PRIVACY POLICY

Your privacy is important to us, and we are committed to protecting your personal information.

This Privacy Policy applies to Turaco Hotels Corporation, trading as Turaco Collection, and to the separate Tanzanian companies that own or operate the hotels within Turaco Collection. References to “Turaco Collection”, “we”, “us” or “our” mean Turaco Hotels Corporation and, where relevant, the company operating the hotel with which you enquire, make a reservation, stay or otherwise interact.

This Privacy Policy explains how we collect, use, store and share personal information when you visit or stay at one of our hotels; use our accommodation, facilities, services or experiences; make a reservation or enquiry; visit or interact with our website; use guest Wi-Fi; attend an event; communicate with us; or engage with our official social media accounts.

Depending on how you interact with us, your personal information may be processed by Turaco Hotels Corporation, the company operating the relevant hotel, or both. The relevant company will be responsible for the personal information it collects and for determining how and why that information is processed. When you make a reservation or stay at one of our hotels, the identity of the relevant hotel and, where appropriate, its operating company will be shown in your booking documentation or made available upon request.

This Privacy Policy should be read together with any additional privacy notice provided when we collect particular information from you.

2. Who This Privacy Policy Covers

This Privacy Policy applies to personal information relating to:

• guests and prospective guests;
• website visitors;
• people making reservations or enquiries;
• event attendees;
• restaurant, bar, spa and leisure guests;
• members of a guest’s travelling party;
• visitors to our properties;
• users of our guest Wi-Fi;
• travel agents, tour operators and corporate clients;
• suppliers, service providers and business contacts; and
• people who interact with us through email, telephone, social media or other communication channels.

“Personal information” means information relating to an identified or identifiable individual. It does not include information that has been anonymised so that an individual can no longer reasonably be identified.

3. How We Collect Personal Information

3.1 Information You Provide at Our Properties

When you are a guest or visitor at one of our properties, you may provide personal information when you:

• make a reservation, check in or check out;
• provide identification or travel documents;
• use our accommodation, restaurants, bars, spas, leisure facilities or other services;
• request transfers, safaris, excursions, activities or other experiences;
• use services provided by independent or outsourced service providers;
• attend a meeting, function or event;
• provide a business card;
• communicate or interact with our employees;
• make a payment;
• provide feedback or make a complaint;
• report an incident or request assistance;
• use our guest Wi-Fi or other technology services; or
• make a special request relating to your stay.

Images and video may also be captured through CCTV or other security systems in public and operational areas at our properties.

3.2 Information You Provide Remotely

You may provide personal information through our website, by post, telephone, email, online chat or social media when you:

• make a reservation or enquiry;
• request information or correspond with us;
• book accommodation, dining, spa treatments, transfers, activities or other services;
• subscribe to newsletters or marketing communications;
• participate in a survey, promotion or competition;
• provide feedback;
• engage with our official social media accounts; or
• apply for employment or submit a business proposal.

3.3 Information Collected Automatically

When you use our website, guest Wi-Fi or other digital services, certain information may be collected automatically, including through cookies and similar technologies. This may include information about your device and browser, IP address, approximate location, pages visited, date and time of access, referring website, interactions with our website, use of guest Wi-Fi, and technical errors or performance information.

3.4 Information Received From Other Sources

We may receive personal information from:

• travel agents and tour operators;
• another person making a reservation on your behalf;
• corporate travel coordinators or employers;
• members of your travelling party;
• hotel brand, loyalty programme and reservation systems;
• online travel agents and booking platforms;
• payment processors, banks and card providers;
• transfer, safari, excursion and activity providers;
• technology, website, analytics and marketing providers;
• social media platforms;
• customer feedback and survey providers;
• publicly available sources; and
• government, regulatory or law-enforcement authorities where permitted or required by law.

4. Personal Information We May Collect

The personal information we collect depends on how you interact with us and may include the following categories.

4.1 Identity Information

• title, first name, middle name and surname;
• date of birth, gender and nationality;
• signature;
• passport, national identification, immigration or visa information where required;
• photographs or other identifying images;
• social media username; and
• account username or similar identifier.

