HotelKaribu Privacy Policy

Introduction

Last Updated in January 2021

This Privacy Policy describes how HotelKaribu.com – JOTRE Consulting Company. Ltd. (“HotelKaribu,” “we,” “us,” “our”) collects, uses, and shares information about you when you visit and interact on our website (mobile and desktop) and mobile app (collectively, “Site”) or other means connected to the Sites (such as contacting our customer service team via chat or email). Below is a summary of our privacy practices. Our full Privacy Policy is available below, or you can click the links on any of the points detailed in the summary table for further details.

1. Information We Collect

We collect information about you that you provide to us when using the Site, such as your name, address, phone number, credit card details, e-mail address, accommodation name, accommodation location and/or length of stay, and your HotelKaribu account password for accommodation reservations. In addition for flight reservations, we may also collect passenger name, date of birth, nationality and passport details including passport number, country of issue and expiry date.

By visiting our Site, we may also automatically collect certain usage information, such as your IP address, geographic data, country, search preferences related to specific searches, browser, and information about your device’s operating system, application version, language settings, and pages that have been shown to you. If you are using a mobile device to access our mobile app or mobile optimized Site, we might also collect information that identifies your mobile device, such as the device ID, location of the device (with your consent), and device-specific settings and characteristics.

If you participate in an HotelKaribu program, there may be limited additional information that we may collect from the accommodation about your stay; for example, see the information below collected as part of the HotelKaribu Umrah program. When you make a reservation, our system registers through which means and from which websites you have made your reservation. We may also collect certain information through cookies, tags, and similar technologies as detailed below.

If you need to get in touch with our customer support team, or reach out to us through other means (such as through social media, or communicating with your accommodation through us), we will collect information from you there too.

Where you submit reviews regarding your accommodation or other ancillary services available on our website through us, we will collect information from you included in your reviews, including your first name and country of residence.

You can decide to participate in our referral programs or other promotions, and doing this will also mean providing us with personal data. In addition to that, you can provide us with feedback or ask for help with using the Sites or our various communications platforms.

Where you are making a booking with other guests whose details you provide to us as part of your reservation, or if you make a booking on behalf of someone else, it is your responsibility to ensure that the person or people you have provided personal information about are aware that you have done so, and have understood and accepted how HotelKaribu uses their information (as described in this Privacy Policy).

Accommodation partners may share information about you with us too – this may happen if you have questions about your pending booking or if disputes arise regarding your booking.

Special categories of personal information

Certain types of personal data, such as religion or health-related information, are considered sensitive and may require additional protection under applicable laws. Although we do not ordinarily collect sensitive personal data as part of standard accommodation bookings, there may be a need to from time to time, collect such information e.g. as contained in a government-issued identification document or medical certificate if such information is supportive of a transaction or request that you ask us to perform on your behalf such as a cancellation or amendment of your booking. You may also elect to provide us with other information which may imply or suggest information like religion, health or other information, such as when specifying your dietary needs. Such collection and processing of such sensitive personal data will be in line with what is set out in this privacy statement.

Where required by law, we rely on the following legal bases to process personal information:

• Necessity to Perform Contract with You – we need to process your information in order to provide our travel reservation services to you, answer questions and requests from you, and provide customer support;
• Our Legitimate Interests – we process your information for security and safety; to detect and prevent fraud; to protect and defend the rights or property of others, or our own rights and interests; to analyze, improve, customize and provide our reservation travel and related services to you; and to respond to lawful requests, court orders, and legal process;
• Compliance with Legal Obligations – we need to process your information to comply with relevant laws and regulatory requirements;
• Consent for Special Categories of Personal Data and Direct Marketing Communications – we rely on your consent to collect sensitive personal data and send direct marketing. You can unsubscribe from direct marketing at any time by following the instructions set out in this Privacy Policy; and
• Protect Vital Interest – we may need to process your information in case of emergency involving an individual’s life or health.

