Our pledge to you:
- is to hold your data securely
- Share only where you agree
- use your data to tailor the information we provide you and improve our services
- put you in control by allowing you to update, delete and access your data
This Policy will inform you as to how we look after your data when you visit our website and tell you about your privacy rights and how the law protects you. It also sets out if you have any queries or concerns about this information.
PURPOSE OF THIS POLICY
This Policy aims to give you information on how DiscoverLaos Today collects and processes your data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or use any of our products, services, applications, websites and consumer, business customer or stakeholder support communications or take part in a competition.
MyLaoTours is the controller and responsible for your data.
CHANGES TO THE POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep Policy under regular review. This version was last updated on 24 September 2019. We reserve the right to make changes to this Policy at any time and we may notify you of changes to this Policy by email.
The personal data we hold about you must be accurate and current. Please keep us informed if your personal data changes during your relationship with us.
1. THE DATA WE COLLECT ABOUT YOU
2. HOW IS YOUR PERSONAL DATA COLLECTED?
3. HOW WE USE YOUR PERSONAL DATA
4. DISCLOSURES OF YOUR PERSONAL DATA
5. INTERNATIONAL TRANSFERS
6. DATA SECURITY
7. DATA RETENTION
8. LEGAL RIGHTS
1. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in certain categories. Please take care when submitting information to us, particularly when completing free text fields or uploading content, documents and other materials. Some of our services may be automated and we may not recognise that you have accidentally provided us with incorrect or sensitive information.
Whenever you interact with us, you may be asked to provide us with information relating to you. The following types of data may be collected from you:
- Identity Data includes first name, last name, username or similar identifier, title, and date of birth.
- Contact Data includes address, email address and telephone numbers.
- Financial Data includes bank account and payment card details. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
- Enquiry Data includes data you provided us with when you contact us for consumer, business customer or stakeholder service assistance (by any means of communication including written communications or via our website(s), support forums, telephone, email, SMS, or our social media channels) or when you visit us at a public event, such as a trade show or exhibition or participate in one of our surveys, competitions or prize draws, we may record all consumer, business customer or stakeholder service communications and keep information about the particular communication, including your name, the product(s) you bought, the reason why you contacted us, and the advice we gave you so we can track the resolution of any consumer, business customer or stakeholder service issues and for consumer, business customer or stakeholder service training purposes.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. We may also receive content that you choose to upload or post, such as your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, interests and hobbies, educational details and employment details, product reviews, comments, photos and forum posts, or details of your interests and preferences that you choose to tell us about when, for example, selecting the services that you wish to receive.
- Usage Data includes information about how you use our website, products and services, as well as the frequency and pattern of your service use.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this 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). Nor do we collect any information about criminal convictions and offences.
IF YOU FAIL TO PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
2. HOW IS YOUR PERSONAL DATA COLLECTED?
As you interact with our website, emails and app we may automatically collect Technical Data about your equipment, browsing actions, patterns and wifi. We collect this personal data by using cookies, server logs, digital analytics (Google) and heat mapping software and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Details of your usage patterns, the content (including any advertisements) that you view and interact with including information on the services and applications you are using in-device to personalise services to your specific needs. For example, when you use our websites, we may collect information about your visit, such as your browser software, which pages you view and which items you 'clicked' on.
A specific example is the use of digital analytics tools such as Google Analytics and DoubleClick. These may be used to record an anonymous user's interaction with DiscoverLaosToday websites. The data may then be used to retarget users through advertising on other websites, therefore an individual's behaviour on one of our websites may result in them being retargeted with advertising related to the pages they visited or actions they took on the site. (You may opt-out of the DoubleClick cookie by visiting the Google advertising opt-out page or you may opt-out of our use of Analytics by visiting the Google Analytics opt-out page.)
Service, product or server logs, which hold technical information about your use of our service, product or websites, such as your IP address, device ID(s), domain, device and application settings, errors and hardware activity. We may use your IP address to determine your location/country of origin.
Device Information such as your device ID(s), including information about where your device is physically located. For example, when you are using a geo-location service or application and you have given consent to your location being shared.
WiFi information such as WiFi_APMac, WiFi_ClientIP, WiFi_ClientMac, WiFi_Location, WiFi_UserAgent.
Third parties or publicly available sources
We may receive personal data about you from various third parties.
- Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register.
- Identity and Contact Data from social media if you:
- interact with any of our social network pages or applications, or;
- use one of our products or services that allow interaction with social networks, we may receive information relating to your social network accounts. For instance:
(a) Logging in: If you log-in to one of our websites, applications or services using your social network account, we may receive basic details from your social network profile. The basic details we receive may depend on your social network account privacy settings; however, they might include your social network ID, name, profile picture, gender and location.
(b) Interactions: If you click on a 'like', '+1' or 'tweet' or similar button in one of our websites or services, we may record the fact that you have done so. In addition, the content that you are viewing may be posted to your social network profile or feed. We may receive information about further interactions with this posted content (for example, if your contacts click on a link in the posted content), which we may associate with the details that we store about you.
3. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you.
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- where we need to comply with a legal obligation
If you are a business customer or stakeholder we generally do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data.
You will only receive marketing communications from us if you have requested information from us by opting in to receive such marketing.
Our aim is to give you a choice over how you receive marketing and what you want to hear about.
We will use your Identity Data, Contract Data, Technical Data and Usage Data to provide you with product and service updates, newsletters and other communications tailored to you and in the channels you have chosen.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR by contacting us at any time.
Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.
Please note that we may occasionally send you important information (including via email) about our products and services that you are using or have used including essential software updates, changes to applicable terms and conditions and/or other communications or notifications as may be required to fulfil our legal and contractual obligations to provide warranty or after-sales repair services. These important products and/or service communications are not affected by your opt-out of any marketing communications.
PUBLISH YOUR REVIEWS, COMMENTS AND CONTENT
Where you have uploaded product reviews, comments or content to our websites or services and made them publicly visible, we may link to, publish or publicise these materials elsewhere including in our own advertisements.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. Please contact us using the details set out at the beginning of this Policy for an explanation as to how the processing for the new purpose is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. DISCLOSURES OF YOUR PERSONAL DATA
We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above.
We may have to share your personal data with the third parties set out below for the purposes set out in the table in paragraph 3 above.
(a) our payment services providers for services relating to our website and services to which you have subscribed to which may be handled by our payment services providers, such as, without limitation, Worldpay. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
(c) our authorised data processors and service providers for the purposes of providing certain data processing services for us (acting as our authorised data processors). Examples of authorised data processors could include evaluation and research agencies, billing and fulfilment partners, data analytics providers who process the information on our behalf for the purposes outlined above. For example, we may use the services of third parties to personalise content, fulfil orders, deliver packages, send postal mail and emails, send text messages (SMS), provide marketing assistance, process credit card payments, provide fraud checking services and provide consumer, a business customer or stakeholder services. When acting as our authorised data processors, our service providers are required to only process data in accordance with our instructions, in line with this Policy, and are subject to appropriate confidentiality and security obligations
(d) our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
(e) to government bodies such as Audit Scotland and law enforcement agencies to prevent fraud, to comply with applicable laws, regulations and court orders and to comply with valid legal information requests from such bodies.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We prepare anonymous, aggregate or generic data (including "generic" statistics) for a number of purposes as outlined above. As we consider that you cannot reasonably be identified from this information, we may share it with any third party (such as our partners, advertisers, industry bodies, the media and/or the general public).
5. INTERNATIONAL TRANSFERS
DiscoverLaos Today is operated by MyLaoTours, a Lao PDR incorporated company, with its headquarters based in Luang Prabang, Laos. We have a national network of offices to assist in delivering our core function of promoting the development of tourism to and within Scotland and encouraging people to visit Laos.
The hosting facilities for our website(s) are situated in Laos.
Some of our external third parties are based outside Laos so their processing of your personal data will involve a transfer of data outside Laos.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Laos.
6. DATA SECURITY
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Some of the steps we use to protect your information from unauthorised access, use or alteration and unlawful destruction, including where appropriate:
- Limiting access to the information we collect about you (for instance, only those of our personnel who need your information to carry out our business activities are allowed access).
- Putting in place physical, electronic, and procedural safeguards in line with industry standards.
As general best practice on the Internet, it is recommended that individuals take great care with user accounts, and follow some basic rules:
- Do not use trivial passwords (such as single dictionary words).
- Do not use the same password for multiple accounts.
- Do use very long passwords (at least 10 characters, but preferably much longer)
- Do use passwords which contain a combination of upper and lower case letters, numbers and special characters e.g. $%^& etc.
- Do keep passwords securely (never written down, or shared with anyone) and changed periodically.
7. DATA RETENTION
HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
This paragraph sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in the event of a complaint, or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention by taking into consideration the period necessary for retention for its lawful purpose.
Details of retention periods for different aspects of your personal data are set out in the table Purposes for which we will use your personal data above.
In some circumstances you can ask us to delete your data: see Legal Rights below for further information.
In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws in relation to your personal data. we have provided a summary of the rights that you have under current data protection law. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under data protection law are:
(a) the right to be informed;
(b) the right to access;
(c) the right to rectification;
(d) the right to erasure;
(e) the right to restrict processing;
(f) the right to object to processing;
(g) the right to data portability;
(h) the right to complain to a supervisory authority; and
(i) the right to withdraw consent.
YOUR LEGAL RIGHTS
You have the right to:
- Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. 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.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) If you want us to establish the data's accuracy.
(b) Where our use of the data is unlawful but you do not want us to erase it.
(c) Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
(d) You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to 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.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us by emailing firstname.lastname@example.org or by post at 04-05, Hua Xieng Village, Luang Prabang, Laos.
You will not have to retain a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Consent must be a "freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she by a statement or a clear affirmative action signifies agreement.