Privacy Policy

Background and scope

Z Travel is a travel agency. We need to collect, use, and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic, and procedural safeguards to protect personal information in our care.

This Privacy Notice (“Notice”) sets out how this Z Travel business or application processes and protects the privacy of your personal information.

What personal information do we collect?

Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.

Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related products and/or services on your behalf.

We therefore typically collect the following types of personal information about you:

• Identifiers

• contact information (such as name, residential/mailing address, telephone number, email address)

• date of birth

• passport details, national identity card details, driver’s license details

• loyalty program / frequent flyer details

• Payment account information (credit/debit card details, including card type, card number, security number and expiry date and other financial details necessary to process various transactions)

• Health information such as your dietary requirements and health issues (if any) and

• Other details relevant to your travel arrangements or required by the relevant travel service provider(s) (e.g. airlines and accommodation or tour providers).

Please note that, when necessary for travel arrangements, we may collect from a responsible adult personal information relating to a child of any age, but we do not knowingly collect any such information directly from children.

We will only collect sensitive information in compliance with your local data protection laws, with your explicit, voluntary consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g., to provide travel-related products and services), unless we are otherwise required or authorized to do so by law. To the extent permitted or required under your local data protection laws, you voluntarily consent to us using and disclosing your sensitive information for the purpose for which it was collected. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you voluntarily consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages, in which case you voluntarily consent to us using and disclosing that information in connection with facilitating your request. We will not use or disclose sensitive information for purposes other than those for which it was collected unless we subsequently request and receive your voluntary consent to use it for another purpose.

How do we collect personal information?

We usually collect your personal information directly from you during the course of your relationship with us. In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g., a family or group booking, or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveler on the booking.

Where you make a travel booking on behalf of another person(s) (e.g. a family or group booking or a travel booking made for an employee), you agree to have obtained the voluntary consent of the other person(s) for Z Travel to collect, use and disclose the other person's personal information in accordance with this Notice and that you have otherwise made the other person(s) aware of this Notice.

You should let us know immediately if you become aware that your personal information has been provided to us by another person without your voluntary consent or if you did not obtain voluntary consent before providing another person's personal information to us.

We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are changes to your personal information or if you become aware that we have inaccurate personal information relating to you. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient, or incomplete personal information that you, or a person acting on your behalf, provide to us.

Where the provision of services or other business processes is dependent upon you voluntarily consenting to the collection and subsequent processing of your personal data, if you choose not to provide your voluntary consent this may prevent us from providing specific services that rely upon the collection of personal data, or otherwise impact the quality of the services, we can provide you.

Similarly, if you request that we restrict or stop using personal information we hold on you or withdraw a voluntary consent you have previously given to the processing of such information, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveler’s full name and must include contact details and appropriate identification (e.g., passport details). We cannot make bookings for you without that information.

Any voluntary consent you provide for the collection, use and disclosure of your personal data will remain valid until such time as you withdraw your consent in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data by submitting your request in writing by emailing Z Travel. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

For the retention of personal data, we may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected and are no longer necessary for legal or business purposes.

How do we use your personal information?

We will only process your information, where:

• you have given your voluntary consent to such processing (which you may withdraw at any time, as detailed at section 3 above)

• the processing is necessary to provide our services to you

• the processing is necessary for compliance with our legal obligations

In detail: Where you contact us in relation to a travel booking or query, the purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel-related products and services.

When you book or otherwise arrange travel-related products and services through us, we usually act as an agent for the relevant travel service providers (e.g., for a hotel). In this case, we process your personal information as necessary so as to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Notice and for the travel service provider for whom we act as agent (e.g., to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.

We may therefore share your information with our travel service providers such as hotel, airline, car rental, or other providers, who fulfill your travel bookings. Please note that these travel service providers also may use your personal information as described in their respective privacy policies and may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or provide you with your requested services. We encourage you to review the privacy policies of any third-party travel service providers whose products you purchase through us. We will provide you with copies of all relevant travel service provider terms, conditions, and privacy policies on request.

We act as agent for or on behalf of many thousands of travel service providers around the world, so it is not possible for us to set out in this Notice all of the travel service providers for whom we act or their locations.

Further purposes for which we process personal information include:

• to facilitate your participation in loyalty programs

• internal accounting and administration

• to comply with our legal obligations, including complying with law enforcement or government authority requests, and any applicable customs/immigration requirements relating to your travel

• to comply with a valid and authorized court order or other valid legal process and

• other purposes as authorized or required by law (e.g., to prevent a threat to life, health or safety, or to enforce our legal rights)

Is personal information disclosed to third parties?

We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Notice and in accordance with your local data protection laws. Note that, in this Notice, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.

Your personal information may be disclosed to the following types of third parties: our independent contractors, suppliers and service providers, including without limitation:

• travel-related service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;

• financial institutions such as banks, when processing financial transactions;

• credit providers, issuers and payment service providers;

• a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);

• your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;

• as required or authorized by applicable law, and to comply with our legal obligations

• customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel

• government agencies and public authorities to comply with a valid and authorised request, including a court order or other valid legal process

• various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes

• enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter and

• When you engage us to book flights on your behalf, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant airline. This enables airlines to advise passengers of irregular flight operations and disruptions (e.g., flight cancellations, schedule changes) directly

Other than the above, we will not disclose your personal information without your voluntary consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g., prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorized or required by law (including applicable privacy / data protection laws).