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Privacy standard (GDPR version)
Travel Expo 365

Privacy standard (GDPR version)

This privacy standard (previously, a data protection policy) sets out the principles and legal conditions that our personnel, our clients and our organisation must satisfy when obtaining, handling, processing, transporting or storing personal data in the course of their operations and activities, including customer, supplier and employee data. It is tailored to comply with the General Data Protection Regulation ((EU) 2016/679) (GDPR)

The GDPR took effect on 25th May 2018 and guidance is still being issued. This Privacy Standard may be amended as and when further guidance is published. Further amendments may be made to this document when the Article 29 Working Party’s final Guidelines on Transparency under the GDPR (WP260) are published.

View sections

1. Interpretation

2. Introduction

3. Scope

4. Personal data protection principles

5. Lawfulness, fairness, transparency

6. Purpose limitation

7. Data minimisation

8. Accuracy

9. Storage limitation

10. Security integrity and confidentiality

11. Transfer limitation

12. Data Subject’s rights and requests

13. Accountability

14. Changes to this Privacy Standard

15. Acknowledgement of receipt and review

Privacy standard (GDPR version) Travel Expo 365

1. INTERPRETATION

1.1 DEFINITIONS

Automated Decision-Making (ADM): when a decision is made which is based solely on Automated Processing (including profiling) which produces legal effects or significantly affects an individual. The GDPR prohibits Automated Decision-Making (unless certain conditions are met) but not Automated Processing.

Automated Processing: any form of automated processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to an individual, in particular to analyse or predict aspects concerning that individual’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements. Profiling is an example of Automated Processing.

The "Client" – The organisation, institution or individual with whom we enter into a contractual arrangement to deliver Services on behalf of "Company" name: Travel Expo 365 Limited trading as Travel Expo 365, a company registered in England and Wales with number 08124525, registered office 152 Sheerstock, Haddenham, Thame, Buckinghamshire HP17 8EX, United Kingdom

Company Personnel: all employees, workers, contractors, agency workers, consultants, directors, members and others.

Consent: agreement which must be freely given, specific, informed and be an unambiguous indication of the Data Subject’s wishes by which they, by a statement or by a clear positive action, signifies agreement to the Processing of Personal Data relating to them.

Data Controller: the person or organisation that determines when, why and how to process Personal Data. It is responsible for establishing practices and policies in line with the GDPR. We are the Data Controller of all Personal Data relating to our Company Personnel and Personal Data used in our business for our own commercial purposes however our Client/s are the Data Controllers for data subjects they capture for the “Services” the Company delivers on their behalf.
Data Subject: a living, identified or identifiable individual about whom we hold Personal Data. Data Subjects may be nationals or residents of any country and may have legal rights regarding their Personal Data.
Data Privacy Impact Assessment (DPIA): tools and assessments used to identify and reduce risks of a data processing activity. DPIA can be carried out as part of Privacy by Design and should be conducted for all major system or business change programs involving the Processing of Personal Data.
Data Protection Officer (DPO): the person required to be appointed in specific circumstances under the GDPR. Where a mandatory DPO has not been appointed, this term means a data protection manager or other voluntary appointment of a DPO or refers to the Company data privacy team with responsibility for data protection compliance.

EEA: the 28 countries in the EU, and Iceland, Liechtenstein and Norway.
Explicit Consent: consent which requires a very clear and specific statement.
General Data Protection Regulation (GDPR): the General Data Protection Regulation ((EU) 2016/679). Personal Data is subject to the legal safeguards specified in the GDPR.

Personal Data: any information identifying a Data Subject or information relating to a Data Subject that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data includes Sensitive Personal Data and Pseudonymised Personal Data but excludes anonymous data or data that has had the identity of an individual permanently removed. Personal data can be factual (for example, a name, email address, location or date of birth) or an opinion about that person’s actions or behaviour.
Personal Data Breach: any act or omission that compromises the security, confidentiality, integrity or availability of Personal Data or the physical, technical, administrative or organisational safeguards that we or our third-party service providers put in place to protect it. The loss, or unauthorised access, disclosure or acquisition, of Personal Data is a Personal Data Breach.
The "Platform" - the environment in which the Travel Expo 365 software service is executed.

Privacy by Design: implementing appropriate technical and organisational measures in an effective manner to ensure compliance with the GDPR. (See APPENDIX 2 )
Privacy Guidelines: the Company privacy/GDPR related guidelines provided to assist in interpreting and implementing this Privacy Standard available here: [see APPENDIX 1].
Privacy Notices (also referred to as Fair Processing Notices) or Privacy Policies: separate notices setting out information that may be provided to Data Subjects when the Company collects information about them. See Privacy Notice.

Processing or Process: any activity that involves the use of Personal Data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transmitting or transferring Personal Data to third parties. Pseudonymisation or Pseudonymised: replacing information that directly or indirectly identifies an individual with one or more artificial identifiers or pseudonyms so that the person, to whom the data relates, cannot be identified without the use of additional information which is meant to be kept separately and secure. Related Policies: the Company’s policies, operating procedures or processes related to this Privacy Standard and designed to protect Personal Data, available here: [Information Protection Policy - attached].

Sensitive Personal Data: information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data, and Personal Data relating to criminal offences and convictions. "The Service/s" - the work to be undertaken by the Company to build the Platform and organise an Event and any subsequent Events and any event content in accordance with the contract.

INTRODUCTION

This Privacy Standard sets out how Travel Expo 365 (”we”, “our”, “us”, “the Company”) handle the Personal Data of our “Client/s”, suppliers, employees, workers and other third parties. This Privacy Standard applies to all Personal Data we Process regardless of the media on which that data is stored or whether it relates to past or present employees, workers, customers, clients or supplier contacts, shareholders, website users or any other Data Subject.

