This privacy policy (“Policy”) sets out how the personal information (“Personal Information”) you may provide on the Twin Sable Safaris’ website (“Website”) and any of its related products, content and services (collectively, “Services”) is collected, protected and used.
It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between you (“User”, “you” or “your”) and the Website owner (“Owner”, “we”, “us” or “our”).
You agree that this Policy will govern your use of the Website and Services and you further agree to abide by the terms and conditions of this Policy.
Kindly note that this Policy only pertains to the Website and Services that we offer.
Automated collection of information
When you open our Website, our hosting/server providers (Bluehost & WordPress) will automatically record information that your browser sends. A browser can be your computer, laptop, tablet or smartphone.
This data is mainly of statistical nature and may include information such as:
- IP address of your browser
- specifications of your browser such as the type of model and version
- the type and version of your operating system
- your language preferences
- pages of the Website and Services that you visit
- the time spent on the Website’s pages
- the information you search for on the Website
- the time and date that you visited the Website.
The reason this information is collected automatically is solely to identify potential cases of abuse and to establish statistical information regarding the usage and traffic of the Website and Services. This statistical information is not that specific so as to identify you or any particular user of the Website.
This Website utilizes Google Analytics which 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 the Website. This data may be shared with other Google services to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Website available to Google Analytics by installing the Google Analytics opt-out browser add-on. This add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits to the Website.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/.
Other programs that we use to protect our Website are:
- Antispam Bee (anti-spam)
- Wordfence Security (security and firewall)
- Updraft Plus (Backup and restore)
Collection of Personal Information
You visit and use the Website and Services without telling us who you are, or without revealing any information that could identify you as a specific individual.
If, however, you wish to use some of the features on the Website, you may be asked to provide certain Personal Information by filling in forms on the Website, or by communicating with us by email or contact form, including when you:
- make use of any of our Services
- complete any online forms on the Website
- comment on any of the pages and posts on the Website
- provide us with feedback.
Some of the Personal Information that we collect is directly from you via the Website and Services and, depending on the required Services, Personal Information may include one or more of the following:
- Identity Information – your name and surname, date of birth, marital status and title
- Contact Information – your billing address, email address and contact numbers
- Financial Information – your payment card details
You can choose not to provide us with your Personal Information, but then you may not be able to utilize the Services or some of the features on the Website. Users who are uncertain about what information is mandatory are welcome to contact us at dtwinsables@gmail.com.
Use and processing of collected information
To make the Website and Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information.
If you do not provide the information that we request, we may not be able to provide you with the requested Services. Any of the information we collect from you may be used for the following purposes:
- to personalize your experience of the Website and Services, so as to better respond to your inquiries and to offer support
- to process transactions
- to improve our Services. Using analytical platforms such as Google Analytics, we will map broader analytical trends and patterns, making sure our Services align with what our customers need and improve marketing materials
- to enforce terms and conditions and other applicable policies and/or disclaimers that are placed on the Website
- to protect from abuse and malicious users – in this instance we utilize the services of Antispam Bee, and Wordfence Security.
Processing your Personal Information depends on how you interact with the Website and Services, where you are located in the world and if one of the following applies:
- You have given your consent for one or more specific purposes. This, however, does not apply whenever the processing of Personal Information is subject to California Consumer Privacy Act (CCPA) or European General Data Protection Regulation (GDPR) (see below for more specific information).
- Provision of information is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof.
- Processing is necessary for compliance with a legal obligation to which you are subject.
- Processing is related to a task that is carried out in the public interest or the exercise of official authority vested in us.
- Processing is necessary for the legitimate interests pursued by us or by a third party.
Note that under some legislations we may be allowed to process information until you object to such processing (by opting out), without having to rely on consent or any other of the following legal bases below. In any case, we will be happy to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Information is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Kindly note that we will not ask for more Personal Information than needed to process a request or to complete a transaction.
Disclosure of information
Depending on the requested Services or as necessary to complete any transaction or to provide any service that you have requested, we may (with your consent) share your information with our trusted third parties that work with us, and any other affiliates and subsidiaries we rely upon to assist in the operation of the Website and Services available to you.
Currently, we utilize the third party services of:
- PayPal (payment services)
- Antispam Bee (anti-spam)
- Wordfence Security (security and firewall)
- WPForms Lite (contact forms)
Your Personal Information will not be sold, exchanged, transferred or given to any other third party for any reason whatsoever, without your consent, other than for the express purpose of delivering any Services to you.
We do not share Personal Information with unaffiliated third parties. These service providers are not authorized to use or disclose your information, except as necessary to perform services on our behalf or to comply with legal requirements. We may share your Personal Information for these purposes only, with third parties whose privacy policies are consistent with ours, or who agree to abide by our policies concerning Personal Information.
These third parties are given Personal Information that they need only to perform their designated functions, and we do not authorize them to use or disclose Personal Information for their marketing or other purposes.
