue.
• Advertisements – When we work with third parties to display advertisements we may use technologies like cookies or pixel tags to record details of your interaction with those advertisements. This data is sometimes sent to us through cookies and pixel tags that are set on our behalf by those third parties.
Why do you use my personal data?
As you probably expect, the main reason we use your personal data is in order to process your bookings and to deal with any queries or issues that arise in relation to those bookings. We also use your personal data for a number of other reasons, such as tailoring adverts and our marketing emails so they are relevant to you, monitoring your use of our websites and apps to help us make improvements, and to provide the additional services that we make available on our website and apps.
Bookings – We use your personal data in order to process bookings with trip providers, and to let you manage your bookings through our platform. Where we process personal data for this purpose we will do so either on the basis that we have a contractual duty to do so, or on the basis of our legitimate interests in providing the booking service.
• Queries and Complaints – When you send us a query in relation to a booking, or if you have a complaint in relation to a property, we will process your personal data in order to answer your query or in order to resolve your complaint. Where we process personal data in the context of a query or complaint we will do so on the basis of our legitimate interest in resolving customer queries and complaints. If you volunteer data in relation to your health, we will process that personal data on the basis that you consent to us using it in order to resolve your query or complaint.
• Reviews – When you provide a review for a trip we will publish this on the property’s page on our website, and on some of our partners’ sites. We will display the text of your review, alongside details of your gender, age range, home country and number of previous reviews. If you have not opted to be anonymous, we will also display your username alongside your review. Our processing of your personal data in order to make reviews available is on the basis of our legitimate interest in making the review system available to our users.
• Providing and Improving our Services – Where we collect data in relation to your use of our services, such as your device details and how you interact with our services, we use this data in order to deliver our services and personalize your experience (e.g. if you turn on location services on your mobile device, we will use this as part of the search function). We also use the data to test new features that we are thinking about introducing, to analyze how our website is used, and to evaluate and improve our services. If we find a problem on our websites or apps, we will use your data in order to fix any bugs that we find. We may also process your personal data as part of our development work, where we take a copy of our database and test our code on that before rolling it out to the live version of the database. Where possible we use this data on an anonymous basis, but sometimes this might not be possible. All of this processing of your personal data is on the basis of our legitimate interests in operating, improving and securing our services.
• Analysis/Reporting – We use data in relation to bookings in order to create internal reports regarding how our business is operating, such as determining how what we have spend on advertising affects the number of bookings that are made. We also use this data for other commercial analysis purposes, and to try to predict future trends that may affect our business. This processing is undertaken on an aggregated basis, so you are not identifiable from the reports or analysis that is produced.
• Advertising – We always want to ensure that when you see a Fajga Travel advert it will be relevant to you and your interests, whether the advert appears on a website we operate, in our marketing emails or on a third-party site. We may also use the same information to show you adverts for carefully selected third-party products and services. We do this in a number of ways, either ourselves or through the use of third-party advertisers:
◦ Segmentation – When we develop some of our advertising campaigns we have certain groups of people in mind who we want to see the advert. This might be people in a particular age range, people who have made a booking recently, or people from a particular geographic location or who speak a particular language. We use the data that we hold in order to create groups of people that we then display an advert to, or ask our third-party advertising partners to display an advert to. We process your personal data in connection with creating these groups of people on the basis of our legitimate interests in ensuring that our advertising, or the advertising of third parties, is effective.
◦ Audience Matching – Some of our advertising partners, like Facebook, Instagram and Google, provide a feature that helps us to identify if we have customers or users in common. Rather than sharing personal data with our advertising partners in order to find out if we have customers or users in common, we actually share what is known as a “hash” of the data that we hold (such as an email address). A hash is created by a computer program that converts data into a string of numbers and letters, but only operates in one direction. This means that you can’t use a hash to find out the underlying information, but if you run the hash on the same data you always get the same results. Our advertising partners compare their hashes with the hashes we send them, and if there is a match you are added to our custom audience. The hashes are then deleted by the advertising partner. We use audience matching to enable us to show you more relevant adverts, or to ensure that we don’t show you an advert that isn’t relevant to you. We process your personal data in connection with audience matching on the basis of our legitimate interests in ensuring that our advertising, or the advertising of third parties, is effective.
• Emails and App Notifications – Where we have collected your email address in the context of providing you with a service and you have not opted out of receiving email marketing, we may send you emails that we think will be useful to you. This may include our regular e-newsletter, special offers, travel tips, customer surveys and information about products and services offered by us. If you have given your consent, we will send you offers from selected third parties. These emails may include advertising that has been tailored using other information that we hold about you, as set out above in the ‘Advertising’ section. Where your settings on your device permit us to send app notifications we may also send you app notifications containing similar information. You may opt out of receiving email messages at any time by clicking on the link provided in the email messages, and app notifications can be disabled by changing the notification settings in your app. Although when we send you an email or app notification this may in certain circumstances be on the basis of your consent, for all other purposes our processing of your personal data in connection with those emails or app notifications is on the basis of our legitimate interests in ensuring that our advertising is effective.
• Affiliate Program – We operate an affiliate program under which third parties advertise our website on our behalf. If you click on one of those advertisements you are directed to our website using a technology that allows us to understand which affiliate referred you. We then track if you make a booking, and if you do we attribute that booking to the affiliate for the purposes of paying them a commission. However, we don’t provide the affiliate with any personal information in relation to you. We process your personal data in connection with our affiliate program on the basis of our legitimate interest in operating an effective commission based affiliate advertising program.