This Privacy Standard applies to all Company Personnel. This Privacy Standard sets out what we expect from our personnel in order for the Company to comply with applicable law. Compliance with this Privacy Standard is mandatory. Privacy Guidelines are available to help you interpret and act in accordance with this Privacy Standard. This Privacy Standard is an internal document however it can be used as a guide for the Company’s Clients to assess their own compliance with GDPR legislation.

SCOPE

We recognise that the correct and lawful treatment of Personal Data will maintain confidence in the organisation and will provide for successful business operations. Protecting the confidentiality and integrity of Personal Data is a critical responsibility that we take seriously at all times. The Company is exposed to potential fines of up to EUR20 million (approximately £18 million) or 4% of total worldwide annual turnover, whichever is higher and depending on the breach, for failure to comply with the provisions of the GDPR. All personnel are responsible for ensuring all Company Personnel comply with this Privacy Standard and need to implement appropriate practices, processes, controls and training to ensure such compliance.

The DPO is responsible for overseeing this Privacy Standard and, as applicable, developing Privacy Guidelines. That post is held by Henry Hallward, privacy@safariguild.com Please contact the DPO with any questions about the operation of this Privacy Standard or the GDPR or if you have any concerns that this Privacy Standard is not being or has not been followed.

In particular, you must always contact the DPO in the following circumstances:

View circumstances

(a) if you are unsure of the lawful basis which you are relying on to process Personal Data (including the legitimate interests used by the Company) (see Section [5.1] below);

(b) if you need to rely on Consent and/or need to capture Explicit Consent (see Section [5.2] below);

(c) if you need to draft Privacy Notices or Fair Processing Notices (see Section [5.3] below);

(d) if you are unsure about the retention period for the Personal Data being Processed (see Section [9] below);

(e) if you are unsure about what security or other measures you need to implement to protect Personal Data (see Section [10.1] below);

(f) if there has been a Personal Data Breach (Section [10.2] below);

(g) if you are unsure on what basis to transfer Personal Data outside the EEA (see Section [11] below);

(h) if you need any assistance dealing with any rights invoked by a Data Subject (see Section [12]);

(i) whenever you are engaging in a significant new, or change in, Processing activity which is likely to require a DPIA (see Section [13.4] below) or plan to use Personal Data for purposes others than what it was collected for;

(j) If you plan to undertake any activities involving Automated Processing including profiling or Automated Decision-Making (see Section [13.5] below);

(k) If you need help complying with applicable law when carrying out direct marketing activities (see Section [13.6] below); or

(l) if you need help with any contracts or other areas in relation to sharing Personal Data with third parties (including our vendors) (see Section [13.7] below).


LAWFULNESS, FAIRNESS, TRANSPARENCY

LAWFULNESS AND FAIRNESS

Personal data must be Processed lawfully, fairly and in a transparent manner in relation to the Data Subject. You may only collect, Process and share Personal Data fairly and lawfully and for specified purposes. The GDPR restricts our actions regarding Personal Data to specified lawful purposes. These restrictions are not intended to prevent Processing, but ensure that we Process Personal Data fairly and without adversely affecting the Data Subject.

The GDPR allows Processing for specific purposes, some of which are set out below:

(a) the Data Subject has given his or her Consent;
(b) the Processing is necessary for the performance of a contract with the Data Subject;
(c) to meet our legal compliance obligations.;
(d) to protect the Data Subject’s vital interests;
(e) to pursue our legitimate interests for purposes where they are not overridden because the Processing prejudices the interests or fundamental rights and freedoms of Data Subjects. The purposes for which we process Personal Data for legitimate interests need to be set out in applicable Privacy Notices or Fair Processing Notices;

Or

CONSENT

A Data Controller must only process Personal Data on the basis of one or more of the lawful bases set out in the GDPR, which include Consent. A Data Subject consents to Processing of their Personal Data if they indicate agreement clearly either by a statement or positive action to the Processing. Consent requires affirmative action so silence, pre-ticked boxes or inactivity are unlikely to be sufficient. For our Clients consent is gained via an online form where the data subject is required to physically tick boxes to give consent freely. There may be multiple boxes to give different and individual forms of consent . Each individual consent is recorded in the Platform database for auditing and compliance purposes. Data Subjects must be easily able to withdraw Consent to Processing at any time and withdrawal must be promptly honoured and the Travel Expo 365 Platform has the technical mechanisms in place to enable withdrawal of consent. Consent may need to be refreshed if you intend to Process Personal Data for a different and incompatible purpose which was not disclosed when the Data Subject first consented which is why for such Clients the Platform asks for the these additional consents before being able to access the Services.

If a data subject does not give these consents than access is denied to the Services and consent is deemed to have been withdrawn Unless we can rely on another legal basis of Processing, Explicit Consent is usually required for Processing Sensitive Personal Data, for Automated Decision-Making and for cross border data transfers. Usually we will be relying on another legal basis (and not require Explicit Consent) to Process most types of Sensitive Data. Where Explicit Consent is required, you must issue a Fair Processing Notice to the Data Subject to capture Explicit Consent.

The Company can evidence Consent captured and keeps records of all Consents so that the Company can demonstrate compliance with Consent requirements.

TRANSPARENCY (NOTIFYING DATA SUBJECTS)

The GDPR requires Data Controllers to provide detailed, specific information to Data Subjects depending on whether the information was collected directly from Data Subjects or from elsewhere. Such information must be provided through appropriate Privacy Notices or Fair Processing Notices which must be concise, transparent, intelligible, easily accessible, and in clear and plain language so that a Data Subject can easily understand them. The Company has a project management process in place to request such Privacy notices in writing from the Client to include as part of the Consent process mechanism i.e. the online registration form.