4.2 Contact Information

• residential or mailing address;
• email address;
• telephone number; and
• emergency contact information.

4.3 Reservation and Stay Information

• reservation details, arrival and departure dates;
• room, accommodation, dining and activity preferences;
• travel itinerary and details of accompanying guests;
• special requests;
• spa, transfer, excursion or experience bookings;
• previous stays and transactions;
• customer-service records; and
• feedback or complaints.

4.4 Payment and Transaction Information

This may include billing information, payment method, transaction details, deposits, payments, refunds, payment status and information required for accounting, audit and fraud-prevention purposes. The Turaco Collection website does not collect or process online payments directly. Further information appears in section 10.

4.5 Profile and Preference Information

• interests, preferences and language preferences;
• marketing preferences;
• survey responses;
• previous interactions with us; and
• information derived from analytics or previous stays that helps us personalise our services.

4.6 Technical and Usage Information

• IP address, device identifiers and login information;
• browser type and version, operating system and time-zone setting;
• approximate location and device type;
• website activity, referring website, pages viewed and links selected; and
• information about how you use our website and online services.

4.7 Security Information

• CCTV images and recordings;
• records of access to certain areas;
• incident reports and lost-property records;
• health and safety information; and
• guest Wi-Fi access and security information.

CCTV is generally used in public, entrance, security and operational areas for safety, security, crime prevention, incident investigation and the protection of guests, employees and property. CCTV is not ordinarily used in areas where guests would reasonably expect complete privacy.

4.8 Marketing and Communications Information

• preferences for receiving marketing communications;
• preferred communication method;
• whether you opened or interacted with a marketing communication; and
• records of consent or a decision to unsubscribe.

4.9 Sensitive Personal Information

In limited circumstances, we may collect sensitive personal information where reasonably necessary to provide a requested service, protect an individual’s vital interests, comply with applicable law or where you have provided the required consent. This may include information concerning health or medical conditions, disabilities or accessibility requirements, allergies, dietary requirements that may indicate health or religious information, religious beliefs, biometric information where legally permitted and actually used, race or ethnic origin, sexual orientation where voluntarily disclosed and relevant to a specific request, and other information treated as sensitive under applicable law.

We seek to minimise the collection of sensitive personal information and restrict access to employees and service providers who reasonably require it. Please do not provide sensitive personal information unless it is relevant to a particular request or service.

5. Information About Other Guests

If you make a reservation or enquiry on behalf of another person, you are responsible for ensuring that you are authorised to provide their personal information to us and, where appropriate, that they have been informed about this Privacy Policy. Please provide information about another person only where it is necessary for their reservation, stay, safety or requested service.

6. Children’s Personal Information

Our website is not designed or directed primarily towards children. Children under the age of 16 should use the website only with the assistance of a parent or legal guardian.

As hotel operators, the relevant hotel companies may nevertheless need to process limited personal information about children who stay at or visit our properties. This may include name and age, reservation information, passport or identification information where required by law, dietary, medical or accessibility requirements, emergency contact information, and information needed to protect the child’s safety and wellbeing.

We normally expect this information to be provided or authorised by a parent, guardian or another adult responsible for the child. Children and family members may also be captured incidentally by CCTV systems in public areas. We do not knowingly use children’s personal information for direct marketing without the consent of a parent or guardian where such consent is required.

7. How We Use Personal Information

We may use personal information to:

• respond to enquiries and requests;
• process and manage reservations;
• verify identity and complete check-in and check-out procedures;
• provide accommodation, dining, spa and other hotel services;
• process payments, deposits and refunds where applicable;
• communicate with you before, during and after your stay;
• manage travel itineraries and arrange transfers, safaris, excursions, activities and experiences;
• manage special requests and preferences;
• personalise your stay and our communications;
• provide customer service and respond to feedback or complaints;
• administer hotel-brand or loyalty-programme benefits where applicable;
• maintain appropriate transaction and guest-interaction records;
• operate and protect our website, guest Wi-Fi and technology systems;
• prevent and detect fraud, crime and other unlawful activity;
• maintain safety and security;
• investigate incidents, claims or disputes;
• comply with legal, regulatory, immigration, tax, accounting and reporting obligations;
• improve our hotels, services and guest experience;
• analyse website and service performance;
• conduct surveys and market research;
• provide relevant marketing communications where permitted;
• manage business operations and conduct audits, testing, training and performance analysis;
• establish, exercise or defend legal claims; and
• protect our legitimate business interests and the rights of others.