Retention of information
We will retain and use your Personal Information only for the period that is necessary to complete any Services.
We will further only retain such Personal Information to comply with our legal obligations, resolve disputes and enforce our agreements, unless a longer retention period is required or permitted by law.
We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.
Once the retention period expires, Personal Information shall be deleted. Once the information is deleted, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.
Transfer of information
Depending on where you live, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union, or to any international organization governed by public international law, or set up by a group of two or more countries such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us, using the information provided in the contact section.
The rights of users
You may exercise certain rights regarding your Personal Information processed by us. In particular, you have the right to do the following:
- You have the right to withdraw consent where you have previously given your consent to the processing of your information.
- You have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent.
- You have the right to learn if the information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing.
- You have the right to verify the accuracy of your information and ask for it to be updated or corrected.
- You have the right, under certain circumstances, to restrict the processing of your information, in which case we will not process your information for any purpose other than storing it.
- You have the right, under certain circumstances, to obtain the erasure of your Personal Information from us.
- You have the right to receive your information in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
The right to object to processing
Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us, or for the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.
Data protection rights under General Data Protection Rights (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights and the Owner aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:
You have the right to request access to your Personal Information that we store and to be able to access your Personal Information.
- You have the right to request that we correct any Personal Information that you believe is inaccurate.
- You also have the right to request us to complete the Personal Information that you believe is incomplete.
- You have the right to request the erasure of your Personal Information under certain conditions of this Policy.
- You have the right to object to our processing of your Personal Information.
- You have the right to seek restrictions on the processing of your Personal Information. When you restrict the processing of your Personal Information, we may store it but will not process it further.
- You have the right to be provided with a copy of the information that we have on you in a structured, machine-readable and commonly used format.
- You also have the right to withdraw your consent at any time where the Owner relied on your consent to process your Personal Information.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, please contact your local data protection authority in the European Economic Area (EEA).
California privacy rights under the Californian Consumer Protection Act (“CCPA”)
Specific Rights you have in terms of the CCPA
If you are residing in California, United States, you will be entitled to additional privacy protection and rights as explained in this Policy, relating to your private information as set out in the CCPA.
Rights to Access
In addition to the rights as set out in this Policy, California residents who provide Personal Information (as defined in the CCPA) to obtain products or services for personal, family or household use, are entitled to request and obtain from us, once a calendar year, information about the Personal Information that we shared, if any, for business purposes.
If applicable, this information would include:
- the categories of Personal Information collected
- the categories of Personal Information sold (if any)
- the categories of any third parties to whom their Personal Information has been sold (if any)
- a list of which categories of their Personal Information was sold to each party (if any)
- the categories of their Personal Information disclosed for business purposes.
Rights to delete personal information
In further addition to the rights under this policy, you may request that your data may be deleted from our records. However, deleting your information may affect the level of Services that are normally provided to Users by the Owner.
Rights not to be discriminated against
In further addition to the rights under this policy, you are entitled to the following non-discriminatory rights:
- not to be denied any services or goods that would normally be offered by the Owner to any of the other Users of the Website
- to be charged different prices than would normally be charged to other Users of the Website
- to be provided with a different quality of Services and/or goods as would normally be offered to other Users.
Exercising your rights to access and deletion of personal information
For a User to exercise the rights to access and deletion, a written and verifiable request can be sent to dtwinsables@gmail.com – please place in the email subject line “Special Request in terms of CCPA” so that we can easily identify your email.
Only a User, or such other person as has been nominated by the user to act on its behalf, may make a verifiable request relating to your personal information. The person nominated must be registered with the California Secretary of State. A User is also entitled to request on behalf of his/her minor child.
A User may send a verifiable request for rights to access twice in 12 months. Furthermore, such a verifiable request must be accompanied by sufficient information that will serve as proof to identify you as the person, or the nominated person, that is indeed entitled to make such a verifiable request. Set out your request in as much detail as possible to ensure that we can understand and assist you.
We will not be able to respond to a User if we are not supplied with sufficient proof of identity or if such request is vague and unclear.
Also, note that we are not required under the provisions of Section 1798.105 (3)(d)(1) – (8) of the CCPA to respond to your request if your personal information is required for any one of the following reasons:
- If we need the information to complete a transaction
- Providing goods and services to you
- If we are required by law to keep the information or have a legal obligation to keep the information
- Protecting the right to free speech
- For solely internal use as long as the User might reasonably expect such action from the Website.
We undertake to respond to a User’s verifiable request within 45 days after receipt of same.
Your rights to opt-out of the sale of personal information in terms of CCPA
As stated previously in this document, residents of California have an exclusive right in terms of the CCPA to not have their personal information that is collected for commercial purposes sold. To exercise this right they are given special opt-out privileges. These privileges are exercised by contacting us directly with a special request “Do Not Sell My Personal Information”. You can simply email us at dtwinsables@gmail.com.
Please note that we do not sell your personal information in any circumstances.