Whenever we collect Personal Data directly from Data Subjects, including for human resources or employment purposes, we must provide the Data Subject with all the information required by the GDPR including the identity of the Data Controller and DPO, how and why we will use, Process, disclose, protect and retain that Personal Data through a Fair Processing Notice which must be presented when the Data Subject first provides the Personal Data.

When Personal Data is collected indirectly (for example, from a third party or publicly available source), you must provide the Data Subject with all the information required by the GDPR as soon as possible after collecting/receiving the data. You must also check that the Personal Data was collected by the third party in accordance with the GDPR and on a basis which contemplates our proposed Processing of that Personal Data.

PURPOSE LIMITATION

Personal Data must be collected only for specified, explicit and legitimate purposes. It must not be further Processed in any manner incompatible with those purposes. You cannot use Personal Data for new, different or incompatible purposes from that disclosed when it was first obtained unless you have informed the Data Subject of the new purposes and they have Consented where necessary.

DATA MINIMISATION

Personal Data must be adequate, relevant and limited to what is necessary in relation to the purposes for which it is Processed. You may only Process Personal Data when performing your job duties requires it. You cannot Process Personal Data for any reason unrelated to your job duties. You may only collect Personal Data that you require for your job duties: do not collect excessive data. Ensure any Personal Data collected is adequate and relevant for the intended purposes. You must ensure that when Personal Data is no longer needed for specified purposes, it is deleted or anonymised in accordance with the Company’s data retention guidelines.

ACCURACY

Personal Data must be accurate and, where necessary, kept up to date. It must be corrected or deleted without delay when inaccurate. You will ensure that the Personal Data we use and hold is accurate, complete, kept up to date and relevant to the purpose for which we collected it. You must check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. You must take all reasonable steps to destroy or amend inaccurate or out-of-date Personal Data.

STORAGE LIMITATION

Personal Data must not be kept in an identifiable form for longer than is necessary for the purposes for which the data is processed. The Storage Limitation will be defined by the Data Controller before the consent capture mechanism is deployed (Online registration form) You must not keep Personal Data in a form which permits the identification of the Data Subject for longer than needed for the legitimate business purpose or purposes for which we originally collected it including for the purpose of satisfying any legal, accounting or reporting requirements.

The Company will maintain retention policies and procedures to ensure Personal Data is deleted after a reasonable time for the purposes for which it was being held, unless a law requires such data to be kept for a minimum time. You will take all reasonable steps to destroy or erase from our systems all Personal Data that we no longer require in accordance with all the Company’s applicable records retention schedules and policies. This includes requiring third parties to delete such data where applicable.

You will ensure Data Subjects are informed of the period for which data is stored and how that period is determined in any applicable Privacy Notice or Fair Processing Notice. Data retention periods for Clients will be stored in Client files and diarised in the project management system.

SECURITY INTEGRITY AND CONFIDENTIALITY

PROTECTING PERSONAL DATA

Personal Data must be secured by appropriate technical and organisational measures against unauthorised or unlawful Processing, and against accidental loss, destruction or damage.

We have developed, implemented and will maintain safeguards appropriate to our size, scope and business, our available resources, the amount of Personal Data that we own or maintain on behalf of others and identified risks (including use of encryption and Pseudonymisation where applicable). We will regularly evaluate and test the effectiveness of those safeguards to ensure security of our Processing of Personal Data. The Company is responsible for protecting the Personal Data we hold.

The Company has implemented reasonable and appropriate security measures against unlawful or unauthorised Processing of Personal Data and against the accidental loss of, or damage to, Personal Data. The Company will exercise particular care in protecting Sensitive Personal Data from loss and unauthorised access, use or disclosure. (See Information Protection Security Policy document)

You must follow all procedures and technologies we put in place to maintain the security of all Personal Data from the point of collection to the point of destruction. You may only transfer Personal Data to third-party service providers who agree to comply with the required policies and procedures and who agree to put adequate measures in place, as requested. You must maintain data security by protecting the confidentiality, integrity and availability of the Personal Data, defined as follows:

(a) Confidentiality means that only people who have a need to know and are authorised to use the Personal Data can access it.
(b) Integrity means that Personal Data is accurate and suitable for the purpose for which it is processed.
(c) Availability means that authorised users are able to access the Personal Data when they need it for authorised purposes.

You must comply with all applicable aspects of our INFORMATION SECURITY POLICY.

REPORTING A PERSONAL DATA BREACH

The GDPR requires Data Controllers to notify any Personal Data Breach to the applicable regulator and, in certain instances, the Data Subject. We have put in place procedures to deal with any suspected Personal Data Breach and will notify Data Subjects or any applicable regulator where we are legally required to do so. The Client must also have such a policy and process in place. If you know or suspect that a Personal Data Breach has occurred, do not attempt to investigate the matter yourself. Immediately contact the person or team designated as the key point of contact for Personal Data Breaches [the DPO]. You should preserve all evidence relating to the potential Personal Data Breach.

TRANSFER LIMITATION

The GDPR restricts data transfers to countries outside the EEA in order to ensure that the level of data protection afforded to individuals by the GDPR is not undermined. You transfer Personal Data originating in one country across borders when you transmit, send, view or access that data in or to a different country.

You may only transfer Personal Data outside the EEA if one of the following conditions applies:

(a) the European Commission has issued a decision confirming that the country to which we transfer the Personal Data ensures an adequate level of protection for the Data Subjects’ rights and freedoms;
(b) appropriate safeguards are in place such as binding corporate rules (BCR), standard contractual clauses approved by the European Commission, an approved code of conduct or a certification mechanism, a copy of which can be obtained from the DPO;
(c) the Data Subject has provided Explicit Consent to the proposed transfer after being informed of any potential risks; or
(d) the transfer is necessary for one of the other reasons set out in the GDPR including the performance of a contract between us and the Data Subject, reasons of public interest, to establish, exercise or defend legal claims or to protect the vital interests of the Data Subject where the Data Subject is physically or legally incapable of giving Consent and, in some limited cases, for our legitimate interest.

