Privacy Policy

 
THIS PRIVACY POLICY WAS LAST UPDATED ON 19 NOVEMBER 2018.

 

Small Group Touring Company respects the importance of your privacy and we are committed to safeguarding your Personal Information. We understand that how we collect, use, disclose and protect your Personal Information is important to you. In order to provide our service as a tour operator to you, we must collect Personal Information from you, and we will take reasonable and necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

It is your responsibility to ensure that others you represent, or who represent you, are aware of the content of our Privacy Policy and consent to your acting on their behalf.

Please note that like many things in life, this is a work in progress, which means we may update our Privacy Policy from time to time.  When we change our Privacy Policy, a new one will be posted on our Website with its Effective Date indicated at the top of that version of our Privacy Policy.   Generally, changes to our Privacy Policy are effective when posted on our Website, unless a later Effective Date is indicated.  You should review this Privacy Policy periodically for any changes. 

 

Definitions

 “Company” “we”, “our”, “us” and “Small Group Touring Company” means Small Group Touring Company, a Missouri limited liability company and as the context may require or permit its respective divisions, parent corporation(s), subsidiaries and affiliates of Small Group Touring Company and their respective divisions, parent corporation(s) and their subsidiaries, shareholders and all of the past, present, or future officers, directors, employees, attorneys, and agents, of each and all of them.

 “Personal Information” means information about you and any other person for who you make a booking, including your name, address, health, medical needs, dietary requirements, disability or other special requirements. 

“Services” means the services offered on our Website and interactions with our employees.

“Service Providers” means third-party providers over whom we have no control such as airlines, ground operators (including, but not limited to, coaches, shipping, rail and cars for hire), restaurants and hoteliers.

 “Website” means www.smallgrouptouringco.com operated by the Small Group Touring Company.

“You”, “Your”, “Guest” or “Passenger” means the person who makes the booking or attends the tour.

 

About This Document

This Privacy Policy sets out the types of information we receive and collect when you use our Services, how we collect it, and what we do with it, as well as some of the steps we take to safeguard information.

 

Data Collection

Personal Information is collected from Guests directly or a registered travel agent registering their contact details on our Website and/or via a separate portal. You might volunteer this information when you request information from us, contact us (and vice versa), make a booking, register interest for and/or enter a competition, register for an event, subscribe to one of our newsletters, use our Services, link to or from our Services, connect with us via social media, by speaking to a consultant or any other engagement we or our business partners have with you.

Depending on the circumstances, we might collect all or some of the following information:

Some of the information we collect might be considered “sensitive information” (such as medical information and religion). We collect this information to provide you with our Services, cater to your needs or act in your interests, and we are only prepared to accept sensitive information on the condition that we have your consent.

We may also record in-bound telephone calls or collect information, primarily to ensure quality of Service and for training purposes, when you use the Intercom feature on our Website to speak with our consultants.

We may collect information about your visits to, browsing of, and use of our Website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our Website.  For more information about our use of cookies please see our cookie policy below. This information might include, but is not limited to:

We may also receive information from a third party about you for example:

You represent and warrant to us that you have obtained all required consents and are fully authorized to disclose all Personal Information you provide to us including, without limitation, Personal Information of your friends and family members provided in connection with making travel bookings.

 

Use of Data

We collect Personal Information about you so that we can perform our business activities and functions and to provide the best possible quality of customer service.

Data will be used primarily for the following purposes:

When you provide your email address and contact information to the Small Group Touring Company to make an online booking, your contact details might be retained even if a transaction is not completed. These details are captured using a secure service. This is so we can assist you in future with online bookings, and as a result of this you might receive a follow up email inquiry.

We might from time to time use your Personal Information to identify new or existing products we believe might be of interest to you. We might communicate this via email, phone or your postal address. Please see the section Opting Out of Marketing and Promotions if you do not wish for your information to be used in this way. 

When you are traveling with us, we might take video and images of you that may be used in brochures, in our advertising or on our Website. All participants on Small Group Touring Company trips authorize us to use his/her image (such as photograph, videotape, film or pictorial representation) or recorded voice. If you do not wish for this to happen, please notify us in writing, at the point of booking or prior to your departure, via the details in the Contact Us section below.