Sharing Personal Information
For a User to determine how we generally use the personal information that we collect and share, the User is referred to the following aforementioned clauses of this policy:
Use & Processing of collected information
Disclosure of information
Sharing of personal information for business purposes
From time to time we may need to share your personal information with a third party for business purposes, for us to deliver Services to you.
In the preceding 12 months, we have collected the following categories of Personal Information for business purposes.
| Category | Personal Info |
| Identifiers | Name, Email, IP Address |
| Commercial | None |
| Usage | Information on the User’s interaction with the Website |
| Geolocation | General Location (country) |
Your personal information was disclosed for business purposes to the following categories of third parties:
Service Providers:
- WordPress (hosting and maintenance)
- PayPal (payment services)
- Antispam Bee (anti-spam)
- Wordfence Security (security and firewall)
- WPForms Lite (contact forms)
Sharing of Personal Information for commercial purposes
For the sake of transparency the Website did not sell any personal information for commercial purposes in the preceding 12 months.
How to exercise these rights
Any requests to exercise your rights can be directed to the Owner through the contact details provided in this Policy.
Please note that before we can provide you with the necessary information we may ask you to verify your identity. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be, or that you are the authorized representative of such person.
You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.
Privacy of children
We do not knowingly collect any Personal Information from children under the age of 18. If you are under the age of 18, please do not submit any Personal Information through the Website and Services.
We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce this Policy by instructing their children never to provide Personal Information through the Website and Services without their permission.
If you have reason to believe that a child under the age of 18 has provided Personal Information to us through the Website and Services, please contact us. You must also be at least 18 years of age to consent to the processing of your Personal Information in your country (in some countries we may allow your parent or guardian to do so on your behalf.)
Cookies
The Website and Services use “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.
We may use cookies to collect, store and track information for statistical purposes to operate the Website and Services. You can accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you will not be able to use and experience the features of the Website and Services.
See our Cookie Policy for more details.
Do Not Track signals
Some browsers incorporate a Do Not Track-feature (DNT) that signals to websites which you visit that you do not want to have your online activity tracked. Tracking is not the same as using or collecting information in connection with a website. For these purposes, tracking refers to collecting personally identifiable information from consumers who use or visit a website or online service as they move across different websites over time.
How browsers communicate the DNT signal is not yet uniform. However, we only track your movement on our Website and do not track your browsing activities across the internet. We do not have any control how third parties may track or not track your browsing activities. If you wish to, here is how you can enable the DNT signal on Chrome as follow:
Open Chrome / Click on More (three dots) / Click Settings / Go to “Privacy & Security” / Turn Send a Do Not Track request with your browsing traffic – click it ON if you don’t want any tracking.
We do not activate any tracking signals on our website. However, some of the third parties may implement this function.
Links to other resources
The Website and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Website and Services and to read the privacy policy of every resource or third party that may collect your Personal Information.
See our Disclaimer for more details on this subject.
Information security
We secure information that you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. We maintain reasonable administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of Personal Information in its control and custody.
However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that:
- there are security and privacy limitations of the Internet which are beyond our control
- the security, integrity and privacy of any information and data exchanged between you and the Website and Services cannot be guaranteed
- any such information and data may be viewed or tampered with in transit by a third party, despite our best efforts
Data breach
In the event that we become aware that the security of the Website and Services has been compromised or that users’ Personal Information has been disclosed to unrelated third parties as a result of security attacks, hacking or fraud, we reserve the right to take every reasonably necessary step to, including, but not limited to, investigate and to report, as well as notify and cooperate with law enforcement authorities.
In the event of a data breach, we will make reasonable efforts to notify affected users if we believe that there is a reasonable risk of harm to the user as a result of the breach, or if notice is otherwise required by law. When we do, we will post a notice on the Website. Alternatively, users will be notified by email if we are in possession of such an address.
Changes and amendments
We reserve the right to edit and amend this Policy as well as the terms relating to the Website and Services from time to time and at our discretion. You will be notified of any amendments by way of an email. Alternatively, you can look at the end of this Policy for the last date when the policy was updated – that will normally reflect the last date of any amendments as well.
This Policy will become effective upon publication thereof on the Website and you will agree that by continuing to use the Website or Services after the date of publication, you accept the terms and conditions of this Policy, in which case acceptance shall include any amendments to the Policy as indicated by the last date of update of this Policy.
Regardless of any amendments or updates that may be affected by the Policy, we will honor the terms on which your Personal Information was initially collected and will not use it in any other way that was agreed upon at that specific time.
Acceptance of this policy
You confirm that you have read this Policy and have familiarized yourself with the content thereof. By accessing the Website and using the Services you agree to be bound by the terms and conditions of this Policy, failing which you will not be entitled to access or use this Website or Services in any manner whatsoever.
Contacting us
For more information, you can contact us at dtwinsables@gmail.com.
This Policy was last updated on 12 July 2023.