DATA SUBJECT’S RIGHTS AND REQUESTS

Data Subjects have rights when it comes to how we handle their Personal Data. These include rights to:

(a) withdraw Consent to Processing at any time;
(b) receive certain information about the Data Controller’s Processing activities;
(c) request access to their Personal Data that we hold;
(d) prevent our use of their Personal Data for direct marketing purposes;
(e) ask us to erase Personal Data if it is no longer necessary in relation to the purposes for which it was collected or Processed or to rectify inaccurate data or to complete incomplete data;
(f) restrict Processing in specific circumstances;
(g) challenge Processing which has been justified on the basis of our legitimate interests or in the public interest;
(h) request a copy of an agreement under which Personal Data is transferred outside of the EEA;
(i) object to decisions based solely on Automated Processing, including profiling (ADM);
(j) prevent Processing that is likely to cause damage or distress to the Data Subject or anyone else;
(k) be notified of a Personal Data Breach which is likely to result in high risk to their rights and freedoms;
(l) make a complaint to the supervisory authority; and
(m) in limited circumstances, receive or ask for their Personal Data to be transferred to a third party in a structured, commonly used and machine readable format.

You must verify the identity of an individual requesting data under any of the rights listed above (do not allow third parties to persuade you into disclosing Personal Data without proper authorisation).

You must immediately forward any Data Subject request you receive to the DPO

ACCOUNTABILITY

The Data Controller must implement appropriate technical and organisational measures in an effective manner, to ensure compliance with data protection principles. The Data Controller is responsible for, and must be able to demonstrate, compliance with the data protection principles.

The Company has adequate resources and controls in place to ensure and to document GDPR compliance including:

(a) appointing a suitably qualified DPO (where necessary) and an executive accountable for data privacy;
(b) implementing Privacy by Design when Processing Personal Data and completing DPIAs where Processing presents a high risk to rights and freedoms of Data Subjects;
(c) integrating data protection into internal documents including this Privacy Standard, Privacy Guidelines, Privacy Notices or Fair Processing Notices;
(d) regularly training Company Personnel on the GDPR, this Privacy Standard, Privacy Guidelines and data protection matters including, for example, Data Subject’s rights, Consent, legal basis, DPIA and Personal Data Breaches. The Company must maintain a record of training attendance by Company Personnel; and
(e) regularly testing the privacy measures implemented and conducting periodic reviews and audits to assess compliance, including using results of testing to demonstrate compliance improvement effort

RECORD KEEPING

The GDPR requires us to keep full and accurate records of all our data Processing activities. The Company will keep and maintain accurate corporate records reflecting our Processing including records of Data Subjects’ Consents and procedures for obtaining Consents in accordance with the Company’s record keeping guidelines.

These records will include, at a minimum, the name and contact details of the Data Controller and the DPO, clear descriptions of the Personal Data types, Data Subject types, Processing activities, Processing purposes, third-party recipients of the Personal Data, Personal Data storage locations, Personal Data transfers, the Personal Data’s retention period and a description of the security measures in place. In order to create such records, data maps should be created which should include the detail set out above together with appropriate data flows.

TRAINING AND AUDIT

We are required to ensure all Company Personnel have undergone adequate training to enable them to comply with data privacy laws. We must also regularly test our systems and processes to assess compliance. You must undergo all mandatory data privacy related training and ensure your team undergo similar mandatory training in accordance with the Company’s mandatory training guidelines. You must regularly review all the systems and processes under your control to ensure they comply with this Privacy Standard and check that adequate governance controls and resources are in place to ensure proper use and protection of Personal Data.

PRIVACY BY DESIGN AND DATA PROTECTION IMPACT ASSESSMENT (DPIA)

We are required to implement Privacy by Design measures when Processing Personal Data by implementing appropriate technical and organisational measures (like Pseudonymisation) in an effective manner, to ensure compliance with data privacy principles. You must assess what Privacy by Design measures can be implemented on all programs/systems/processes that Process Personal Data by taking into account the following:

(a) the state of the art;
(b) the cost of implementation;
(c) the nature, scope, context and purposes of Processing; and
(d) the risks of varying likelihood and severity for rights and freedoms of Data Subjects posed by the Processing. Data controllers (our Clients) must also conduct DPIAs in respect to high risk Processing. You should conduct a DPIA (and discuss your findings with the DPO) when implementing major system or business change programs involving the Processing of Personal Data including:
(e) use of new technologies (programs, systems or processes), or changing technologies (programs, systems or processes);
(f) Automated Processing including profiling and ADM;
(g) large scale Processing of Sensitive Data; and
(h) large scale, systematic monitoring of a publicly accessible area.

A DPIA must include:
(i) a description of the Processing, its purposes and the Data Controller’s legitimate interests if appropriate;
(j) an assessment of the necessity and proportionality of the Processing in relation to its purpose;
(k) an assessment of the risk to individuals; and
(l) the risk mitigation measures in place and demonstration of compliance.

AUTOMATED PROCESSING (INCLUDING PROFILING) AND AUTOMATED DECISION-MAKING

Generally, ADM is prohibited when a decision has a legal or similar significant effect on an individual unless:

(a) a Data Subject has Explicitly Consented;
(b) the Processing is authorised by law; or
(c) the Processing is necessary for the performance of or entering into a contract.

