Privacy Policy - South Africa

Privacy matters but it can be confusing. This page explains our approach to privacy on our Travel Counsellors website and how it affects you.

We value your privacy and we want you to understand how we collect data through our website, how we use that data, and how we disclose it.

This notice is about what kind of personal information we collect, how we use and store it, how we protect it, and what rights you have in terms of your personal information.

If you have any questions, please contact ian.keane@travelcounsellors.co.za

 

Short version

• We collect anonymous statistics about your visit, like which of our pages you viewed.
• Some 3rd parties like Facebook and Twitter may know you visited this website, if you use their services.
• If you sign up with us we take great care to keep your information safe and we’ll never share it with others without being legally justified to do so.
• We only share your data with 3rd parties to help us deliver our own services.  refer to section 4 for more details on how we share your information.

These are just the key points. If you need detail, keep reading.

 

1) What this Privacy Notice is all about

Who does this privacy notice apply to?

This notice applies to everyone that visits our website. In terms of the Protection of Personal Information Act (‘POPIA’), you are the data subject.

Who are you sharing your information with?

You are sharing your information with Travel Counsellors
Our registered address is:
4 Bree Street,
1601 Portside Towers
Cape Town
8001

In terms of POPIA, we are the responsible party.

What personal information is.
Personal information is all information relating to a specific individual. This includes contact information, information relating to your race, gender, sex, pregnancy status, marital status, ethnic or national origin, sexual orientation, physical or mental health, disability, religion, belief, culture, language, education background, financial information, criminal behaviour, employment history, personal opinions, views or preferences, and private or confidential correspondence.

It does not matter whether the information is held on paper or in an electronic or other format – it is still personal information and must be protected.

We may update this notice from time to time.
From time to time, we may have to change this privacy notice to accommodate changes in our business or changes to the law.

2) How we collect and use your information

When you sign up for our exclusive offers/ travel ideas and news.
You can choose to subscribe to our marketing communications. However, if you want to unsubscribe you can do so at any time by following the unsubscribe link at the bottom of our email or by contacting us.

When you contact us.
The type of personal information we collect and share depends on whether you submit questions, request information, inquire about our services, or give us feedback. When you contact us, we collect the information included in your message, such as your contact details (e.g., name, telephone numbers, post code, email addresses). We use this information to communicate with you.
When we use cookies to optimise our website.
Most of the time we collect your information directly from you. However, sometimes we collect your personal information using cookies.

When you visit our website, we collect certain information automatically by using cookies, including:
• your device operating system
• access time
• other device data
• advertisements and other areas of the website you clicked on your location

3) How we use cookies / measure our visitors

We measure visitors to our website using Google Analytics. This records what pages you view within our site, how you arrived at our site and some basic information about your computer. All of that information is anonymous – so we don’t know who you are; just that somebody visited our site.

The information we collect from analytics helps us understand what parts of our sites are doing well, how people arrive at our site and so on. Like most websites, we use this information to make our website better.

You can learn more about Google Analytics or opt out if you wish.

We use cookies to collect information for our website to function optimally.
We use first-party and third-party cookies.

First-party cookies are cookies that we put on your device directly.

Third-party cookies are cookies that our service providers place on your device when you visit our website. We use these service providers to analyse how you use our website and to detect malicious visitors.

We use cookies that are essential for our website.
These cookies are essential for the normal functioning of our website and for you to use its features, such as accessing secure areas of the site.

We use cookies to collect statistics and analyse how you use our website.
These cookies, which include cookies from third-party analytics services, collect information about how you use our website, such as the pages you visit and the links you click on. We cannot use this information to identify you as the information is anonymised. The sole purpose of these cookies is to improve the functionality of our website.

You may opt out of these cookies without affecting the functionality of our website.

We use cookies to store your preferences.
These cookies allow our website to remember choices you made in the past, such as your selected font size.

You may opt out of these cookies, but this will affect some functionality of our website.

We use cookies for marketing and advertising purposes.
These cookies track your online activity to help us deliver relevant advertising, or limit how many times you see an ad. These cookies can share information with other organisations or advertisers.

You may opt out of these cookies without affecting the functionality of our website.

You can manage cookies through your web browser.
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies.

You can find out how to do this by clicking ‘help’ on your browser’s menu or by visiting www.allaboutcookies.org.

If you disable cookies, it may affect the functionality of our website.

