PRIVACY POLICY

Last Updated: March 24, 2022

 

This Privacy policy (“Policy”) governs the access to and use of all parts of the website and mobile application branded as KINGO of DIGILYO TRAVEL LTD and licensed to operate under KINGO SMART TRAVEL LTD referring to the domain www.kingotravel.com (hereinafter referred as the “Website” “App”).  All documents, data, materials or other information are made available on the Website and/or App.

 

This Policy applies to all visitors, users and others who access or use the Website and/ or App. Please take a moment to read this Privacy Policy along with the Terms & Conditions and Cookies Policy carefully before making any bookings, and note that by using KINGO , you are consenting to the collection, storage, processing and transfer of your personal information as described in this Policy.

 

KINGO processes your personal data under this Policy and in accordance with applicable legislation, including the European Union, General Data Protection Regulation (2016/679) and the applicable national data protection laws of the jurisdiction in which we provide services to you.

 

 

1. PURPOSE

 

We at KINGO know and understand how important it is for you to understand how we collect, store, process, share and use your personal data. We respect and protect the privacy of our users’ personal data on our platform. 

 

The purpose of this Policy is to describe how KINGO collects, processes and manages users’ personal data through the Website and/or App, that are developed to offer KINGO services.

 

1. DEFINITIONS 

 

1. ‘Personal data’ means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;

 

1. “User(s)” means any natural legal person over 18 years of age with legal capacity who access, visits and successfully completes the booking process in the Website and/or App

 

1. ‘Consent’ means any freely given, specific, informed and unambiguous indication of the User wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of Personal data relating to him or her including the Personal data of the people who are making the booking through him or her.

 

1. ACCEPTANCE 

 

By accessing and using KINGO Website and/or App, you are consenting and accepting the terms of this Policy. If you do not agree or consent with the details we require with any aspect of this Policy, you shall at any time withdraw your consent and discontinue access or use of our services.

1.   PERSONAL DATA COLLECTED FROM USERS

 

Your Personal data is collected and stored with KINGO in order to provide, develop and to enhance our products and services including technical infrastructure, security, compliance, fraud prevention and customer support.

 

Information stored by KINGO are;

 

1. Personal information

• Personal and Contact details: Title, full name, email address, phone number
• Passport details: Passport number, date of birth, nationality
• Payment Information: Card number, security number, expiration date and cardholder name
• Authentication data: billing information, billing address, digital wallet address, residence address, username
• Dietary requirements and health issues (relevant to travel arrangements or required by the relevant travel service provider(s) (e.g., accommodation or tour providers)
• Information provided by filling the forms on our website and/or App.
• Call recordings; calls may be recorded for the purpose of quality control and staff training.
• Social media: by interacting with the social media features on our website and/or App (Facebook, Twitter or Instagram), you will be bound by the privacy policies of the respective social media companies

 

1. Browser Information 

• IP Address 
• Login information 
• Browser type and version
• Time zone setting
• Platform
• Operating System 
• Transaction history
• Pages accessed and links clicked
• Public blockchain data

 

1. Log information 

• Device- specific information
• Location 
• System activity 
• Uniform Resource Locators [URL] 
• Data collected via Cookies

 

1. HOW WILL WE COLLECT THIS INFORMATION?

 

We usually collect your Personal data from the information you submit through our Website and/or App.

 

We may collect the data;

1. when you purchase or make enquiries regarding a travel arrangement via Website and/or App
2. when you book the travel with us
3. when you do the payments in order to complete the booking process
4. when you subscribe to receive our marketing materials
5. when you speak to our customer support service
6. when you enter into any competitions or register for promotions with us 
7. when you connect with us through any social media platform

 

1. WHY USERS’ PERSONAL DATA IS USED

 

1. To perform our services and to complete your booking
2. To communicate with User
3. To provide, troubleshoot and improve KINGO Services
4. To enforce our terms in our Terms & Conditions of our Website and/or App
5. To complete the booking process and the payment process
6. To provide customer services
7. To ensure quality control
8. To ensure network and information security
9. To engage in marketing activities
10. Purposes for which we seek User’s consent

 

1.   DATA TRANSFER

 

We may share your Personal data with selected third parties, including collaboration partner or provider(s), distributors and subcontractors, when it is necessary for the delivery of our services, or when there is a legal basis to do so. The aforementioned third parties only collect, use and disclose your information in the ways indicated by us in order to provide adequate services.