If certain types of Sensitive Data are being processed, then grounds (b) or (c) will not be allowed but such Sensitive Data can be Processed where it is necessary (unless less intrusive means can be used) for substantial public interest like fraud prevention. If a decision is to be based solely on Automated Processing (including profiling), then Data Subjects must be informed when you first communicate with them of their right to object. This right must be explicitly brought to their attention and presented clearly and separately from other information. Further, suitable measures must be put in place to safeguard the Data Subject’s rights and freedoms and legitimate interests.

We must also inform the Data Subject of the logic involved in the decision making or profiling, the significance and envisaged consequences and give the Data Subject the right to request human intervention, express their point of view or challenge the decision. A DPIA must be carried out before any Automated Processing (including profiling) or ADM activities are undertaken.

DIRECT MARKETING

We are subject to certain rules and privacy laws when marketing to our customers. For example, a Data Subject’s prior consent is required for electronic direct marketing (for example, by email, text or automated calls). The limited exception for existing customers known as “soft opt in” allows organisations to send marketing texts or emails if they have obtained contact details in the course of a sale to that person, they are marketing similar products or services, and they gave the person an opportunity to opt out of marketing when first collecting the details and in every subsequent message.

The right to object to direct marketing must be explicitly offered to the Data Subject in an intelligible manner so that it is clearly distinguishable from other information. A Data Subject’s objection to direct marketing must be promptly honoured. If a customer opts out at any time, their details should be suppressed as soon as possible. Suppression involves retaining just enough information to ensure that marketing preferences are respected in the future.

SHARING PERSONAL DATA

Generally we are not allowed to share Personal Data with third parties unless certain safeguards and contractual arrangements have been put in place. You may only share the Personal Data we hold with another employee, agent or representative of our Company if the recipient has a job-related need to know the information and the transfer complies with any applicable cross-border transfer restrictions.

You may only share the Personal Data we hold with third parties, such as our service providers if:

(a) they have a need to know the information for the purposes of providing the contracted services;
(b) sharing the Personal Data complies with the Privacy Notice provided to the Data Subject and, if required, the Data Subject’s Consent has been obtained;
(c) the third party has agreed to comply with the required data security standards, policies and procedures and put adequate security measures in place;
(d) the transfer complies with any applicable cross border transfer restrictions; and
(e) a fully executed written contract that contains GDPR approved third party clauses has been obtained.

CHANGES TO THIS PRIVACY STANDARD

We reserve the right to change this Privacy Standard at any time without notice to you so please check back regularly to obtain the latest copy of this Privacy Standard. We last revised this Privacy Standard on 25-03-2018 This Privacy Standard does not override any applicable national data privacy laws and regulations in countries where the Company operates.

APPENDICES

APPENDIX 1 – PRIVACY GUIDELINES

The new GDPR legislation has been designed to protect the rights of an individual and how their data is used by organisations. Travel Expo 365 has a legal responsibly to ensure that it is compliant with such legislation. When acting on behalf of a Client to deliver the Services we have been commissioned to provide we are Data Processors and our Client/s are Data Controllers. Please refer to the Privacy Standard document to clarify the difference between each.

Our responsibilities include –

Setting up an online registration form to capture the data of the users who intend to access the Services.

To ensure this online registration form is fully compliant with GDPR legislation. Our DPO (Emma Riley) will give you full training on how to set up a form that meets these legal requirements

Advising our Client/s on how to meet their own legal responsibilities as Data Controllers when they commission us to deploy the Services on their behalf

Ensuring that the Platform is built with Privacy by Design in mind. This means that the software is built to meet GDPR legislation and the project management processes to deliver the Services are GDPR compliant.

Reporting breaches of data to the DPO. Data breach definitions and actions to report and resolve such breaches are noted in the Privacy Standard document.

Keeping a data subjects personal information secure both electronically and any paper based details of that subject

Travel Expo 365 platform has been built from the ground up with security at the forefront of its development. The service is hosted within the AWS (Amazon Web Services) eco system, the Salesforce.com platform and on UK Web Hosting servers which are all accredited with ISO27001 certification. There is a comprehensive Information and Security Policy that sits on top of that with a set of processes and systems in place to support the overall security strategy of the Travel Expo 365 platform. All personnel are trained on this set of policies as part of their on-boarding process with amendments and revisions being communicated within 2 weeks of them becoming part of this policy document.

The data centre is based in the EU (Ireland) within the AWS environment and on UK Web Hosting servers. This is a legal requirement for our Clients to be GDPR compliant. The system is penetration tested (ask the DPO about this technical process) on an annual basis however we do advise that any Client carries out their own pen-testing to meet their own security criteria. Regular vulnerability scanning is performed across the AWS EC2 instances and associated services.

The Client is the Data Controller) and is responsible for determining the purposes for collecting data and is accountable for actions of the Data Processor (Travel Expo 365). Travel Expo 365 must comply with the Clients instructions in relation to maintaining security, keeping records and reporting breaches. Travel Expo 365 ae responsible for reporting any security breaches to the Information Commissioner's Office within 72 hours of the breach occurring. This will include; the nature of the breach, number of records and individuals impacted, consequence of the breach and measures taken to address and mitigate the breach.

APPENDIX 2 – PRIVACY by DESIGN

The service deploys SHA & AES 256 bit encryption. All data is encrypted in both transit and at rest. Passwords are hashed with bcrypt. This is technical jargon that means that the platform deploys the highest levels of encryption available to support our security strategy and processes. Travel Expo 365 have recently developed their Platform to ensure GDPR compliance – this includes storing a digital record in the database of the user’s original consent at the point of registration (online registration form) including a date and time stamp as well as granular consents, which are also stored individually where applicable – these consents relate to how a data subject agrees to be contacted by the Data Controller.