2. How We Use the Information We Collect

We may use information collected through the Site to:

• Provide you with the requested services, such as creating a user account, processing and confirming your reservation, and communicating with you about services requested (e.g., pre-reservation or post booking chat support (excluding credit card number), special request, cancellations, rewards
• Send you email marketing communications about products and services that may be relevant to you
• Conduct surveys or provide you with information about our services on our Site or on other websites you may visit
• Maintain and improve the Site, tailor the user experience, and for internal training
• Protect the security of you and the Site
• Exercising a right or obligation conferred or imposed by law, including responding to request and legal demands

When you make a reservation on one of our business partners’ websites or apps, we may also receive certain information such as your name and reservation information, including the accommodation reserved, in order to process your reservation and identify which channel your reservation has originated from.

During calls with our customer support team, live listening may be done or calls may be recorded for quality and reference purposes which includes the usage of the recordings for the handling of claims, training and fraud detection purposes. If you would prefer that your call was not recorded, you can opt out by stating this, or by hanging up. Call recordings are kept for a limited amount of time and automatically deleted thereafter, unless HotelKaribu has a legitimate interest to keep such recording for a longer period, including for fraud investigation and legal purposes.

If you have not finalized a reservation online, we may send you a reminder to continue with your reservation. We believe that this additional service is useful to you because it allows you to carry on with a reservation without having to search for the accommodation again or fill in all the reservation details from scratch. You may opt-out of receiving these reminders as detailed below under “Opting Out of Marketing Communications from Us.”

Please note that the confirmation emails and text messages sent after your booking are not marketing messages. These messages are part of your accommodation reservation process. Respectively, they contain information for you to check in at your booked accommodation and a separate invitation to complete the guest review form. You will continue to receive them, even if you have opted out of our marketing messages. Similarly, opting into receiving Price Alerts will not affect any other choices you have made regarding receiving communications from us. If you elect to receive Price Alerts, you will be able to opt out of receiving the same by clicking on the “turn off price alerts” or a similar message found in the Price Alert sent to you.

If you have selected a Mix and Save offer but look to have only finalized part of the offer (e.g. only finalized the booking for one but not both rooms), we may send you an email confirming you selected Mix and Save and to remind you to complete all bookings for your selected Mix and Save offer. This message is part of the Mix and Save booking process confirming your selection and in case you have overlooked completing all bookings. In addition to this, we may also send you a pre-check in email reminding you about changing rooms during your stay at the accommodation.

As mentioned above, if you are completing the booking for another person who will stay at the reserved accommodation, you also have the option to insert the guest’s email address for the purpose that the guest will receive the reservation confirmation and a separate invitation to complete a guest review.

Communications on the Site

We offer you and accommodation partners various means to communicate about accommodations and existing reservations, directing the communications through the Site. You can contact us with questions about your reservation or about your accommodation via the Site, and via other channels that we may make available.

We may access communications and may use automated systems to review, scan, and analyze communications for security purposes; fraud prevention; compliance with legal and regulatory requirements; investigations of potential misconduct; product development and improvement; research; customer engagement, including to provide you with information and offers that we believe may be of interest to you; and customer or technical support. We reserve the right to block the delivery of or review communications that we, in our sole discretion, believe may contain malicious content, spam, or may pose a risk to you or, accommodation partners, us, or others. Note, all communications sent or received using the Site’s communication tools will be received and stored by us. Business partners through whose platform you made the reservation and accommodation partners may choose to communicate with you directly via email or other channels that we do not control.

3. Mobile Devices

With your consent, we may send you push notifications with information about your reservation, guest reviews, potential future stays, or as part of any HotelKaribu programs that you participate in, including coupons. You may grant us access to your location information or contact details in order to provide services requested by you. When you upload a picture from your mobile device, your picture may also be tagged with your location information. Please read the instructions of your mobile device to understand how to change the settings and enable the sharing of such information or the receipt of (or opt out of receiving) push notifications (including Software Development Kit (“SDK”) and push token data). Different device operating systems may have different default settings, so please familiarize yourself with such settings governing push notifications.