 

We further ensure that we comply with the applicable data protection legal norms and we shall only share information in the following circumstances:

 

1. with applicable regulatory bodies to comply with our legal obligations.
2. with a collaboration partner(s) or provider(s) of KINGO. (Airlines, hotels, tour operators, transfer providers, car rentals and/or activity providers who fulfill your travel reservations.)
3. with service providers under contracts to operate the business. For example, to aim of providing IT solutions for operating the Website and/or App, and for other purposes such as;

• Cloud storage
• Payment process
• Transaction Monitoring
• Network Infrastructure 
• Security 
• Customer Support
• Marketing 
• Data analytics 

 

1. with the outsourced service providers who can provide and ensure adequate level of Personal data protection. 
2. with our affiliates/ business partners as a general part of conducting business to offer services 
3. with financial institution (payment gateways) which we partner to process payments you have authorized 
4. with outside of the European Economic Area (EEA). In the event when you want to book a ticket with a carrier from a Third Country or when you order a service from a provider based in a Third Country. We may also transfer your Personal Data outside of the EEA to Data Processors located in Third Countries. For transfers to recipients in countries where we cannot rely on the decision of the adequate level of protection according to Art. 45 of the GDPR or appropriate safeguards according to the Art. 46 of the GDPR, we will transfer your Personal Data based on the exception in the Art. 49 Para. 1 Lett. b) of the GDPR. Each selected carrier or service provider will treat your Personal data in accordance with its own Privacy Policy (which is published on every carrier's website). Disclosure of Personal data to other collaboration partners or providers will be done in accordance with the applicable Personal data laws and regulations.

 

KINGO ensures that the collaboration partner or provider(s) and affiliates/ business partners who process personal information to acknowledge the confidentiality of this information and to protect the User’s right to privacy by complying with all applicable privacy and data protection laws 

 

1.    PROTECTION AND STORAGE OF PERSONAL DATA

 

KINGO maintains physical, technical, administrative and procedural safeguards in connection with the collections, storage and disclosure of User’s Personal data. We use firewall barriers, encryption techniques and authentication procedures to maintain the security of User’s online sessions. 

 

KINGO Users are requested to protect their account password from unauthorized access to avoid unnecessary authentication issues. In order to circumvent loss, misuse, unauthorized acquisition or alteration of your data, Users are requested to choose the strongest password and to protect the account privacy data from any third-parties.  In the event of unauthorized access, the KINGO insists the Users to notify the customer support immediately. 

 

Furthermore, KINGO does not ensure the security or privacy of data transmitted via email, phone or SMS, till such data reaches the domain of our network, since we have no access to protect such data until it reaches our network domain. 

 

1. DATA RETENTION

 

Personal data is retained as long as is necessary, for the purpose that it was originally obtained and in order to protect us against any contractual claims, generally we shall retain your Personal data for a period of 6 years. Furthermore, information or data collected via technical means such as cookies, web page counters and other analytics tools may be kept for a period of up to one year as applicable to the Cookie policy.

 

1.   GENERAL DATA PROTECTIONS REGULATIONS OF EU

KINGO is obliged and bound by the General Data Protection Regulation [GDPR], which is drafted and passed by the European Union to regulate and protect the data of EU citizens. This regulation came into effect on May 25, 2018 and KINGO will be liable for any violation of its privacy and security standards, with penalties.

According to the GDPR, KINGO provides privacy notice, 

• in a concise, transparent, intelligible and easily accessible form, 
• written in clear and plain language, 
• delivered in a timely manner; and 
• provided free of charge.

1.   YOUR RIGHTS PROTECTED UNDER THE GDPR

 

Under certain circumstances, you have rights under data protection laws in relation to your Personal data which are set out in more detail below;

 

1. Request access 

This enables you to receive copies of your Personal data. We hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us. 

 

1. Request erasure 

This enables you to request us to delete or remove Personal data where there is no good reason for us continuing to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal data. 

 

1. Request to Rectification

You have the right to request that we correct any of your Personal data if it is inaccurate or incomplete.

 

1. Request to Restrict Processing

This enables you to object to the processing of your Personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.

 

1. Request to Object Processing

You have the right to object to the processing of your Personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal data for direct marketing purposes. 

 

1. Request to transfer 

If you request us, we will provide you or a third party you have chosen, your Personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

1. Request to withdraw consent

In cases where the processing is based on your consent, you have the right to withdraw your consent to such processing at any time.

 

1.   PRIVACY TERMS IN USING DIGITAL ASSETS AND BLOCKCHAIN

 

The digital assets are recorded on a public blockchain.  It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks which are not controlled or operated by any third-party collaboration partner or provider(s) or affiliates or business partners of KINGO, and we have no access or authority to erase, modify or alter any Personal data from such networks.

 

 

 

1.  MODIFICATIONS

 

We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time and such update details shall be indicated at the top of this page. We will review and revise this Policy when there are any material circumstances arisen that may affect our ability to apply this Policy pursuant to the provisions of statutory and law requirements. What constitutes a material change will be determined at our sole discretion.

 

We will inform our Users on all material amendments to this Policy by publishing the updated version of this Policy on our Website and/or App. When an updated version of the Policy is released, your continued access to the Website and/or App means that you agree to the updated content and agree to abide by the updated Policy.

1. CONTACT INFORMATION

 

In the event of any comments, questions, inquiries or complaints regarding this Policy, the User has the right to submit questions and/or concerns at infor@kingo.travel or please visit the About Us page for more information.