These links will explain how to manage cookies for the most common browsers:
• Microsoft Edge
• Google Chrome
• Firefox
• Safari

4) How we share your information

We may share your personal information internally or with service providers to run our website.

We may have to share your personal information:

• in some instances with travel agents within the Travel Counsellors franchise for everyday business purposes;
• to comply with legislation, the government, or a court order;
• if, from time-to-time, parts of the business are sold which could include a transfer of your information;
• when we share our website visitor statistics with Google for data analytics purposes; and
with companies who provide services on our behalf and with our instructions (e.g., our website maintenance service providers).

We only share the minimum amount of your personal information.
We only share the minimum amount of your personal information that our service providers require.

We only share your personal information with service providers we trust.
We require that our service providers agree to keep your personal information secure and confidential and only use it for the purposes for which we shared it with them.

Some of the service providers that we use may be in other countries.
When we share personal information with our service providers in other countries that may not have the same levels of protection of personal information as South Africa, they must undertake to protect your personal information to the same level that we do.

We provide for appropriate safeguards before we share your personal information.
We have appropriate safeguards in place in contracts between our local and foreign service providers and us.

5) How we store your information

We retain your personal information for as long as it is reasonably necessary.

We retain your personal information for as long as we have a legitimate reason to keep it. These periods vary depending on the type of personal information, the reason why we originally collected it, and if there is a specific retention period required by law.

Security
Travel Counsellors take many precautions to prevent the loss, misuse or alteration of your personal information. These precautions include:

•  Use of SSL encryption for sensitive data
•  Hardware stored in secured datacentres behind firewalls
•  All access to information restricted by password and/or secure key
•  Restrictions to what information can be accessed via any location

We take great care to ensure all personal information remains protected, we cannot guarantee the security of data.

Of course you are responsible for keeping your password and user details confidential. Nobody at Travel Counsellors will ever ask you for your password, so please don’t trust anybody asking you for it.

6) How we keep your information secure

We have reasonable security measures in place to protect your personal information and to minimise the impact of a breach.

We base our security measures on the sensitivity of the personal information that we hold. Our security measures are in place to protect your personal information from:
• loss
• misuse
• unauthorised access
• being altered
being destroyed

We regularly monitor our systems for possible vulnerabilities and attacks.
No system is perfect, and we cannot guarantee that we will never experience a breach of any of our physical, technical, or managerial safeguards, but we regularly monitor our systems for vulnerabilities.

We will let you know of any breaches that may affect your personal information.
If something should happen, we have taken steps to minimise the threat to your privacy, and we will let you know if your personal information has been compromised.
We will also let you know how you can help minimise the impact of the breach.

Online Payment
We use a variety of payment providers to bill for our products online. These companies will have access to your personal and payment information. When paying by credit card, Travel Counsellors do not ever have any access to your credit card details.

We share information with our payment processing providers only to the extent necessary for the purposes of processing payments you make via our website.

7) Your personal information rights

You may ask us about your personal information.
You have the right to know when we collect and use your personal information, and to ask us what we know about you and what we do with that information.

You may access your personal information.
You may ask to access your personal information by contacting ian.keane@travelcounsellors.co.za
We may take up to one month to respond to your request and may charge a fee in some circumstances. We will let you know if this is the case.

You have control over your personal information.
You may:
• ask that we update incorrect personal information, or complete personal information that may be incomplete;
• ask that we delete your personal information;
• ask to receive your personal information in a structured, commonly used and machine-readable format;
• ask that we reuse your personal information for your own purposes across different services;
• object to the processing of your personal information under certain circumstances;
• object to automated decision-making and profiling;
• ask that a human review any automated decisions that we make about you, express your point of view about it, obtain an explanation of the decision, and challenge any automated decision made about you; and
ask that we restrict our use of your personal information.

You have the right to unsubscribe.
You have the right to unsubscribe from any direct marketing we send you.