8. Legal Bases for Processing Personal Information

Depending on the circumstances and applicable law, we process personal information where:

• processing is necessary to perform a contract with you or take steps at your request before entering into a contract;
• processing is necessary to comply with a legal or regulatory obligation;
• processing is necessary for our legitimate business interests or those of another person, provided those interests do not improperly override your rights and interests;
• you have provided consent;
• processing is necessary to protect your or another person’s vital interests; or
• another lawful basis applies under applicable data-protection law.

Our legitimate interests may include operating and improving our hotels and services, communicating with guests, maintaining accurate records, protecting guests, employees, properties and systems, preventing fraud, understanding how our services are used, developing our business, and providing relevant information about our hotels and services.

Where processing is based on consent, you may withdraw consent at any time. Withdrawal will not affect the lawfulness of processing undertaken before consent was withdrawn. We will obtain consent for direct marketing or sensitive personal information where required by applicable law.

9. Reservations, Hotel Brands and Booking Platforms

Certain hotels within Turaco Collection may participate in third-party hotel brands, loyalty programmes, reservation systems or booking platforms. Where you make a reservation through such a provider, personal information may be collected and processed by both the relevant hotel company and the third-party provider under their respective privacy policies. Information necessary to manage your reservation, stay, loyalty benefits or guest experience may be shared between us and the relevant provider. We encourage you to review the privacy policy presented by that provider.

10. Payments and Third-Party Booking Platforms

The Turaco Collection website does not collect or process online payments directly.

If you choose to make a reservation, you may be redirected to an independent booking or reservation platform. That provider may collect and process your payment-card details and other payment information in accordance with its own terms and privacy policy.

Turaco Collection and the company operating the relevant hotel may receive information necessary to manage your reservation, such as your name, contact details, booking information, payment status, deposit status, transaction reference and refund status. We do not receive or retain your complete payment-card number or card security code through the Turaco Collection website.

Where payment is made directly to a hotel, including at the property or through a payment link issued by the hotel, the relevant hotel company and its authorised payment provider will process the payment in accordance with the terms and privacy information applicable to that transaction.

11. Sharing Personal Information

We may share personal information where reasonably necessary with:

• individual hotels and companies within or associated with Turaco Collection;
• hotel operators, brand partners, loyalty programmes and reservation-system providers;
• travel agents, tour operators and corporate travel coordinators;
• payment processors, banks, card networks and financial institutions;
• IT, cybersecurity, website-hosting, communications, cloud-storage and property-management system providers;
• marketing, analytics, survey and advertising service providers where permitted;
• transfer, safari, excursion, activity and other service providers;
• restaurants, spas and other outsourced service providers;
• professional advisers, including lawyers, auditors, insurers and accountants;
• government authorities, immigration authorities, regulators, law-enforcement agencies and courts where required or permitted by law;
• emergency services and medical providers where necessary to protect health or safety; and
• prospective purchasers, investors, financiers or advisers in connection with a legitimate corporate transaction, subject to appropriate protections.

We require service providers processing personal information on our behalf to use appropriate safeguards and process information only for authorised purposes. We do not sell personal information.

12. Marketing Communications

Where permitted by applicable law, and where required with your consent, we may use your contact information to provide news, offers and information about Turaco Collection, our hotels and experiences. Marketing may be sent by email, SMS, social media or another communication method you have selected or permitted.

You may change your preferences or unsubscribe at any time by using the unsubscribe link in an email, following instructions in an SMS or other communication, or contacting us using the details in section 19. Unsubscribing from marketing will not prevent service-related communications concerning an existing reservation, enquiry, payment or stay.

We will obtain any consent required before sharing your information with an independent third party for that party’s own direct marketing.