Information you are required to provide
You are not obliged to provide us with any of your personal data. However, if you want to make a booking you will need to provide us with the information that is indicated as required on our checkout page. If you don’t provide us with this information, we won’t be able to process your booking.
Who do we share your personal data with?
In order to process your booking we have to send your details to the property that you have booked. This includes making your credit or debit card details (not including the CVV code, which we do not store) available to the property in order for them to take payments where this is required (e.g. the charges that are applicable if you fail to show up at a property and have not cancelled your booking in accordance with the property’s cancellation policy). If you purchase an ancillary service we may need to share personal data with the third-party service provider so that they can provide you with that service.
As part of our online advertising programs we may share your personal data with third parties, who will combine it with data that they hold about you in order to tailor adverts that appear on third-party websites (which may be our own adverts, or adverts we serve on behalf of third parties). Where this data is shared you are not directly identifiable from the information itself, as we use technologies that use non-personally identifiable codes and tags.
We also use a number of service providers to assist us in providing our services, some of whom will have access to your data (e.g. we use various software service providers who host our data as part of their services). Where we engage a third party to process your data on our behalf, we make sure that they respect your privacy rights and that they process data in accordance with data protection law.
◦ Payment Processors – We use third-party payment processors in order to assist us with taking payments on our website.
◦ Customer Relationship Management – We use a third-party provider to host our customer relationship management system, which our Customer Services team uses to record all contacts that you have with us and how we have resolved your queries and complaints.
◦ Technology Providers – This includes service providers who provide services that help us to secure our network, systems and emails. It also includes providers of services that enable us to undertake particular tasks, such as surveys or market research, or to implement our advertising programme.
• Third-Party Advertisers – When we purchase advertising on third-party websites we may share information with them about your use of our services, which they then combine with the information that they hold about you in order to implement the particular advertising campaign. The data that is shared with third-party advertisers relates to how you use our websites and apps, such as the pages you have visited, the searches you have made, and whether you have made a booking. We use specialist service providers to help us purchase advertising, and to transfer the information about your use of our services to third party advertisers that is required for those third party advertisers to be able to show you the correct advert.
• Ancillary Services – We sometimes work with partners to make services available to you that we think will be useful, such as travel insurance. If you avail of one of these services we may need to provide your details to that third party in order to allow them to provide the service. We may also share non-personally identifiable information with the third party to enable them to track that we referred you to them.
Retention of personal data
The record retention policy operates on the principle that we keep personal data for no longer than is necessary for the purpose for which we collected it, and in accordance with any requirements that are imposed on us by law. This means that the retention period for your personal data will vary depending on the type of personal data.
• Email Marketing – We will keep a copy of personal data that is required in order to send you marketing messages for as long as you are subscribed to receive those marketing messages. We will also retain certain information in relation to your transactions in order to allow us to customize our marketing messages. If you are subscribed to receive marketing messages and your transaction data is anonymized in our main database, we will continue to retain certain details in relation to your transactions, such as where you have booked properties before, what types of property you have booked, whether you have used our apps or our websites, your average length of stay, and what countries you have made bookings for and in.
For personal data that is not transaction data or related to email marketing, we will apply the following criteria:
• Managing legal claims – When we assess how long we keep personal data we take into account whether that data may be required in order to defend any legal claims which may be made. If such data is required, we may keep it until the statute of limitations runs out in relation to the type of claim that can be made (which varies from 2 to 12 years).
• Business requirements – As we only collect personal data for defined purposes, we assess how long we need to keep personal data for in order to meet our reasonable business purposes.
Important Information about Consent
When we process your personal data on the basis of your consent, you are free to withdraw that consent at any time. You can withdraw your consent by contacting us using the contact details at the bottom of this notice. If your consent relates to receiving email marketing you can use the unsubscribe link in the email, or if it relates to app notifications you can turn off app notifications using your device settings. Please note that if you withdraw your consent we may not be able to continue to provide the related service to you.
Your rights under data protection law
You have various rights under data protection law in connection with our processing of your personal data. For example, you have the right to request a copy of your personal data that we hold and to request that we correct any errors in the personal data that we hold. These rights are subject to certain exceptions and exemptions.
You have the following rights under data protection law:
• Right to access your personal data – You have the right to request a copy of the personal data that we hold about you, together with other information about our processing of that personal data.
• Right to rectification – You have the right to request that any inaccurate data that is held about you is corrected, or if we have incomplete information you may request that we update the information so that it is complete.
• Right to erasure – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the right to be forgotten.
• Right to restriction of processing or to object to processing – You have the right to request that we no longer process your personal data for particular purposes, or to object to our processing of your personal data for particular purposes.
• Right to data portability – You have the right to request us to provide you, or a third party, with a copy of your personal data in a structured, commonly used machine readable format.
Other Relevant Privacy Policies
Some of our third party advertising partners ask us to make you aware of their privacy policies. These policies are available by following the links below. (URL’s updated as of last update of Policy)
Questions and Complaints
If you have any queries or complaints in connection with our processing of your personal data, you can get in touch with us using the following contact information:
Email: support@fajgatravel.com