 

Retention of Data

We may retain and use your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy.  This retention includes, but is not limited to, your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

We may also retain usage data for internal analysis purposes. Usage data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

 

Transfer of Data

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws might differ from those of your jurisdiction.  If you are located outside the United States and choose to provide information to us, we may transfer the data, including Personal Information, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take reasonably necessary steps to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your date and other Personal Information.

 

Use of Cookies

Small Group Touring Company uses web browser “cookies” to enhance user experience. A cookie is a simple text file that is stored by the browser (e.g. Internet Explorer, Chrome, Safari, Firefox) on your computer or mobile device. They allow a website to “remember” you. A cookie triggers a “memory” for the website, enabling it to recognize a user and respond appropriately. These cookies make the interaction between you and the website faster.   Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

There are four main types of cookies – here’s how and why we use them.

(1) Site functionality cookies. These cookies allow you to navigate the site and use our features.

(2) Site analytics cookies. These cookies allow us to measure and analyze how our Passengers use the site, to improve both its functionality and your browsing experience.

 (3) Customer preference cookies. When you are browsing our Website these cookies will remember your preferences (like your language or location), so we can make your browsing experience as seamless as possible, and more personal to you.

 (4) Targeting or advertising cookies. These cookies are used to deliver ads relevant to you. They also limit the number of times that you see an ad and help us measure the effectiveness of our marketing campaigns.

By using our site, you agree to us placing cookies on your device and accessing them when you visit the site in the future. If you want to delete any cookies that are already on your computer, the “help” section in your browser should provide instructions on how to locate the file or directory that stores cookies. Please note that if you disable the use of cookies on your web browser or remove or reject specific cookies from our Website or linked sites, then you might not be able to gain access to all content and functions of our Website.

 

Disclosure of Data

Small Group Touring Company may disclose your Personal Information to our employees, contractors or Service Providers located in the United States or overseas for the purpose of operation of our Website or our business, fulfilling requests by you, managing your bookings, responding to your enquiries and to otherwise provide products and Services to you, including, without limitation, to airlines, tour companies, travel agencies, web hosting providers, IT systems administrators, debt collectors, and professional advisors such as accountants, attorneys, solicitors, business advisors and consultants.

We may share your Personal Information inside our Company, including but not limited to, our parent company, its subsidiaries and affiliates for the purposes of providing products or Services to you, as well as for research, training, marketing and quality control purposes.

We are affiliated with a range of Service Providers located overseas. In the course of doing business with you, we will routinely disclose some of your Personal Information (including sensitive information and health information) to these overseas recipients. These Service Providers are located at destinations used by Small Group Touring Company, including Africa, Asia, South America, Central America, North America, the Middle East and Europe. Their permitted use of such information is limited to providing the required services.

We will only disclose your Personal Information to overseas recipients where:

We will never sell your name, address, e-mail address or other Personal Information to any third-party for any purpose.

We may disclose your Personal Information in the good faith belief that such action is necessary to:

We may also share data if Small Group Touring Company is involved in a merger, acquisition or asset sale.

Under certain circumstances, we may be required to disclose your Personal Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

We may share aggregated non-Personal Information with third parties, such as our travel industry partners, to analyze trends and further improve our Service offerings to you and others.

When you provide us Personal Information for the purposes of booking travel related services on your behalf or on behalf of another person, we must provide such Personal Information to the travel providers you have selected for the purposes of completing the booking. We have no control over how travel providers use, disclose or store Personal Information. Please insure you agree with the privacy practices of the travel providers you select prior to providing us your Personal Information for the purposes of booking travel related services with such travel providers.

You acknowledge and agree that we provide your Personal Information to such travel providers solely as your agent and not as the principal holder.  We do insure their compliance with applicable privacy laws, this Privacy Policy or otherwise accept liability or accountability for your Personal Information provided to these third parties, including without limitation their use and disclosure of your Personal Information.

 

Children’s Privacy

We do not knowingly collect identifiable Personal Information from anyone under the age of 18 (a “Child”), unless such information is submitted by or authorized to be submitted by a Child’s legal guardian. Please contact us as soon as you become aware of a Child’s unauthorized sharing Personal Information with us. If we become aware that we have collected Personal Information from a Child without verification of parental consent, we will take steps to remove that Personal Information from our servers.