Users can, at any time through their digital profile, change their preferences easily and consent can be withdrawn as required. Each action is date and time stamped in the database, which the client has access to via their admin portal should they request to audit the Travel Expo 365 platform. Travel Expo 365 insists on the Client drawing up a written document that sets out their GDPR policy relating to how the Services are to be used in terms of users data to comply with GDPR regulations e.g how long they require Travel Expo 365 as data processors to store data for and the submission of their own compliant Privacy notice for registered users of the Services to read and consent to. The Travel Expo 365 Platform has been designed so that user data can be removed from the system after a set period and also on an individual basis upon request by the Data Subject. It will be the Client’s (Data Controller) responsibility to download data from the system and provide instruction on which records to remove and when. We also have a template to issue to Clients to help support a DPIA on their behalf if required.

APPENDIX 3 – Contractual clauses for privacy, GDPR compliance and security of information (Client document)

DATA PROTECTION

DEFINITIONS

Data Protection Legislation: (i) unless and until the GDPR is no longer directly applicable in the UK, the General Data Protection Regulation ((EU) 2016/679) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in the UK and then (ii) any successor legislation to the GDPR or the Data Protection Act 1998.

Data, Personal Data, Data Controller, Data Processor, Data Subject and Processing shall have the same meanings as are assigned to those terms in the Data Protection Legislation. Purpose means registering and managing attendees throughout an event and any subsequent events and interactions, and providing an analysis of how attendees interact with the event and any subsequent events.

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1. Each party will comply with all applicable requirements of the Data Protection Legislation. This clause 28 is in addition to, and does not relieve, remove or replace, a party’s obligations under the Data Protection Legislation.

2. Where either party is a Data Controller, that party shall comply with its obligations under the Data Protection Legislation including, without limitation, by:

3. obtaining all consents required; and

4. providing to the other party all information necessary to that party to perform its obligations; and

5. co-operating with the other party so that each party is able to comply with its obligations in respect of any Data collected, held or processed as part of this contract.

6. The parties acknowledge that, with regard to the processing of Personal Data by the Company, it is their intention that the Client is the Data Controller and Company is the Data Processor processing Data for the Purpose of behalf of the Client.

7. Without prejudice to the generality of clause 28.1, the Company shall, in relation to any Personal Data processed in connection with the performance by the Company of its obligations under this contract:

8. process that Personal Data only on the written instructions of the Client unless the Company is required by the laws of any member of the European Union or by the laws of the European Union applicable to the Company to process Personal Data (Applicable Laws). Where the Company is relying on laws of a member of the European Union or European Union law as the basis for processing Personal Data, the Company shall promptly notify the Client of this before performing the processing required by the Applicable Laws unless those Applicable Laws prohibit the Company from so notifying the Customer;

9. the Company, as Data Processor, undertakes to the Client to process the Personal Data only for the purpose and in accordance with the terms of this contract and on the lawful instructions reasonably given by the Client Company from time to time; and that:

10. the Company shall have in place appropriate technical and organisational measures against unauthorised or unlawful processing of Personal Data and against accidental loss or destruction of, or damage to, Personal Data (including, but not limited to, adequate backup procedures and disaster recovery systems and ensuring confidentiality, integrity and resilience of its systems);

11. Company shall ensure that each of its employees, agents and subcontractors are made aware of the Company’s obligations under this contract, and will keep the Personal Data confidential;

12. Company shall allow its data processing facilities, procedures and documentation to be inspected by the Client for which representatives order to ascertain compliance with the terms of this contract;

13. Company shall promptly inform the Client if any Personal Data is lost or destroyed or becomes damaged, corrupted or unusable;

14. Company shall notify the Client without undue delay on becoming aware of a Personal Data breach;

15. Company shall not process or transfer Personal Data outside the European economic area except with the express prior written consent of the Client and provided that the data subject has enforceable rights and effective legal remedies;

16. Company shall assist the Client at the Client’s cost in responding to any request from a data subject and in ensuring compliance with its obligations under the Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators;

17. Company shall not divulge any Personal Data to any other Company applications or systems, or to any third-party without the prior authorisation of the Data Controller;

18. At the written direction of the Client, the Company shall delete or return Personal Data and copies thereof to the Client on termination of the agreement unless required by Applicable Law to store the Personal Data.

19. Notwithstanding the provisions of clause 6, and subject to clause 28.6 below, the Company agrees to indemnify and keep indemnified and defend the Client against all costs, claims, damages or expenses incurred by the Client or which the Client may become liable due to any failure by Company or its employees, subcontractors or agents to comply with the obligations under this contract.

20. The Client acknowledges that the Company is reliant on the Client for direction as to the extent to which Company is entitled to use process the Personal Data. The Client indemnifies the Company against all costs, claims, damages or expenses incurred by the Company or for which the Company may become liable consequent on it following the instructions and directions of the Client under this contract.

21. Company may authorise one or more third-party subcontractors to process the Data for the purpose under this contract provided that:

22. full details of the subcontract have been provided to the Client and the Client has expressly consented to the subcontractor being appointed;

23. the subcontractor’s contract is on terms which are substantially similar to those set out in this clause 28; and

24. the subcontractor’s contract will terminate automatically on the termination of this contract for any reason.

Events
PR Media

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PR Media

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Lorem Ipsum is simply dummy text of the printing and typesetting industry:

Lorem Ipsum is simply dummy text of the printing and typesetting industry. Lorem Ipsum has been the industry's standard dummy text ever since the 1500s, when an unknown printer took a galley of type and scrambled it to make a type specimen book.

Lorem Ipsum is simply dummy text of the printing and typesetting industry. Lorem Ipsum has been the industry's standard dummy text ever since the 1500s, when an unknown printer took a galley of type and scrambled it to make a type specimen book.