4. Sharing Your Information

In connection with your visit to our Site and use of our services, we may share your information as follows:

• Travel Supplierssuch as accommodation properties (e.g., the specific accommodation that you have requested us to reserve) and/or third party accommodation suppliers (e.g., Booking.com), airline, car rental, insurance, and, where available, activity providers, who fulfil your travel reservations. These suppliers may contact you as necessary to obtain additional information about you, facilitate your travel reservation including communicating with you prior to arrival about your upcoming stay, or respond to a review you may submit in accordance with their own independent privacy policies.
• Third Party Service Providers who provide data processing services to us (for example web hosting), or who otherwise process personal information for purposes such as credit card and payment processing, business analytics, customer service, marketing, or distribution of surveys, to facilitate the delivery of online services and advertising tailored to your interests, and/or fraud prevention. Our third party service providers will only process information as needed to perform their functions. They are not permitted to share or use the information for any other purpose.
• Business Partnerswith whom we may jointly offer products or services, or whose products or services may be offered on our Sites. You can tell when a third-party business partner is involved in a product or service you have requested because their name will appear, either alone or with ours. If you choose to access these optional services, we will on occasion share your personal information with those partners. An example of a business partner would be a third-party loyalty program that you will earn points for, through a booking.
• Our Affiliated Group Companies – our affiliated (group) companies who have access to this information with our permission and who need to know or have access to this information in order to: perform the service requested by you (including to make, administer, and manage reservations or handle payments, “single sign-on”, and customer service);  analyze how you use our independent and affiliated platforms, improve and provide new and personalized offers, products and services, and marketing; detect, prevent, and investigate fraudulent transactions and/or activities, other illegal activities, and data breaches; internal (audit/compliance) investigations; or as otherwise required or permitted by applicable law.
• Where Required or Permitted by Law– such as to protect ourselves against liability, to respond to subpoenas, judicial processes, legitimate requests, warrants or equivalent by law enforcement officials or authorities, to investigate fraud or other wrongdoing or as otherwise required or necessary in order to comply with applicable law, protect our legitimate interests or to the purchasers in connection with any sale, assignment, or other transfer of all or a part of our business or company. We may also, in compliance with applicable law, disclose your information to enforce or apply the terms and conditions applicable to our services or to protect the rights, property, or safety of HotelKaribu, our users, or others.
• Business Reorganization– such as part of any sale, assignment or other transfer of our business, or transition of service to another provider. We will ask for your consent if required by applicable law.

We provide appropriate protections for such sharing as required by applicable law to prohibit third parties from using your information for their own purposes, and to address the security and confidentiality of your information. Except as disclosed in this Privacy Policy or as required or permitted by applicable law, we will not disclose your information to third parties without your consent.

5. Country-Specific Privacy Rights

California Privacy Rights

If you are a California resident, please note the following about how we collect, use and disclose your personal information, including additional rights you may have to your personal information:

• CA Personal Information. Consistent with the “Information We Collect”section above, we may collect certain categories of information about California residents, such as:
  • Identifiers: name, address, phone number, e-mail address, HotelKaribu account password, IP address, device ID, cookie ID, information collected via Cookies;
  • Commercial Information: credit card details, name of and details about your accommodation, services purchased, search preferences, transaction history, demographic information;
  • Internet or Other Electronic Network Activity: browser, operating system, application version, pages shown;
  • Geolocation Data:physical location of your mobile device or pictures uploaded from your mobile device; and
  • Audio information: we may record your calls to our support team with your permission.
• Sources of CA Personal Information. Consistent with the “Information We Collect”section above, we may collect personal information directly from you, as well as from Travel Suppliers, Accommodation Partners, Business Partners (including social media), and our Affiliated Group Companies.
• Use of CA Personal Information. We process your personal informationconsistent with the “How We Use the Information We Collect” section above.
• CA Personal Information Sold or Disclosed for Business Purposes.
  • Sharing Personal Information for Business Purposes:We disclose the following categories of personal information for business purposes: Identifiers, Commercial Information, Internet or Other Electronic Network Activity, Geolocation Data, Audio information to web hosting, credit card and payment processing, business analytics, customer service, marketing, and survey service providers.
  • Sale of Personal Information:Our disclosure of Identifiers (specifically, preferences and interests on our Site, collected via Cookies to advertising technology providers and, in limited instances, email addresses in hashed format, to social media companies) are sharing activities that are considered a sale under CCPA.
• California Privacy Rights.As a California resident and subject to certain exceptions, you may have the right to know and/or delete your personal information. This includes the right to request information about the personal information we have “sold” or disclosed for business purposes, by contacting us at privacy@HotelKaribu.com or via our Customer Support page.

