PRIVACY POLICY

We at Diaspora Museum Tours LTD have created this privacy policy (this “Privacy Policy”) because we know that you care about how the information you provide to us is used and shared. This Privacy Policy applies to our information collection and uses practices: (i) online when you visit our website and (ii) offline when you provide information to us via email, social media, phone, WeChat, WhatsApp, in person, or via any other channel listed or not here.

This privacy notice provides you with details of how we collect and process your data:

By providing us with your data, you warrant that you are over 13 years of age.

allwaystravelling.com is the data controller, and we are responsible for your data (referred to as “we,” “us,” or “our” in this privacy notice).

The information we hold about you must be accurate and up to date. Please let us know if your personal information changes by emailing us anytime.

Capitalized terms not defined in this Privacy Policy shall have the meaning outlined in our Terms of Service.

Acceptance of Terms
By visiting our website, you agree to the terms of this Privacy Policy and the accompanying Terms of Service, both of which govern your use of the website. You also agree to this Privacy Policy’s terms by providing us with information offline.

The Information We Collect
In operating the website and interacting with you, we will collect (and receive) the following types of information.

1. 1. PERSONAL INFORMATION.
      When you sign up to receive any of our newsletters, like or engage with any social media channel, respond to a survey, request a reservation, or purchase any product or service, you may be required to provide us with personal information about yourself, such as your name, address, email address, phone number, and credit card information. We do not collect any personal information from Visitors when they use the website unless they provide such information voluntarily, such as by registering or sending us an email or signing up for a newsletter. All information we collect and receive under this section is collectively called “Personal Information.”

1B: WHAT DATA DO WE COLLECT ABOUT YOU, FOR WHAT PURPOSE, AND ON WHAT GROUND DO WE PROCESS IT

Personal data means any information capable of identifying an individual. It does not include anonymized data.

We may process the following categories of personal data about you:

Communication Data includes any communication you send us through the contact form on our website, email, text, social media messaging, or any other communication you send us. We process this data to communicate with you for record-keeping and the establishment, pursuance, or defense of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records, and to establish, pursue or defend legal claims.

Customer Data includes purchases of goods and services, such as your name, title, billing address, delivery address, phone number, contact details, purchase details, and card details. We process this data to supply the goods and services you have purchased and to keep records of such transactions. Our lawful ground for this processing is the performance of a contract between you and us and taking steps to enter into such a contract at your request.

User Data includes data about how you use our website, any online services, and any data you post for publication on our website or through other online services. We process this data to operate our website and ensure relevant content is provided to you, to ensure the security of our website, to maintain back-ups of our website and databases, and to enable publication and administration of our website, other online services, and business. Our lawful ground for this processing is our legitimate interests, which in this case, enable us to properly administer our website and business.

Technical Data that includes data about your use of our website and online services such as your IP address, your login data, details about your browser, length of visit to pages on our website, page views and navigation paths, details about the number of times you use our website, time zone settings and other technology on the devices you use to access our website. The source of this data is our analytics tracking system. We process this data to analyze your use of our website and other online services, to administer and protect our business and website, to deliver relevant website content and advertisements to you, and to understand the effectiveness of our advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to enable us to properly administer our website and business, grow our business, and decide our marketing strategy.

Marketing Data includes your preferences in receiving marketing from our third parties and us and your communication preferences. We process this data to enable you to partake in our promotions, such as competitions, prize draws, and free giveaways, to deliver relevant website content and advertisements to you and measure or understand the effectiveness of this advertising. Our lawful ground for this processing is our legitimate interests, which in this case are to study how customers use our products/services, develop them, grow our business and decide our marketing strategy.

We may use Customer Data, User Data, Technical Data, and Marketing Data to deliver relevant website content and advertisements to you (including Facebook adverts or other display advertisements) and to measure or understand the effectiveness of the advertising we serve you. Our lawful ground for this processing is legitimate interests which is to grow our business. We may also use such data to send other marketing communications to you. Our lawful ground for this processing is either consent or legitimate interests (namely, to grow our business).

Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

We require your explicit consent for processing sensitive data. When you submit your details, we will send you a further communication asking you to confirm your consent to this process.

Where we are required to collect personal data by law or under the terms of the contract between you and us, do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered, but if we do, we will notify you at that time.

We will only use your data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this, please email us. If we need to use your details for an unrelated new purpose, we will let you know and explain the legal grounds for processing.

We may process your data without your knowledge or consent, where this is required or permitted by law.

We do not carry out automated decision-making or any automated profiling.

2. RESERVATION INFORMATION.
   When you place a reservation, you must provide us with information about the products and services you want to purchase. Such information is collectively called “Reservation Information.”
3. BILLING INFORMATION.
   When you wish to purchase a product or service, you must provide certain information in addition to the Personal Information and Order Information noted above. Such information may include a debit card number, credit card number, expiration date, billing address, activation codes, and similar information. Such information is collectively called “Billing Information.” Although we will have access to the Billing Information, it will also be collected and processed by our third-party payment vendors according to the terms and conditions of their privacy policies and terms of use.
4. OTHER INFORMATION
   In addition to the information noted above, we may collect additional information (collectively, the “Other Information”). Such Other Information may include:
5. From You. Additional information about yourself that you voluntarily provide us through a survey or other means, such as company name, number of employees, country of operation, product, and service preferences that do not identify you personally.
6. From Your Activity. Information that we automatically collect when you use the website, including, without limitation: IP addresses, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device; browser type and language; referring and exit pages and URLs; date and time; the amount of time spent on particular pages; what sections of the website you visit; and similar data; and information about your device, including the type of device; universally unique ID (“UUID”); advertising identifier (“IDFA”); MAC address; operating system and version (e.g., iOS, Android or Windows); carrier and country location; hardware and processor information (e.g., storage, chip speed, camera resolution, NFC enabled); network type (WiFi, 3G, 4G, LTE); and similar data.
7. Third-Party Analytics We use third-party analytics services (such as Google Analytics) to evaluate your use of the website, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the website and mobile and Internet usage. These third parties use cookies and other technologies to help analyze and provide us with the data. By accessing and using the website, you consent to process data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the website. d. From Other Sources. We also may collect or receive information from third parties, such as Facebook and other third-party social media sites.

