LAST UPDATED 28th January 2020
As you visit our site, request more information, and process your application, you will be required to provide certain pieces of information about yourself, your contact details and other personal details required to organise your trip.
With this in mind, it is important you know that your information remains secure and protected and that you know how this information will be used. By providing information to Kaya you indicate that you agree to the collection and use of your personal information by Kaya as outlined in this policy.
What information is collected?
We collect two types of information: personal information that you provide to us and non-personal information automatically collected through automated means.
Wherever possible, personal information is collected directly from you, although there may be occasions when information is collected about you from third parties, such as host or partner universities, with the prior approval of the individual or a publicly maintained record. If you are registered with us, you can access content and services that we offer only to registered users. Registered users also have the option of changing or deleting the data specified during registration at any time. We are also able to provide you with information about the personal data we hold about you at any time.
If you do not want to provide us with your Personal Information, you are not required to do so; however, while you may still access the Website, certain services may not be available to you. By providing your Personal Information to us via the Website, you consent to receive information and updates from us, our representatives or our authorized third party service providers (except where prohibited by law).
Personal information that we might collect includes:
- email address, home address or telephone number.
- To ensure that any phone calls are made during your daytime hours we may also request your location and timezone.
- If you chose to sign up to any of our programs we will also require further information to help us shape your trip. This information will include your travel details, health information, personal preferences and a CV/resume or background on your skills and interests.
- Payments are made directly into our bank by yourself or through our online Stripe system and so no financial information is taken by Kaya Responsible Travel.
When you access our website, information of a general nature is automatically recorded. We use web analytics tools that rely on cookies, web beacons, and other automated tracking technologies to help us analyze how users interact with our website, how we can improve our website, how we can personalize your website experience and provide you with information we believe may be of interest to you. This information does not individually identify you as a person. Anonymous information of this kind is statistically evaluated by us to optimize our internet presence and the underlying technology.
Non-personal information that we might collect automatically includes:
- The type of web browser you are using
- The operating system you are using
- The name of your internet service provider
- Your anonymous IP address in our access and error logs
Our website uses third party tracking technologies like Google Analytics and Google Conversion Tracking. In both cases these technologies rely on the use of “cookies” and “web beacons.” A cookie is a small amount of data which is sent to your browser from a web site’s computers and stored on your computer’s hard drive.
Most browsers automatically accept cookies as the default setting. You can modify your browser setting to reject our cookies or to prompt you before accepting a cookie by editing your browser options. However, if a browser is set not to accept cookies or if a user rejects a cookie, some portions of the website and services may not function properly.
A web beacon is an electronic image, also called a “gif,” that may be used on our web pages to deliver cookies, count visits and compile statistics on usage and campaign effectiveness or in our emails to tell if an email has been opened and acted upon.
To better understand how Google may use the information collected through Google Analytics to evaluate Users’ and Visitors’ activity on our Site see Google Analytics Privacy and Data Sharing. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
What we do with the information we gather.
Kaya does not sell, rent, trade or share any information gathered with any other companies or third parties who are not directly involved in the delivery of your programme.
This information is used only internally by Kaya administrators and administrators of any Kaya partners in the locations to which you sign up in order to understand your needs and provide you with a better service, and in particular for the following:
We use the information – other than Client Data – to operate, maintain, enhance and provide all features of the Service, to provide the services and information that you request, to respond to comments and questions and to provide support to users of the Service. We process Client Data solely in accordance with the directions provided by the applicable Client or User.
We use the information – other than Client Data – to understand and analyze the usage trends and preferences of our Visitors and Users, to improve the Service, and to develop new products, services, feature, and functionality.
We may use a Visitor’s or User’s email address or other information – other than Client Data – to contact that Visitor or User (i) for administrative purposes such as customer service, to address intellectual property infringement, right of privacy violations or defamation issues related to the Client Data or Personal Data posted on the Service or (ii) with updates on promotions and events, relating to products and services offered by us and by third parties we work with. You have the ability to opt-out of receiving any promotional communications as described below under “Your Choices.”