To protect your privacy and security, we will verify your identity before responding to such request, and may request you provide us with information matching the identifiers and commercial information already maintained by HotelKaribu about you or additional proof where necessary. If you are making this request on behalf of someone else, we may request the authorized agent provide us with a copy of a valid power of attorney or evidence of the written authorization. You will not be penalized for exercising your rights to your personal information.

“Do Not Sell My Info.” You also have the right to opt-out of HotelKaribu “selling” your personal information as defined under CCPA. To exercise this right, please click the Do Not Sell My Personal Information link. If you are making this request on behalf of someone else, we may request the authorized agent provide us with a copy of a valid power of attorney or evidence of the written authorization. If we have actual knowledge that you are under the age of 16, we will not sell your personal information without proper consent.

We also entrust the processing of your information as provided below, accompanying such entrustment with contractual safeguards to protect your information:

As described in more detail under the section “How You Can Access or Change Your Information,” you may have certain data subject rights under local law.

We will retain your information for the period necessary to provide and secure our Sites and services, and to exercise our legal rights and comply with our legal or regulatory obligations. When HotelKaribu no longer needs to use your information, we will remove your information from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it, unless we need to keep your information to carry out corporate tasks and conduct our business or to comply with applicable legal or regulatory obligations.

Disclosure / Transfer of Information

We will maintain the confidentiality of your information, but may provide or transfer your information to third parties as detailed above under “Sharing Your Information,” which may include transferring your information to persons to whom we are required to make disclosures to under applicable law within or outside China.

6. Cookies

Our Site may use and allow third parties to place cookies (session and persistent), pixels/tags, SDKs, application program interfaces (“APIs“), and other technologies (collectively, “Cookies“) on our Site that may collect and store certain information about you. Some of these Cookies are necessary to provide, secure, and maintain the basic functions of the Site, such as to keep you logged in while your visit our Site (“Functional Cookies”), while other Cookies are used to provide you with a better user experience, such as:

• To personalize the Site by remembering information about your activities on the Site (e.g., the language you selected or your log-in details). We may also use Cookies together with other automatically collected usage information to recognize a user across different devices, sessions or browsers (including when they have not logged-in) so as to deliver tailored information;
• Perform non-essential website analytics, such as impression reporting, demographic reporting and interest reporting. This may include the recording of mouse clicks, movements, page scrolling and restricted text entered into our Site forms through selected third parties but we will take sufficient precautions to ensure that personal information will not be collected during such recordings e.g. through the adoption of irreversible masking. Website analytics is used to improve our Site and services; and
• To provide you advertising tailored to your interest (collectively, “Non-Functional Cookies”).

Our use of Functional Cookies and Non-Functional Cookies is subject to geographic implementation as detailed below.

Interest Based Advertising

We may allow certain third parties to place Non-Functional Cookies on our Site to collect information about your online activities on our Site (e.g., pages visited on the Site and searches you performed) and over time and across different websites you may visit. This information is used to provide advertising tailored to your interests from us (via email, on our Site, and on other websites) and by third parties on other websites you may visit, also known as interest based advertising, and to analyze the effectiveness of such interest based advertising. We may also share one-way hashed information with third party partners (e.g., Facebook) who may combine hashed information with other identifiers in order to serve custom HotelKaribu advertisements on other websites or mobile apps based on your prior visits to the Site. HotelKaribu neither supports nor endorses the goals, causes, or statements of any websites or mobile apps that display our advertisements.

Cross-Device Tracking

We may also combine information collected through Non-Functional Cookies and certain usage information from a particular browser or mobile device with another computer or device that may be linked to you (cross-device tracking) to optimize our services and provide tailored HotelKaribu communications and advertisements to you. If you do not want HotelKaribu to combine such information for its optimization of communications to you please unsubscribe from the HotelKaribu communications i.e. the newsletter.