 

Storage and Security of Data

We take reasonable steps to ensure that the Personal Information we hold is protected from loss, misuse, unauthorized access, but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

We have extensive firewall and intruder detection systems in place to constantly monitor online traffic and financial transactions. The secure connection between your browser and our systems for transfers of private information (which includes but is not limited to financial transactions, bookings forms and survey responses) uses encryption that is compatible with modern browsers.

For credit card security, all online payments are transmitted via this SSL connection. Credit card information is transmitted immediately to a payment gateway solution via an encrypted port. We do not store your credit card number in any of our systems, it is used only within the confines of the transaction and then destroyed upon receipt from an acquiring bank. All credit card payments receive an identification number that is proof of the transaction’s acceptance into the banking system. This identification number can be used to trace any transaction back to the credit card issuer (for example, the bank that issued the MasterCard, or VISA credit card). Personal Information is destroyed or de-identified when no longer needed. For all financial transactions, if we become aware of suspicious activity, we may investigate to determine whether there has been a breach of our security. Occasionally, this may involve one of our staff members contacting you to verify a transaction.

However, we cannot insure the security of credit card details sent to us via email.  While we take reasonable steps to ensure that your Personal Information is secure, the internet is inherently insecure and any Personal Information or other information you transmit to us online is transmitted at your own risk.  If you do not agree to assume this risk, you may provide this information to us in another form of your choosing.

 

Access and Correction of Data

We will, on written request, provide you with access to information we hold about you, unless there is a legal exception that limits what we are required to provide. Your request for access will be dealt with in a reasonable time and we may recover from you our reasonable expenses incurred.

We take reasonable steps to ensure that the Personal Information we hold about you is correct and up-to-date when we collect or use it. If you consider that the information you or others have provided on your behalf may need to be changed, you may contact us via the details in the Contact Us section of this Privacy Policy and we will take steps to correct it.

Under certain circumstances we may not be able to grant you access to the Personal Information we hold, for example if granting access would result in a breach of confidentiality or interfere with the privacy of others. If this occurs, we will give you the reasons for refusal in writing.

 

Link to Other Sites

Our Website may contain links to third-party websites, micro-sites or analytical tools (e.g. Google) not controlled or owned by us, such as reference, review, ancillary products and services sites or websites owned by our parent, sister or affiliated companies. It is your responsibility to check the status of these sites before using them. We make no representations or warranties in relation to the privacy practices of any third-party website and we are not responsible for the privacy policies or the content of any third-party website. Please read their applicable privacy policies and terms of use carefully.

 

Social Sharing Features

Our Website might offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Website with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

 

Opting Out of Marketing and Promotions

We may from time to time use your Personal Information to identify new or existing products that we believe may be of interest to you. We may communicate this via email, phone or your postal address.

You may have the right to ask us to amend or stop how we use your Personal Information, including for marketing purposes. Please get in touch via the Contact Us details below to discuss any limitations you would like placed on your Personal Information.  You can unsubscribe from email communications by clicking the unsubscribe link at the bottom of any of our emails or by emailing us at dataprivacy@smallgrouptouringco.com.

If you have booked a trip with us; however, we need to gather, distribute and retain your Personal Information and other information according to the terms set out in this Privacy Policy.  The reason for our doing so, includes, but is not limited to, processing your booking and fulfilling your contract.

 

Making a Privacy Complaint

If you believe that your privacy has been breached or your Personal Information used in a way not permitted by this Privacy Policy, please contact us via the email or postal address in the Contact Us section of this policy and provide details of the incident so that we can investigate. We may need to contact you for further information during this time, this will usually be via email but might also be a recorded phone call.

We request that complaints about breaches be made in writing, so we can keep record of the details of the complaint. We will aim to deal with your complaint as quickly as possible.

 

Contact Us

By email: dataprivacy@smallgrouptouringco.com

By Postal Mail:  2 Cityplace Drive, Suite 200, St Louis MO 63141

By Toll Free Phone: 855-207-6255