You have the right to lodge a complaint with the Information Regulator.
You can contact the Information Regulator at inforeg@justice.gov.za

PAIA - Promotion of Access to Information Act 2 of 2000

Date of compilation: 1 June 2021. Date of revision: 28 Feb 2022

Table of Contents

1. Introduction
2. Company Introduction
3. Purpose of PAIA Manual
4. The Information Officer and Deputy Information Officer(s)
5. Guide on How To Use Paia and How To Obtain the Guide
6. Records Which Are Available Without a Person Having To Request Access
7. Applicable Legislation
8. Description of Subjects on Which the Body Holds Records and Categories of Records Held on Each Subject by the Travel Counsellors
9. Processing of Personal Information
10. Availability of the Manual
11. Updating of the Manual

1. Introduction

The provision of the Act The Promotion of Access to Information Act no 2. of 2000 (the “Act”) was enacted on 3 February 2000 and was put into effect in part on 9 March 2001, with Section 51 and other sections pertaining to the manuals to be prepared by public and private bodies coming into effect on 15 February 2002. The object of the Act is to give effect to the constitutional right of access to information held by another and required for the exercise or protection of any right, privacy, commercial confidentiality, and professional privilege. When a request is made by a requester in accordance with the procedure provided for in the Act, for access to information held by a body (being either a public body or a private body), that body is obliged to deal with such a request in the manner prescribed in the Act. More specifically, that body is obliged to release the information except in those cases where the Act expressly provides that the information may not or must not be released.

 

2. Company Introduction

Travel Counsellors is an International Travel Company which recruits and empowers experienced travel professionals who are taking advantage of the opportunity to build and develop their own home-based travel businesses using the Travel Counsellors business system.Travel Counsellors (Pty) Ltd has been operational in South Africa since 2007.

 

3. Purpose of PAIA Manual

This PAIA Manual is useful for the public to -3.1 check the categories of records held by a body which are available without a person having to submit a formal PAIA request;
3.2 have a sufficient understanding of how to make a request for access to a record of the body, by providing a description of the subjects on which the body holds records and the categories of records held on each subject;
3.3 know the description of the records of the body which are available in accordance with any other legislation;
3.4 access all the relevant contact details of the Information Officer and Deputy Information Officer who will assist the public with the records they intend to access;
3.5 know the description of the guide on how to use PAIA, as updated by the Regulator and how to obtain access to it;
3.6 know if the body will process personal information, the purpose of processing of personal information and the description of the categories of data subjects and of the information or categories of information relating thereto;
3.7 know the description of the categories of data subjects and of the information or categories of information relating thereto;
3.8 know the recipients or categories of recipients to whom the personal information may be supplied;
3.9 know if the body has planned to transfer or process personal information outside the Republic of South Africa and the recipients or categories of recipients to whom the personal information may be supplied; and
3.10 know whether the body has appropriate security measures to ensure the confidentiality, integrity and availability of the personal information which is to be processed.

4. The Information Officer and Deputy Information Officer(s)

4.1 Chief Information Officer
The MD is our Information Officer.

Information Officer: Mr Mladen Lukic
Postal Address:  PO Box 6739, Roggebaai, 8001
Physical Address: 4 Bree Street, 1601 Portside Towers, Cape Town, 8001
Phone: +27 (0) 21 812 3102
Email: mladen.lukic@travelcounsellors.co.za

4.2 Deputy Information Officer
The Information Officer designated the following Deputy Information Officer(s):

Deputy Information Officer:  Mr Ian Keane
Position: Operations Manager
Postal Address:  PO Box 6739, Roggebaai, 8001
Physical Address: 4 Bree Street, 1601 Portside Towers, Cape Town, 8001
Phone: +27 (0)21 812 3102
Email: ian.keane@travelcounsellors.co.za

4.3 Access to information general contacts
 Email: ian.keane@travelcounsellors.co.za

4.4 National or Head Office
The Information Officer designated the following Deputy Information Officer(s):

Full Name:  Travel Counsellors Pty Ltd
Registration No: 2007/010456/07
VAT Registration No: 4580237768
Postal Address:  PO Box 6739, Roggebaai, 8001
Physical Address: 4 Bree Street, 1601 Portside Towers, Cape Town, 8001
Phone: +27 (0)21 812 3102
Email: ian.keane@travelcounsellors.co.za

5. Records Which Are Available Without a Person Having To Request Access

The Information Regulator has published a guide that introduces the Promotion of Access to Information Act 2 of 2021, as amended (PAIA) to assist you in exercising your right to accessing information. The guide can be accessed on the website of the Information Regulation https://www.inforegulator.org.za/ 

6. Records Which Are Available Without a Person Having To Request Access

 