Cookies and Tracking Technologies
We use automatically collected information and other information collected on the Service through cookies and similar technologies to: (i) personalize our Service, such as remembering a User’s or Visitor’s information so that the User or Visitor will not have to re-enter it during a visit or on subsequent visits; (ii) provide customized advertisements, content, and information; (iii) monitor and analyze the effectiveness of Service and third-party marketing activities; (iv) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (v) track your entries, submissions, and status in any promotions or other activities on the Service. You can obtain more information about cookies by visiting http://www.allaboutcookies.org.
We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the Site and identify visitor preferences; but in this case, the data will be in non-identifiable form. We do not use any of this information to identify Visitors or Users.
Sharing, Disclosure, and Accountability for Onward Transfer
We at the Kaya Responsible Travel abide by the requirements laid out by Privacy Shield and GDPR which outlines the situations in which an organization may disclose personal information to a third party. Only as needed, and within specified limited purposes consistent with the consent provided, we may share your personal information with:
- Our internal staff
- Technical consultants
- Host or home universities and institutions,
as well as other third parties such as:
- Transit or travel authorities
- homestay partners
- medical professionals
- legal authorities
Personal information may be disclosed where an individual has consented to the disclosure, or when the disclosure is done in the best interest of the individual such as in the case of a medical emergency, a serious and imminent threat to a person’s life, health or safety, a requirement under law or authorized by law, or a requirement for an enforcement body.
Kaya Responsible Travel establishes contracts with all third party organizations affirming that they will abide by the same regulations and principles as the company. Furthermore, the third party organizations will only process the provided information for the limited and specified purposes consistent with the consent provided by you. In these situations the company remains accountable for personal data, as well as liable to relevant data protection authorities if any third parties engages in activities that are inconsistent with these policies and all appropriate legal frameworks unless the company is able to prove that it was not responsible for the event that caused the damage.
This means that they will take all reasonable efforts to protect your data, but also not use, share, or alter the provided personal information in any way that was not previously and explicitly consented to by you. Kaya Responsible Travel will not share your personal data with any third-party or organization that you do not agree to.
Our agents and representatives will inform you of what data is shared, and to whom. You may request through your program advisor or coordinator that your information not be shared to a particular outside organization. You may also write your requests to our EU Data Protection Representative.
Kaya Responsible Travel is committed to cooperate with European Data Protection Authorities, and will disclose information as required in response to any lawful requests made by public authorities, including to meet national security or law enforcement requirements.
Internet based advertising
Interest based advertising is the collection of data from different sources and across different platforms in order to predict an individual’s preferences or interest and to deliver to that individual, or his/her computer, smart phone or tablet, advertising based on his/her assumed preference or interest inferred from the collection of data pertaining to that individual or others who may have a similar profile or similar interests.
We work with a variety of third parties to attempt to understand the profiles of the individuals who are most likely to be interested in the Kaya Responsible Travel projects so that we can send them promotional emails, or serve our advertisements to them on the websites and mobile apps of other entities.
These third parties include: advertising networks, which collect information about a person’s interests when that person views or interacts with one of their advertisements, attribution partners, which measure the effectiveness of certain advertisements; and business partners, which collect information when a person views or interacts with one of their advertisements.
In collaboration with these third parties, we collect information about our customers, prospects and other individuals over time and across different platforms when they use these platforms or interact with them. Individuals may submit information directly on our Sites or on platforms run by third parties, or by interacting with us, our advertisements, or emails they receive from us or from third parties. We may use special tools that are commonly used for this purpose, such as cookies, beacons, pixels, tags, mobile advertising IDs, flash cookies, and similar technologies. We may have access to databases of information collected by our business partners.
The information we or third party collect enables us to learn what purchases the person made, what ads or content the person sees, on which ads or links the person clicks, and other actions that the person takes on our Sites, or in response to our emails, or when visiting or using third parties’ platforms.
We, or the third parties with which we work, use the information collected as described above to understand the various activities and behaviors of our customers, Site visitors and others. We, or these third parties, do this for many reasons, including: to recognize new or past visitors to our Sites; to present more personalized content; to provide more useful and relevant ads – for example, if we know what ads you are shown we can try not to show you the same ones repeatedly; to identify visitors across devices, sales channels, third party websites and Sites, or to display or send personalized or targeted ads and other custom content that is more focused on a person’s perceived interest in products or services similar to those that we offer.