13. Cookies, Analytics and Similar Technologies

Our website may use cookies and similar technologies to provide essential functionality, remember preferences, maintain security, understand website use, resolve technical problems, measure performance, personalise content and provide or measure advertising where permitted.

These technologies may collect information including your IP address, browser, device type, pages viewed, referring website and interactions with the website. Where required, we will obtain consent before placing non-essential cookies on your device. You can manage cookies through our cookie-management tool, where available, or through browser settings. Disabling certain cookies may affect website functionality. More information may be provided in our Cookie Policy or cookie-management notice.

14. Profiling and Automated Processing

We may analyse reservation history, service preferences, website activity and interactions with communications to better understand our guests and improve or personalise our services and marketing. We do not ordinarily make decisions that produce legal or similarly significant effects based solely on automated processing.

If we introduce automated decision-making that has a significant effect on individuals, we will provide any additional information and safeguards required by law. You may object to profiling used for direct marketing at any time.

15. International Transfers

Because we work with international guests, hotel brands, reservation systems and service providers, personal information may be transferred to or accessed from countries outside Tanzania or your country of residence. Data-protection standards in those countries may differ from those in Tanzania.

Where required by applicable law, we will take appropriate steps before transferring personal information internationally. These may include confirming that an adequate level of protection is available, using appropriate contractual safeguards, obtaining regulatory approval or a transfer permit where required, obtaining consent where appropriate, or relying on another lawful basis.

Personal information transferred to another jurisdiction may be subject to the laws of that jurisdiction and may be disclosed to courts, regulators, law-enforcement agencies or government authorities where legally required. You may contact us for further information about applicable safeguards.

16. Security

We maintain reasonable technical and organisational measures designed to protect personal information against unauthorised or unlawful access, accidental loss, misuse, alteration, unauthorised disclosure and destruction.

Measures may include access restrictions based on job responsibilities, confidentiality obligations, technical security controls, secure communication and payment channels where appropriate, employee training, system monitoring and testing, incident-management procedures, and secure disposal or anonymisation.

No website, electronic communication or information-storage system can be guaranteed completely secure. You should take appropriate precautions when communicating or transacting online. If a personal-data breach occurs, we will investigate and take appropriate steps, including notifying affected individuals and the relevant authority where required by law.

17. Retention of Personal Information

We retain personal information only for as long as reasonably necessary for the purposes for which it was collected, including to provide services, manage reservations and guest relationships, comply with legal, tax, accounting, immigration and regulatory requirements, manage complaints or disputes, prevent fraud, maintain security, and establish, exercise or defend legal claims.

Retention periods vary according to the nature of the information, its purpose and applicable legal requirements. When personal information is no longer required, we will take reasonable steps to delete, destroy or anonymise it securely.

18. Your Rights

Subject to applicable law and relevant exemptions, you may have the right to:

• be informed about how your personal information is processed;
• request confirmation of whether we process your information;
• request access to personal information held about you;
• request correction of inaccurate, incomplete, outdated or misleading information;
• request erasure or destruction in appropriate circumstances;
• object to certain processing, including direct marketing;
• request restriction of processing in appropriate circumstances;
• withdraw consent where processing is based on consent;
• request information about recipients or categories of recipients;
• request information about safeguards used for international transfers; and
• object to certain automated decision-making or profiling.

To protect your privacy and security, we may ask for information necessary to verify your identity before responding. Certain rights are subject to limitations and exemptions. We may, for example, retain information where required by law or necessary to establish, exercise or defend a legal claim. We will respond within the period required by applicable law and, where legally permitted, explain if we cannot fully comply.

19. Contact Us About Privacy

If you have questions about this Privacy Policy, wish to exercise a privacy right or have concerns about how your personal information is handled, please contact:

Turaco Collection
Email: info@turacocollection.com

Your request will be handled by Turaco Hotels Corporation or referred to the company operating the relevant hotel, depending on the nature of your enquiry. Please include sufficient information to allow us to understand and respond to your request.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our hotels, services and business operations; the ways in which we process personal information; our technology and systems; or applicable legal and regulatory requirements.

The date shown at the beginning of this Privacy Policy indicates when it was most recently updated. Where changes are material, we may provide additional notice through our website or another appropriate communication method.