Lorem Ipsum is simply dummy text of the printing and typesetting industry. Lorem Ipsum has been the industry's standard dummy text ever since the 1500s, when an unknown printer took a galley of type and scrambled it to make a type specimen book.

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Travel Expo 365 product promotion image
Travel Expo 365 product promotion image
Travel Expo 365 product promotion image

Partnered Opportunities
as a Satsa Member

We would love you to join SATSA on Travel Expo 365 – a new and engaging online marketing platform driving revenues and increasing profitability for you 365 days a year, 24/7. Joining the South Africa Hall with a stand will deliver you extended visibility and a global reach to 104,000 fully vetted agents placing business in Africa.

Global promotion events throughout the year

SATSA has partnered with Travel Expo 365 to provide SATSA members with stands in the South Africa Hall. SATSA will run a number of global promotion events throughout the year to promote the membership to the Travel Expo 365 agent community.

Travel Expo 365 will provide you with the tools to:

Generate new business – spend more time with existing clients, network, improve product knowledge, learn about the latest industry developments

Showcase your product – reach more buyers globally, instant notifications: you are never offline

Be exclusive, engaged and operational – easy set-up, sign up once and pay once for the year, enhance your marketing and sales, update your marketing collateral as often as you wish, remain relevant to buyers

Manage your content – curate and manage your own video channel content online, interactive schedule of events, presentations, product development and discussions, webinar presentations, showcase featured content on behalf of sponsors or partners

Your stand at Travel Expo 365 is available 365 days a year, 24/7 and includes:

Face-to-face meetings with delegates

Your stand is never offline

Attendees have their own event bag to download collateral

Data capture and your own analytics

Text chats, audio or video chats for 1 to 1 online meetings

As a SATSA member we are offering a guaranteed low rate stand cost for you, payable in South African Rand – contact us on expo@travelexpo365.com for more information and to book a short online demo so we can show you how your stand could look!


The Travel Buyer Community
A resource of 104,000 qualified global travel buyers

The buyer consortium partnership with Travel Expo 365 is with The Safari Guild and IATA, creating a pool of global travel buyers in all budget ranges.


Country/Region Breakdown

Region IATA Travel Agents Tour Operators Other Travel Buyers/Media TOTAL
Americas 31,305 2,331 18,836 83,210
EMEA 33,069 1,009 2,211 5,551
Asia & Oceania 18,836 4,190 5,635 15,894
Total 83,210 38,268 26,682 104,655

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Discover Opportunities
For your own digital exhibition

If you already organise your own travel exhibition, Travel Expo 365 can help you extend your reach 365 days a year, 24/7 to create a DIGITAL EXHIBITION, on your own platform.

Reach and engage
with buyers

Differentiate your travel trade exhibition offering to exhibitors – provide your exhibitors with the chance to extend their stand presence throughout the whole year – before, during and after your exhibition. Reach and engage with buyers that couldn’t attend your travel trade exhibition increasing delegate attendance, remind buyers and visitors to follow up with the suppliers they met, and get them to meet the exhibitors they missed.

Event Days
Create additional event days online for opportunities missed


There is never enough time during a tradeshow to run all the events you want to and be able to reach all the participants. On Travel Expo 365, you can create Event Days where you promote additional product, trends and functions to suit your diary.

Invite those delegates (buyers and suppliers) to help your own brand awareness and reach. Invite the press and industry trade to attend.

Keep and publicise your content
Promote the content from your exhibition


Don’t let the content from your exhibition go to waste while you work on next year. Keep your content from each year within easy reach of visitors, press and suppliers ensuring they get to see everything they missed. Keep your speakers and delegates happy and your content in one place.

Maintain exhibitor and visitor relationships
Keep in touch with your exhibitors and buyers throughout the year


You will be able to promote your travel trade exhibition throughout the year with key publicity pieces, news and information whether it’s before, during or after the physical event. Keeping in touch with your participants maintains a year-long relationship with a reason to attend, review and commit.

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Discover Opportunities
As a Travel Buyer

The opportunity for you as a buyer is to access the global travel community when you want to research, contact or arrange a meeting. Whenever the time is right for you.

Global reach
of the travel community

Whether you attend tradeshows throughout the year or not, your opportunities to research the best deals, the best venues and the right packages are endless, whenever you are ready.

The Travel Community
Global reach of the travel community at your fingertips


Travel Expo 365 gives you the opportunity to travel through destinations, reach products and DMCs at your own pace, in your own time. Arrange appointments with those suppliers you want to reach out to, download information and keep it in your content area and manage your own time more effectively and cost efficiently.

Join presentations and seminars when you can, and if you are not around for live event days, join them later to review! Network when you can, and with whom you want to meet with. The pressure is off, the ease is on for you to do business.

Online instant resources
Digital event bags, webinar and auditorium trends resources and more


Once you register on the Travel Expo 365 platform, you can easily access destination halls and supplier products. You have your own digital event bag where you can collect content from the stands, resource centre and live presentations. What you need – whenever you need it.


What best describes your product/service?

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Discover Opportunities
as an Industry Supplier

Travel Expo 365 provides industry suppliers with an engaging online marketing platform to drive revenues, increase profitability and promote your destination or product – 365 days a year, 24/7.

Interact with the travel community 365 days a year, 24/7

If you are a destination, hotel or lodge, resort, airline, cruise or travel supplier, you can now interact with the travel community 365 days a year, 24/7. If buyers don’t attend industry events or you miss them at a show you have an online presence keeping you accessible and visible.

Your interactive stand comes complete with a suite of online marketing and engagement tools, together with a vetted community of travel trade buyers in established and emerging outbound markets. Removing geographical boundaries that prevent travel suppliers from accessing buyers for their products and services, Travel Expo 365 also reaches agents and influencers that do not typically attend traditional travel trade exhibitions.

