Privacy Policy

Empathy Tours respects the privacy of travellers, website visitors and people who contact us.

This Privacy Policy explains what personal information we collect, why we collect it, how we use it, who we may share it with and the choices available to you.

It applies to information collected through empathytours.com, enquiries, safari bookings, car hire bookings, email, telephone, messaging platforms and other direct interactions with Empathy Tours.

1. Who we are

Empathy Tours [insert registered legal entity name] is a travel company based in Uganda.

For the personal information covered by this Privacy Policy, Empathy Tours generally acts as the data controller.

Contact:

Empathy Tours — Plot 7 Old Port Bell Rd, Kampala, Uganda

Email: info@empathytours.com

Registered address: Plot 7 Old Port Bell Rd, Kampala, Uganda

2. Information we collect

The information we collect depends on how you interact with us and the services you request.

Contact information

This may include:

• name;
• email address;
• telephone number;
• country of residence; and
• preferred method of communication.

Travel information

When planning or booking a safari, we may collect:

• travel dates;
• destinations;
• number of travellers;
• accommodation preferences;
• budget or accommodation category;
• dietary requirements;
• activity preferences;
• flight information;
• arrival and departure information; and
• other information necessary to plan the trip.

Identification information

Certain services, particularly wildlife permits, flights and cross-border travel, may require:

• full legal name;
• nationality;
• passport number;
• date of birth;
• passport expiry date; and
• other identification details required by the relevant authority or supplier.

We collect this information only where it is reasonably required for the service being arranged.

Health and accessibility information

You may give us information about:

• medical conditions;
• mobility or accessibility requirements;
• allergies;
• dietary requirements; or
• other health-related circumstances.

This information can be important when determining whether an activity is suitable or when arranging appropriate assistance.

Because health information is particularly sensitive, we limit its collection and use to circumstances where it is relevant and permitted by law.

Car hire information

Where you request self-drive car hire, we may collect information including:

• driver's licence details;
• driver age;
• identification documents;
• rental dates;
• intended route;
• additional authorised drivers; and
• information required for insurance or vehicle security.

Payment information

We may receive information relating to payments you make to us, including:

• transaction references;
• payment amount;
• payment date;
• payer name; and
• limited payment information supplied by our payment providers.

Where card payments are handled by an independent payment processor, we do not need to store your complete card details ourselves.

Communications

We may retain:

• email correspondence;
• enquiry forms;
• WhatsApp or other messaging correspondence;
• feedback;
• complaints; and
• other communications connected with your enquiry or booking.

Website and technical information

When you use our website, certain technical information may be collected automatically, including:

• IP address;
• browser type;
• device type;
• operating system;
• pages visited;
• referral source;
• approximate location derived from technical information; and
• cookie or similar technology identifiers.

The exact information collected depends on the website technologies and cookie preferences in use.

3. How we collect information

We may receive personal information:

• directly from you;
• from another person making a booking on your behalf;
• from a travel agent or business partner acting for you;
• through our website;
• through email, telephone or messaging services;
• from payment providers;
• from travel suppliers; or
• from authorities where necessary to manage an existing booking.

If you provide information about another traveller, you must have authority to provide that information and should make them aware of this Privacy Policy.

4. Why we use your information

We use personal information where it is reasonably necessary to operate our business and provide the services you request.

Responding to enquiries

We use the information you provide to understand your travel plans, answer questions, recommend suitable arrangements and prepare quotations.

Arranging your safari

We use booking information to arrange services such as:

• accommodation;
• transfers;
• safari vehicles;
• guiding;
• national park activities;
• gorilla or chimpanzee permits;
• flights;
• meals;
• activities; and
• other services included in your confirmed itinerary.

Arranging car hire

We use your information to:

• assess rental eligibility;
• prepare rental documentation;
• arrange vehicle delivery or collection;
• administer deposits and payments;
• coordinate breakdown assistance; and
• meet insurance or legal requirements.

Communicating about your booking

We may contact you about:

• payments;
• itinerary updates;
• permit information;
• travel documents;
• operational changes;
• emergencies; or
• other matters affecting your trip.

Safety and traveller support

Where appropriate, we may use relevant information to assist with emergencies, accessibility requirements or health-related arrangements connected with your trip.

Administration and legal obligations

We may use information for:

• accounting;
• financial records;
• fraud prevention;
• dispute resolution;
• regulatory compliance;
• legal claims; and
• responding to lawful requests from authorities.

Improving our website and services

We may use aggregated or appropriately protected information to understand how people use our website and where our service can be improved.

Marketing

Where permitted, we may send information about Empathy Tours, travel planning or relevant services.

Where consent is required, marketing will be sent only with appropriate consent.

You can unsubscribe at any time.

5. Legal basis for processing

We process personal information only where there is an appropriate legal basis.

Depending on the circumstances, this may include:

• your consent;
• processing necessary to provide a service or perform a contract with you;
• compliance with a legal obligation;
• protection of legitimate interests recognised by applicable law; or
• another basis permitted under applicable data protection law.

Where processing relies on consent, you may withdraw that consent, although this does not invalidate processing that occurred before withdrawal.

Withdrawing consent may prevent us from continuing a service where the information is necessary to provide it.

6. Who we share information with

Travel cannot normally be arranged without sharing some information with the organisations delivering the trip.

We may share information with parties including:

Wildlife and government authorities

For example, information required to obtain gorilla, chimpanzee or other wildlife permits.

Accommodation providers

Hotels, lodges and camps may need traveller names, dates, dietary information and relevant accessibility requirements.