Your Choices

Please review your Internet browser settings, typically under the sections “Help” or “Internet Options,” to exercise choices you have for certain Functional Cookies and Non-Functional Cookies. If you disable or delete certain Functional Cookies or Non-Functional Cookies in your Internet browser settings, you might not be able to access or use important functions or features of this Site, and you may be required to re-enter your log-in details.

To learn more about certain Non-Functional Cookies used for interest based advertising (including through cross-device tracking) and to exercise certain opt-out choices you may have regarding such Non-Functional Cookies, please visit the Digital Advertising Alliance, Network Advertising Initiative, or Digital Advertising Alliance-Canada, or for our mobile app, by updating your device settings or downloading the AppChoices app.

Please also visit the following third parties’ websites to exercise certain opt-out choices over Cookies:

• Google Analytics – https://tools.google.com/dlpage/gaoptout?hl=en
• Appsflyer (mobile app analytics) – By emailing appsflyer at: privacy@appsflyer.com
• Baidu – http://www.baidu.com/duty/safe_control.html
• Apple – https://support.apple.com/en-us/HT202074
• Facebook – https://www.facebook.com/ads/settings
• Google Ads – https://adssettings.google.com/
• Criteo – https://www.criteo.com/privacy/
• Mouseflow recording – https://mouseflow.com/opt-out/
• SecuredTouch – https://www.securedtouch.com/privacy/

By exercising such choices regarding interest-based advertising, you may still receive advertisements, but the network from which you opted out will no longer deliver ads tailored to your interests. You should also know that logging out of your user account does not actually mean that you opt out of personalized advertisements.

You may need to make such choices on each browser and device you may use to exercise choice regarding certain Functional Cookies and Non-Functional Cookies. Lastly, at this time the Site is not configured to honor browsers’ “Do Not Track” signals, except where required by applicable law.

7. Opting Out of Marketing Communications from Us

You can opt out of receiving marketing communications from us at any time by using the “Unsubscribe” link in each newsletter or communication, or through your HotelKaribu account (if you’ve created one) – the email subscriptions settings is under “Profile”.

8. International Transfers

In connection with the purposes described above, your information may be stored in locations outside of your home country, which may have different standards of data protection than your home country. We provide appropriate protections for cross-border transfers as required by law for international data transfers, including information transferred to third parties. With respect to such transfers from the European Economic Area (“EEA“) to the United States and other non-EEA jurisdictions, we may rely on the EU Model Clauses and/or the need to process your information in order to provide the requested services (performance of a contract) to transfer your information. As permitted by applicable law, you may request details about the suitable safeguards we have in place by contacting us as detailed below. For Chinese residents, please see the details provided above under “China Privacy Rights.”

9. Information from Other Partners

On occasion, affiliated entities, business partners, or other third party providers may share information with us. One example is if you access or sign in to our Site through social media, such as Facebook Connect, we may collect information from you such as your username, and other information made available to us via such services. In general, your ability to provide such information is through the service provider themselves and you can change those settings in your account settings of the relevant service provider. In general, we may work with our partners to improve and personalize your use of our website in accordance with this policy.

We have partnered with Facebook to provide personalized content on HotelKaribu for members of Facebook. If you are a Facebook and HotelKaribu user and you have signed into HotelKaribu via the Facebook single sign on feature, then our Site will be personalized for you to display information/stays of your Facebook friends at accommodation in the past and also future stays at accommodation bookable through the Site. The information that may be displayed include the name of the accommodation, the date of stay, the location of the accommodation, your review of past accommodation, the hotel room and price of the hotel room (“Stay Information“), and such information may be shown and personalized to you on the search pages of the accommodation on the Site, and the search calendar amongst other places. Further, your Stay Information will also be displayed to your Facebook friends who are also HotelKaribu customers and who have signed in through the Facebook single sign on feature on the Site, as displayed on their search pages described above within the Site and updated each time you make a booking through HotelKaribu.

How to opt out: HotelKaribu has made it simple for you to opt out of this feature at any time by toggling “no” through (i) the thank you page after you make a booking, and (ii) your “Manage My Booking” page on the Site. Further, if you need help to opt out you may contact our customer experience team at any time.

