Effective date: 26 July 2021
The simple version
WHAT & WHY?
We collect your contact information when you give it to us – we use it to send you email campaigns, arrange meetings with you, and when we represent our members in our meeting with you, in which case we also share your details with them.
We also collect your usage information (when you open our emails or browse to our website) to understand how to improve our constantly evolving service to you.
We use widgets on our website (such as Instagram) that saves a cookie to your local computer.
WHO SAID WE COULD DO IT?
We only use your data with your consent and where we have a legit(imate) interest, such as our business relationship with you.
HOW LONG DO WE USE IT?
When it is an ongoing relationship, we keep your data until the end of that relationship… seems fair? Where it is analytics data, we keep it for the minimum time that Google Analytics allows us.
WHERE DO WE KEEP YOUR DATA?
We use systems from all over the world, but we take great care to ensure their policies and security is up to scratch.
WHO DO WE TELL?
We share your data with our members, only when we have consulted you about those members. We have never been asked to share your data for legal reasons, and it’s unlikely it will ever happen, but if we have to, we will.
We will NEVER sell your data or treat it lightly. Our relationship with you is of the utmost importance to us.
WHAT CAN YOU DO ABOUT IT?
You can ask us to give you the information we have of you, to update it, to not use it, to transfer it and to change your mind. Just email email@example.com
We don’t take responsibility for the external sites that we link to (best to read their policies), we don’t knowingly collect information from children, we will change this policy from time to time (it will evolve as we do) and you can contact us at any time for more information.
Just email firstname.lastname@example.org
Thank you for visiting!
The proper version
Classic Portfolio (“us”, “we”, or “our”) operates the website https://www.classic-portfolio.com and email campaigns from the same domain (the “Service”). Here we list our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy.
Service is the website https://www.classic-portfolio.com and email campaigns under the same domain operated by Classic Portfolio.
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your data more effectively.
Data Subject (or User)
Data Subject is any living individual who is using our Service and is the subject of Personal Data.
Weekly Sales Tip
Weekly Sales Tip is the weekly email campaign we send to our trade partners.
Classic Portfolio Members are the hotels, camps & lodges in our Portfolio as well as their owners and managers.
Representation Service includes arranging meetings, telephone or video calls or other means of training provided to our Trade Partners about the Members in our Portfolio.
Travel industry professionals who potentially sell vacations to the destinations in our Portfolio.
Information collection and use
We collect different types of information to provide and improve our Service to you.
While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
First name and last name
Company name and details
Address, State, Province, ZIP/Postal code, City
Cookies and Usage Data
We may use your Personal Data to arrange meetings with you when we are doing sales in your country, contact you with Weekly Sales Tip, educational invitations, trade show meetings, newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at email@example.com.We may provide some of your Personal Data to our Members who have opted for our Representation Service after meeting with you as part of our reporting to them.
We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
Session Cookies. We use Session Cookies to operate our Service.
Analytics Cookies. We use Analytics Cookies to analyse visitor and user behaviour to improve our Service.
Security Cookies. We use Security Cookies for security purposes.
Use of data
Classic Portfolio uses the collected data for various purposes:
To provide and maintain our Service.
To notify you about changes to our Service.
To allow you to participate in interactive features of our Service when you choose to do so.
To provide customer support.
To gather analysis or valuable information so that we can improve our Service.
To monitor the usage of our Service.
To detect, prevent and address technical issues.
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already used or enquired about unless you have opted not to receive such information
Legal basis for processing personal data under General Data Protection Regulation (GDPR) and Protection of Personal Information Act (POPIA)
Classic Portfolio may process your Personal Data because:
We need to perform a contract with you.
You have given us permission to do so.
The processing is in our legitimate interests and it’s not overridden by your rights.
To comply with the law.
Retention of data
Classic Portfolio will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Transfer of data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Please note that we may transfer data, including Personal Data, to the locations of our third-party service providers’ servers and process it there.
Disclosure of data
Classic Portfolio may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation.
To protect and defend the rights or property of Classic Portfolio.
To prevent or investigate possible wrongdoing in connection with the Service.
To protect the personal safety of users of the Service or the public.
To protect against legal liability.
Security of data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
'Do not track' signals
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your data protection rights under GDPR
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Classic Portfolio aims to take reasonable steps to allow all users to correct, amend, delete, or limit the use of your Personal Data, whether they are located in the EEA or not.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us at firstname.lastname@example.org.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Classic Portfolio relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).
We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: WWW.GOOGLE.COM/INTL/EN/POLICIES/PRIVACY/
We use MailChimp to send email campaigns and track activity or lack thereof, including opens & clicks.
Your email service provider will automatically disable tracking by not downloading pictures. You have the option to temporarily or permanently allow downloading of pictures by setting your preferences accordingly.
We periodically send out surveys and track responses via Survey Monkey.
Links to other sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Our Service does not address anyone under the age of 18 (“Children”).
We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to this privay policy