Accessing and Modifying Personal Information and Communication Preferences
You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link at the bottom of any All Ways Travel/ Knowing Cuba email. Customers cannot opt out of receiving transactional emails related to their accounts or orders. We will use commercially reasonable efforts to process such requests on time. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

How We Use and Share the Information
We use the Personal Information, the Order Information, the Billing Information, and the Other Information (collectively, the “Information”) to provide our services; to process Orders; administer our rewards and promotional programs; to maintain and improve our website and services to you; to solicit your feedback, and to inform you about our products and services and those of our third-party marketing partners.

We may also use and share information as described below.

All Ways Travel/ Knowing Cuba will access, use, and share the information as required to process your Orders and provide support to you. We may employ other companies and individuals to perform functions on our behalf. Examples may include technical assistance, Order fulfillment, customer service, and marketing assistance. These other companies will only have access to the information necessary to perform their functions and to the extent permitted by law. In an ongoing effort to better understand our Visitors, customers, and our products and services, we may analyze the Order Information and Other Information in aggregate form to operate, maintain, manage, and improve the website and our products and services. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics to describe our products and services to current and prospective business partners and third parties for other lawful purposes. We may share some or all of your information with any of our parent companies, subsidiaries, joint ventures, or other companies under common control with us. We might sell or buy businesses or assets as we develop our businesses. The information may be part of the transferred assets in the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event. To the extent permitted by law, we may also disclose the information: (i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (ii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of All Ways Travel/ Knowing Cuba or others.

Information You Share
Please keep in mind that whenever you voluntarily make your Personal Information available to third parties — for example, on our social media channels — that information can be seen, collected, heard, and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

How We Protect the Information
We take commercially reasonable steps to protect the information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases nor that the information you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, emails sent to or from the website may not be secure, and you should therefore take special care in deciding what information you send us via email.

Children
We do not knowingly collect Personal Information from children under 13 through the website. If you are under 13, please do not give us personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Information through the website without their permission. If you believe a child under 13 has provided Personal Information, please contact us, and we will endeavor to delete that information from our databases.

Changes to This Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing the website and using our services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the information is governed by the Privacy Policy at the time we collect the information. Please refer back to this Privacy Policy regularly.

5. HOW WE COLLECT YOUR DATA
   We may collect data about you by you providing the data directly to us (for example, by filling in forms on our site or by sending us emails).

We may receive data from third parties such as analytics providers such as Google based outside the EU, advertising networks such as Facebook based outside the EU, search information providers such as Google based outside the EU, and providers of technical, payment, and delivery services.

6. MARKETING COMMUNICATIONS
   Our lawful ground for processing your data to send marketing communications is your consent or our legitimate interests (namely, to grow our business).

Before we share your data with any third party for marketing purposes, we will get your express consent.

You can ask third parties or us to stop sending you marketing messages by emailing us anytime.

If you opt out of receiving marketing communications, this opt-out does not apply to personal data from other transactions, such as purchases and reservation requests.

7. DISCLOSURES OF YOUR DATA
   We may have to share your data with the parties set out below:

Other companies in our group provide services to us.
Service providers who provide IT and system administration services.
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your data and treat it according to the law. We only allow such third parties to process your data for specified purposes and follow our instructions.

8. INTERNATIONAL TRANSFERS
   We are subject to the General Data Protection Regulations that protect your data. Where we transfer your data to third parties outside of the EEA, we will ensure that certain safeguards are in place to ensure a similar degree of security for your data. As such:

We may transfer your data to countries that the European Commission have approved as providing an adequate level of protection for personal data; or If we use US-based providers that are part of EU-US Privacy Shield, we may transfer data to them, as they have equivalent safeguards in place; or Where we use certain service providers who are established outside of the EEA, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe. If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

9. DATA SECURITY
   We have implemented security measures to prevent your data from being accidentally lost, used, altered, disclosed, or accessed without authorization. We also allow access to your data only to those employees and partners who have a business need to know such data. They will only process your data on our instructions and must keep it confidential.
10. DATA RETENTIONWe will only retain your data for as long as necessary to fulfill the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

When deciding the correct time to keep the data, we look at its amount, nature and sensitivity, potential risk of harm from unauthorized use or disclosure, processing purposes, and if these can be achieved by other means and legal requirements.

In some circumstances, we may anonymize your data for research or statistical purposes and use this information indefinitely without further notice.

11. YOUR LEGAL RIGHTS
    Under data protection laws, you have rights with your data that include the right to request access, correction, erasure, restriction, transfer, object to processing, portability of data, and (where the lawful ground of processing is consent) to withdraw consent.

Please email us if you wish to exercise any of the above rights.

You will not have to pay a fee to access your data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive, or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to anyone with no right to receive it. We may also contact you to ask you for further information concerning your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made some requests. In this case, we will notify you.

If you are unhappy with any aspect of how we collect and use your data, you have the right to contact us, and we will try to resolve it for you.

12. THIRD-PARTY LINKS
    This website may include links to a third-party website, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control this third-party website and are not responsible for its privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.