Airlines and transport providers

Where flights, transfers or other transport are arranged, information required by the operator may be shared.

Guides, drivers and ground operators

Information needed to operate the itinerary may be supplied to relevant members of the travel team.

Car hire and insurance providers

Where appropriate, driver's licence or other necessary rental information may be shared with insurers or service providers involved in the rental.

Payment providers and financial institutions

Payment information may be processed by banks, payment gateways and other financial service providers.

Technology providers

We may use companies that provide services such as:

• website hosting;
• cloud storage;
• email delivery;
• customer communication;
• analytics;
• cybersecurity; and
• business administration.

These providers may process limited personal information on our behalf.

Professional advisers

Information may be disclosed where reasonably necessary to accountants, auditors, lawyers, insurers or other professional advisers.

Authorities

We may disclose information where required by law, court order or a lawful request from a competent authority.

We do not sell personal information to advertisers or data brokers.

7. International transfers

Travel arrangements and internet-based services can involve information being processed outside Uganda.

For example, a Rwanda gorilla trekking arrangement may require information to be provided to organisations in Rwanda, while technology providers may operate infrastructure in other countries.

Where personal information is transferred or stored outside Uganda, we take steps required under applicable data protection law, which may include using appropriate safeguards, assessing the protections available in the destination or obtaining consent where required.

8. How long we keep information

We keep personal information only for as long as reasonably necessary for the reason it was collected.

Retention periods depend on factors including:

• whether you have an active booking;
• accounting and tax requirements;
• legal obligations;
• contractual obligations;
• dispute or insurance requirements; and
• whether you have consented to ongoing communication.

When personal information is no longer required, we will delete, destroy, anonymise or otherwise securely dispose of it as appropriate.

9. Security

We use reasonable technical and organisational measures designed to protect personal information against:

• unauthorised access;
• accidental loss;
• unlawful processing;
• alteration;
• disclosure; and
• destruction.

Access to personal information should be limited to people and service providers who require it for legitimate business purposes.

No online system can guarantee absolute security. We therefore continuously consider security in relation to the nature of the information we hold and the systems used to process it.

10. Data breaches

If we become aware of a personal-data breach, we will investigate it and take appropriate steps to limit the consequences.

Where notification to the Personal Data Protection Office, affected individuals or another authority is required by applicable law, we will make the required notification.

11. Your rights

Depending on the circumstances and applicable law, you may have the right to:

• ask whether we hold personal information about you;
• request access to your personal information;
• request correction of inaccurate or incomplete information;
• object to certain collection or processing;
• request that incompatible processing stop;
• request deletion, erasure, blocking or destruction where appropriate;
• withdraw consent where processing is based on consent; and
• raise a complaint about the way your information is handled.

Some rights are subject to legal exceptions.

For example, we may need to retain certain records where required by law or where they are necessary for an existing legal claim.

To exercise a privacy right, contact info@empathytours.com.

We may need to verify your identity before acting on a request.

12. Complaints about personal information

If you believe that Empathy Tours has handled your personal information incorrectly, contact us first so that we can investigate the matter.

Email: info@empathytours.com

You may also have the right to lodge a complaint with Uganda's Personal Data Protection Office or another competent data protection authority.

13. Marketing communications

You can ask us to stop sending marketing emails or messages at any time.

You can normally do this by:

• using the unsubscribe option provided in the communication; or
• contacting us directly.

Stopping marketing communications does not prevent us from sending operational messages relating to an existing enquiry, booking, payment or rental.

14. Cookies

Our website may use cookies and similar technologies.

These may include:

Strictly necessary cookies

Required for security or essential website functions.

Preference cookies

Used to remember choices made on the website.

Analytics cookies

Used to help us understand website traffic and how visitors use the site.

Advertising or marketing cookies

Where used, these may help measure advertising performance or provide more relevant advertising.

Where required, non-essential cookies will be controlled through the website's cookie-consent mechanism.

Changing or rejecting optional cookies may affect some website functionality but should not prevent access to basic website content.

15. Third-party websites

Our website may link to websites operated by airlines, government authorities, lodges, conservation organisations or other third parties.

Their privacy practices are controlled by them, not Empathy Tours.

You should review the privacy information provided by the relevant organisation when supplying information directly to it.

16. Children

Our travel services may include children travelling with parents or guardians.

We do not intentionally collect personal information from a child unless it is reasonably necessary for a legitimate travel booking or another lawful purpose.

Where required, information relating to a child should be supplied or authorised by a parent or legal guardian.

Age restrictions imposed by wildlife authorities and activity providers continue to apply independently of this Privacy Policy.

17. Sensitive personal information

Some travel arrangements may require information relating to health, accessibility, dietary requirements or other sensitive matters.

We request only information reasonably necessary for planning or delivering the service.

Please do not provide detailed medical information that is unnecessary for your travel arrangements.

Where professional medical advice is required, you should consult an appropriate healthcare professional rather than relying on Empathy Tours.

18. Changes to this Privacy Policy

We may update this Privacy Policy when:

• our services change;
• the technologies used by our website change;
• our suppliers or processing arrangements change; or
• applicable legal requirements change.

The latest version will be published on our website with its revision date.

Material changes may be communicated through additional notice where appropriate.

19. Contact us

Questions, privacy requests or complaints can be sent to:

Empathy Tours — Plot 7 Old Port Bell Rd, Kampala, Uganda

Email: info@empathytours.com

Registered legal entity: [insert legal entity name]
Registered address: Plot 7 Old Port Bell Rd, Kampala, Uganda