Our interest-based ads may be served to you in emails or on third-party platforms. We may serve these ads about our products or services or send commercial communications directly ourselves or through these third parties.
Visitors may opt out of receiving interest based advertising by advertising networks that may be delivered to them on our platform and other websites by visiting the following websites: http://www.aboutads.info/consumers; and http://www.networkadvertising.org. These features will opt a Visitor out of many – but not all – of the interest-based advertising activities in which we or third parties engage.
We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place efficient physical, electronic and managerial procedures to safeguard and secure the information we collect online.
In alignment with GDPR Article 32 and section 4 of the Privacy Shield framework the company takes all reasonable and appropriate measures to protect your data from unauthorized access, disclosure, loss, use, modification, or other misuse.
The company also consistently destroys hard copies of personal information that is no longer required. This destruction is undertaken by secured means. When in digital form, your personal information is contained within secured networks (i.e. HTTPS, AES Encryption, etc) and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Stripe’s secure connection.
GDPR Information rights and Practices
As of May 25th, 2018, all European Union residents and citizens are granted personal privacy as a fundamental human right. This also applies to our participants while they are residing in Europe during our various programs. As such, under these regulations, the company will not hold onto participant data for longer than is legally necessary and only for as short as possible to protect individual privacy as well as business interests.
You also have the right to rectify any mistakes or incomplete information that may have been provided in order to ensure accurate and complete records. You may also object to the processing of data relating to themselves except in the cases of a specific legal obligation. The company agrees to not collect more personal data than necessary for its legitimate business interest of providing safe and rewarding international programs. All customers have the right to revoke consent to the onward transfer of their personal information or to be forgotten, so long as there is no conflicting legitimate business or individual interest.
In addition customers may request to have a copy of their personal data sent to them. All of these rights are afforded free of charge. However, we are not responsible for removing your personal information from the lists or systems of any third party who has previously been provided your information in accordance with this policy. Once data is no longer relevant to our legitimate business purposes, it is pseudonymized or anonymized based on the kind and calibre of information. The information that we keep exists strictly for analytical purposes to better serve the interests of future customers.
Controlling your personal information
The company recognizes your rights to access your personal data, and will take all reasonable steps to ensure that personal information is accurate. To aid this, you may request to see and correct any mistakes present in your record. You have the right to request that your personal details be removed from our records (a.k.a., “opt out”), provided there is no legal requirement or legitimate business interest relating to the purpose for which they were collected or processed.
Such requests need to be made in writing (see address below) to our Data Protection Representative, who then will investigate the validity of the request and proceed to take all reasonable steps, including technical measures, to inform controllers that are processing the personal data that you have requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
Kaya Responsible Travel, The Arches, North Campus Incubator, Sackville St, Manchester, M60 1QD, or email@example.com. Alternatively you may phone us on 0161 870 6212.
If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible, at the above address. We will promptly correct any information found to be incorrect.
Requests for removal will not be honoured in the cases of the following:
- The removal impinges on the “right of freedom and expression”
- There is a corresponding legal obligation which requires processing or holding of financial or medical records
- Reasons of public interest in the area of public health
- For archiving purposes in the public interest, scientific, historical research, or statistical purposes
- For the establishment, exercise or defense of legal claims
You may opt out of receiving promotional emails or text messages from us at any time by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations, as well as emergency communications regarding our programs abroad.
Changes to the policy
Data Protection, Questions and Concerns
Kaya Responsible Travel is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). If an individual believes that their personal information has not been dealt with in accordance with the company’s policies or applicable laws and regulations, they may lodge a complaint to the Data Protection Authority in writing via email listed below. Acknowledgement will be made within 7 working days of receiving the complaint and a response provided within 30 days. If the result of this does not satisfy the need you may also invoke binding arbitration.
In compliance with the Privacy Shield Principles, Kaya Responsible Travel commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact Kaya Responsible Travel at:
Kaya Responsible Travel,
The Arches, North Campus Incubator,
Sackville St, Manchester,
or email us at firstname.lastname@example.org. Alternatively you may phone us on 0161 870 6212.