Categories of records	Types of the Record	Available on Website	Available upon request
Terms & Conditions		Y	Y
Contact Details		Y	Y
Our Franchise Model		Y	Y
Privacy Policy		Y	Y
Corporate Social Responsibility		Y	Y

 

7. Applicable Legislation

Travel Counsellors hold records for the purposes of PAIA in accordance with the following legislation, among others;

1. Companies Act 71 of 2008
2. Income Tax Act 58 of 1962
3. Labour Relations Act 66 of 1995
4. Basic Conditions Of Employment Act 75 of 1997
5. B-BBEE Act 53 of 2003
6. Employment Equity Act 55 of 1998
7. Skills Development Levies Act 9 of 1999
8. Occupational Health and Safety Act 85 of 1993
9. UIF Act 63 of 2001
10. Compensation for Occupational Injuries and Diseases Act 130 of 1993
11. Skills Development Act 9 of 1999

 

8. Description of Subjects on Which the Body Holds Records and Categories of Records Held on Each Subject by the Travel Counsellors

Subjects on which the body holds records	Categories of records
Human Resources	-    Employee Personnel documents and    records -    Employment contracts -    Disciplinary records -    Salary records -    Leave records -    Training records -    Address lists -    Internal telephone lists
Company Records	-    Company incorporation documents -    Share register -    Memorandum of Incorporation -    Minutes of meetings of the board of directors -    Records relating to the appointment of directors, auditors, and other officers
Finance	- Bank statements - List of the company's debtors and creditors -    Budgets -    Management accounts -    Asset registers -    Invoices -    Salaries -    Audited annual financial statements
Income Tax	- Pay-as-you-earn (PAYE) records -    Documents issued to employees for income tax purposes -    Records of payments made to South African Revenue Services on behalf of employees -    All or any statutory compliance -    Value Added Tax -    Skills development levies -    Unemployment Insurance Fund
Travel Management	-    Travel bookings for customers -    Travel related information -    Invoices -    Itineraries  -    Supplier lists

9. Processing of Personal Information

9.1 Purpose Of Processing Travel Counsellors processes

Categories of data subjects	The purpose for which information is collected and used
Clients/Travel Counsellor Clients	Personal information is essential throughout the client journey. We use your personal information to: provide our services to you, to carry out a transaction with you and maintain our relationship; invoice you for our services or send you any other necessary documentation; process your payment; book your flight; provide customer support; process your information to our service providers and necessary third parties to perform our obligations to you. liaise with public officials (e.g. Department of International Relations and Cooperation) In case of emergencies carry out other general administrative and business execution reasons (e.g. doing quarterly sales' forecasts).
Employees	Personal information is essential throughout the employment life cycle. Personal information is used to: manage our relationship with employees and run our business conduct training and development manage remuneration and benefits assist in performance management and the disciplinary processes assist in day-to-day management of Travel Counsellors
Suppliers	We use the service provider’s Personal information to manage our relationship. We use personal information to: assess applications to become our supplier/service provider. communicate with service provider about their goods or service. send service providers statements and any other legal documents; monitor and audit service provider’s compliance with our contract;

 
9.2 Who Receives Your Personal Information?

Depending on the relationship you have with us, we share personal information with:
9.2.1 Service providers and third parties (this includes Airlines, international hotels, and tour operators)
9.2.2 Travel Counsellor agents
9.2.3 Companies that provide services on our behalf so we can do business (e.g. tax auditors, IT, accountants, and other professional consultants)

9.3 Crossborder Flows Of Information

We may only transfer your personal information outside the borders of South Africa if we have satisfied and complied with the requirements of POPIA.
Parties that we may share your Personal Information with that are outside the borders of South Africa are:
• Hotels
• International Airlines
• Tour Operators
• Overseas Insurers

9.4 Information Security Measures

We have implemented appropriate, reasonable technical and organisational measures to secure the integrity and confidentiality of personal information.
We base our security measures on the sensitivity of the personal information that we hold. Our security measures are in place to protect your personal information from loss, misuse, unauthorised access, being altered and being destroyed. 

10. Availability of the Manual

A copy of the Manual is available:
10.1.1 on all our websites
10.1.2 head office of the Travel Counsellors for public inspection during normal business hours;
10.1.3 to any person upon request and upon the payment of reasonable prescribed fee;

11. Updating of the Manual

The company may update this manual every six months or at such intervals as may be necessary