Unique features
Data capture analytics, attendee profiles, appointment system and more

Registration and data capture are key components of Travel Expo 365. Users have to register to enter Travel Expo 365, essential for generating their profile and establishing their digital footprint to enable data capture and recording analytics. Each registered visitor has their own unique profile where they can upload and display information about themselves, as well as their various social media credentials.

You will be able to see an instant snapshot of attendees who are at your stand or who have visited – through selected fields of registration data.

The online registration system is a fully integrated part of the platform and gives you the ability to access live registration numbers and data. You can choose any quantity of custom fields for your registration page.

Marketing from anywhere
365 days a year, 24/7

By taking a stand at Travel Expo 365, you can access your online event systems statistics 24/7 via your administration panel. Here you will have complete transparency as to how successful the online event is on a minute by minute basis; who has registered, who attended, where they went, what they viewed and downloaded and how they interacted.

Each stand has its own individual analytics and data capture section with the ability to download a transcript of all web chat conversations, as well as what was downloaded or viewed and who downloaded or viewed it.

As a stand holder you will have your own private meeting slots for buyers to meet with you - time slots can be as long or as short as you like. Appointments can be with speakers, press, trade visitors or representatives.

Meetings can be hosted for between 1 and 50 users at a time (video chat is 1-4 maximum). A full diary management system is available in the stand administration panel with meeting slot approval, calendar and reminder email set up. A meeting can be set to run as a text chat, audio or video chat.

Your Stand
Package

Your stand functionality
Email marketing, social media feeds and video meetings


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Your Stand Package

Single point of contact

Meeting appointment system

Who is at my stand? – real time stand attendance manifest with full contact information

Contact Us facility if the stand is unattended – full contact information

Business card exchange facility

Promotional / product video viewable on the stand

Live presentations for Agent Training module for up to 8 presenters

Stand webinar feature

Live 1-1 and group text chats with stand visitors

Live 1-1 video meeting room/chat for face-to-face meetings

Information download area - facility for brochures, videos and documents

Social media feeds – LinkedIn, Facebook & Twitter

Email marketing system to stand visitor database

Analytics - metrics of all agent activity/meetings on the stand

Maximum impact
Helping you to meet your marketing and communication objectives


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Reduce your budget and increase productivity

Reduce travel costs

Reduce sales collateral production costs

Extend your expo presence from a few days to year-round for the same cost

Reduce out-of-office time, using existing internet connectivity to service more buyers in the saved time

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Reach a geographically dispersed audience

Agents are everywhere but few attend travel expos – every agent that can sell your product is accessible online

Educating agents through webinars has no viewer limitations reducing the cost of agent training whilst increasing the reach

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Increased accessibility and availability

Multiple communication tools including:

Video – deliver your videos seamlessly in platform as soon as someone visits your stand...

Face-to-face video chat within the platform – meet as you would at a normal travel expo...

Text chat within the platform – present to many agents and take questions by text chat ensuring no questions go unanswered, ever...

Email notifications when your stand has video viewings, meeting requests, collateral downloads and v-card downloads – never miss a stand visitor again...

If you are away your colleagues can follow up any stand visit notifications – no cold leads...

Always connected – you can manage your stand from anywhere with an Internet connection 365 days a year, 24/7 – always in touch via any smart device – phone, pad or computer

Discover
Global opportunities

Travel Expo 365 is a global marketing medium for the travel trade sector, designed to drive new business through a highly engaging online platform - 365 days a year, 24/7.

An online forum for buyers and sellers to conduct business, the Travel Expo 365 platform improves product knowledge and enables agents to learn about the latest industry developments from exhibitors enabled with one-to-one video chat, video conferencing, training webinars and live webcasts.

Travel Expo 365 works with leading associations, agents and global companies ensuring that a maximum global reach is continuous, up-to-date and flexible at all times.

Available 24 hours a day, 365 days a year and accessible via PC, tablet or mobile phone

One stop shop – all agents, buyers, products, brands and DMCs in one place

No geographical or financial boundaries to attendance – a truly global meeting place

Significantly higher attendance and networking within a global framework building new relationships and re-connecting with established ones

Trackable ROI for stand holders / easy access of content and potential product for buyers

Time efficient and cost effective ‘trading’ for all with access to more ‘digital’ travel trade buyers and suppliers

Organised promotional events and activities including webinars and seminars to be viewed live, on demand or downloaded

Increasing registrations and audiences for exhibitors and content suppliers / Increasing flexibility and global reach for agents and buyers

Join Travel Expo 365
The Digital Platform with a Global Reach,
365 days a year, 24/7

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Expand your global reach
Online 365 days a year, 24/7
with travel expo 365

Travel Expo 365 is an innovative marketing medium designed to drive revenues and increase profitability through a highly engaging online platform (100% Cloud based). It is a forum to improve product knowledge where delegates can connect directly via dedicated chat rooms.

Join the
SATSA Hall
(Southern Africa
Tourism Services Association)

Travel Expo 365
Global Opportunities

Join Our B2b Exhibitions

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Availability

365 days a year, 24/7

A one stop shop for both buyers & sellers

Global exposure

timeline

Data & Analytics

Attendee lists, qualified audience

Analytical reports detailing all visitor interactions

Customised reports

All downloadable into Excel or PDF format for monthly meetings

Transcripts of all online conversations

local_atm

Cost & Time Efficient

Easily measurable ROI

Minimal outlay, maximum 365 exposure

Efficient use of sales / marketing staff time

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Interaction

Live web chat and video facility

Scheduled interactive webinars

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Join Travel Expo 365
The Digital Platform with a Global Reach,
365 days a year, 24/7