10. Protecting Your Information

We maintain reasonable physical, electronic, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, or unauthorized disclosure or access. We use Secure Socket Layer technology to encrypt credit card information during transit. Through your personal account, you also have the ability to save credit card details for faster future bookings and payments. Your card details are encrypted and you can always log in to your personal account to delete, edit, or add certain credit card details. For security reasons, the number cannot be edited (but the card details can be deleted). When viewing card details, only the last 4 digits of the number will be visible. Please note that we will store the last 4 digits of your credit card securely upon any booking made (this is required to manage any refund requests for that booking).

Data Retention

We will retain your information for the period necessary to provide and secure our Sites and services, and to exercise our legal rights and comply with our legal or regulatory obligations. When HotelKaribu no longer needs to use your information, we will – unless we need to keep your information to comply with applicable legal or regulatory obligations or the information is required to carry out corporate tasks and conduct our business – remove it from our systems and records and/or take steps to properly anonymize it so that you can no longer be identified from it.

11. How You Can Access or Change Your Information

You can easily correct your account name, the booking holder name (subject to the cancellation policy attached to the booking) and contact number at any time by signing in to your account on the website. Alternatively, please contact us via our Customer Support page or at privacy@HotelKaribu.com to exercise any of the following rights:

• Access: You are entitled at any time to obtain information about your personal information that we store, in accordance with applicable law and without any fee. However, in exceptional cases we ask you to pay reasonable fees before we provide the information if permitted by applicable law.
• Rectification: You may request that we rectify any of your personal information that is incomplete or incorrect.
• Deletion:You may request that we delete your account.
• Restrictions of Processing: You may ask us to cease processing of your personal information for example if you have objected to the processing and the existence of legitimate grounds is still under consideration.
• Objection: You may object, at any time, to your personal information being processed for direct marketing purposes.
• Right to Revoke Consent: You have the right to withdraw your consent at any time, without affecting the lawfulness of our processing based on such consent before it was withdrawn.
• Data Portability: If applicable, you may request us to send you your personal information which we store, in a commonly used and machine readable format which shall be decided at our sole discretion.

To protect your privacy and security, we will verify your identity before responding to such request, and your request will be answered within a reasonable time frame. We may not be able to allow you to access certain personal information in some cases e.g. if your personal information is connected with personal information of other persons, or for legal reasons. In such cases, we will provide you with an explanation why you cannot obtain this information. We may also deny your request for deletion or rectification of your personal information due to statutory provisions, especially those affecting our accounting processes, processing of claims, for fraud detection or prevention purposes, and mandatory data retention, which may prohibit deletion or anonymization.

12. Updates to Privacy Policy

On occasion, HotelKaribu may revise this Privacy Policy to reflect changes in the law, our information collection and use practices, the features of our Site, or advances in technology. If we make revisions that change the way we collect or use your information, those changes will be posted in this Privacy Policy and the effective date will be noted at the beginning of this Privacy Policy. Therefore, you should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. HotelKaribu will also prominently post such material changes prior to implementing the change, and ask for your consent if required by law.

13. Links to Third Party Websites

We may provide links to other websites that are not owned or operated by us (“Third Party Websites“). When you use a link online to visit a Third Party Website, you will be subject to that website’s privacy and security practices, which may differ from ours. You should familiarize yourself with the privacy policy, terms of use and security practices of the linked Third Party Website before providing any information on that website.

14. Additional Considerations

A Special Note About Minors

Our Site is not directed to minors under the age of 18. However, minors can normally accompany their parent(s) or legal custodian(s) who have booked an accommodation, unless prohibited by an accommodation property’s policies.

Language

This Privacy Policy has originally been drawn up in the English language. Translations in other languages are available for your convenience. In case of conflict between the English language version and a translated version, the English language version shall prevail.

Terms of Use

Please review the HotelKaribu Terms of Use for more details on using our Site. This Privacy Policy forms an integral part of our Terms of Use.

15. Contacting Us

If you have any questions about this Privacy Policy or our privacy practices, please contact our HotelKaribu Data Governance Officer by email at privacy@HotelKaribu.com or by sending a registered letter to the address at:

HotelKaribu – JOTRE LLC

Dar es salaam, Tanzania

E-Mail:        privacy@HotelKaribu.com