This document discloses the data protection and privacy practices for Zuba Ltd.
Your privacy is very important to us. Please read below to see how Zuba Ltd handles information.
1. Information We Collect
Our primary goal in collecting personal information from you is to provide you with a smooth, efficient, and personalised experience while using our services. This allows us to provide services and features that most likely meet your needs, and to customise our service to make your experience easier and quicker.
Information you give us.
When you make a booking with us we may ask you for information that shall include but shall not be limited to: your name; contact information including email address, mobile phone number, address, and copies of personal identification documents (such as your passport).
Information we collect.
We use a number of different cookies on our site. If you do not know what cookies are, or how to control or delete them, then we recommend you visit http://www.aboutcookies.org for detailed guidance.
The following describes the cookies we use on this site and what we use them for. Currently we operate an ‘implied consent’ policy which means that we assume you are happy with this usage. If you are not happy, then you should either not use this site, or you should delete Zuba Ltd cookies having visited the site, or you should browse the site using your browser’s anonymous usage setting (called "Incognito" in Chrome, "InPrivate" for Internet Explorer, "Private Browsing" in Firefox and Safari etc.). If you block cookies, for the most part the websites should continue to operate normally, however there may be some areas where you may not be able to take full advantage of the website’s functionality.
You can disable Cookies in your web browser. Information can usually be found in your Web Brower’s help section.
Persistent Cookies for Site Analytics and Performance.
Google Analytics – we use this to understand how the site is being used in order to improve the user experience. User data is all anonymous. You can find out more about Google’s position on privacy as regards its analytics service at http://www.google.co.uk/intl/en/analytics/privacyoverview.html
On each page of the site you will see 'social buttons'. These enable users to share or bookmark the web pages. There are buttons for: Twitter, Facebook, LinkedIn, and Addthis. In order to implement these buttons, and connect them to the relevant social networks and external sites, there are scripts from domains outside of Zuba Ltd. You should be aware that these sites are likely to be collecting information about what you are doing all around the internet, including on Zuba Ltd's site. So if you click on any of these buttons, these sites will be registering that action and may use that information. In some cases these sites will be registering the fact that you are visiting www.zubaski.com, and the specific pages you are on, even if you don’t click on the button if you are logged into their services, like Google and Facebook. You should check the respective policies of each of these sites to see how exactly they use your information and to find out how to opt out, or delete, such information.
External Web Services.
We use a number of external web services on the Zuba Ltd websites, mostly to display content within our web pages (weather, photos, videos). For example to show videos we use YouTube and to display accommodation galleries we use Flickr. These are not the only services we use, or might use in the future, when embedding content, but they are the most common. As with the social buttons we cannot prevent these sites, or external domains, from collecting information on your usage of this embedded content. If you are not logged in to these external services then they will not know who you are but are likely to gather anonymous usage information e.g. number of views, plays, loads etc.
Some emails that we send you have no tracking in at all e.g. service emails with booking information. Some emails we can track, at an individual level, whether the user has opened and clicked on the email. We rarely use the latter information at a personal level, rather we use it to understand open and click rates on our emails to try and improve them. Sometimes we do use the personal information e.g. to re-email people who didn’t click the first time. If you want to be sure that none of your email activity is tracked then you should opt out of Zuba Ltd's emails which you can do at the bottom of every email you receive.
Surveys and Contests.
From time to time our site may request information from users via surveys, contests or for a particular service (e.g. newsletter). Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose this information. Information requested will include contact information (as supplied to the site during registration) and supplementary information on your interests, opinions and preferences (e.g. choice of holiday, experience, opinions on resorts, feedback on the Zuba Ltd service). We will use the contact information to notify winners. We will not publish winners' details on the site though on request we will provide details of any winner's name. If the survey or contest has a sponsor then we may share information given by entrants with the sponsor, but only with the user's consent.
In order to process payments online our external payment provider, Stripe, requires your credit card details. For details of how this information is used, please see https://stripe.com/gb/privacy. We do not request for or hold any credit card information and believe this to be one of the most secure payments systems in the world.
In order to leave a comment in our Blog you have to give us at least your Name and Email address. You can choose whether to post as yourself, or anonymously. We require name and email address even for anonymous posts for quality control purposes.
2. Our Use of Your Information
We use personally identifiable information about you to improve our marketing and promotional efforts, to statistically analyse site usage, to improve our content and product offerings and to customise our site's content, layout, and services. We believe these uses allow us to improve our site and better tailor it to meet our users' needs.
We use your email address to send you newsletters or other communications that you have requested from the Site. Out of respect for our clients we offer an opt-out (see Section 3 below).
We use information in the file we maintain about you, and other information we obtain from your current and past activities on the Site, to resolve any disputes, troubleshoot problems and enforce our Terms & Conditions. At times, we may look across multiple users to identify problems or resolve disputes.
Your Personal Information is stored in our databases. Please note that the information you enter may be transferred outside the European Economic Area to the United States of America where it will be stored for the purposes of processing by Zuba Ltd or any of its affiliates including subcontractors. By submitting your information, you consent to this transfer.
Zuba Ltd complies with the UK Data Protection Act 1998 and from the 25th May 2018 the General Data Protection Regulation.
3. Email Communications
As part of the registration process you have the opportunity to opt in or out of various email communications. If at any stage you wish no longer to receive any emails that you receive you can unsubscribe or change your preferences on any of the emails that you receive.
4. Our Disclosure of Your Information
We do not sell or rent any personally identifiable information about you to any third party.
By way of example (without limiting the foregoing), we may be forced to disclose information to the government or third parties under certain circumstances, or third parties may unlawfully intercept or access transmissions or private communications. We can (and you authorise us to) disclose any information about you to law enforcement or other government officials as we, in our sole discretion, believe necessary or appropriate, in connection with an investigation of fraud, Intellectual Property Rights infringements, or other activity that is illegal or may expose us to legal liability.
Visibility of your information on the Site.
Following are details of how your information is visible across the site depending on the site section and what you are doing:
Blog Comments and Forum Posts.
If you post a comment to our Blog or post to our Forums then, by default, your name (first name, last name) will be published against your post, based on the information you submit.
Booking Confirmation Information.
During the process of booking through Zuba Ltd, we collect and store information that we require in order to fulfill the service. This will include your name, address, date of birth, email address, phone number as well as similar information about your group and next of kin. We share the required information with partners to enable the fulfilment of the services.
By way of example:
- We will share your name and phone number with our airport transfer partners to enable them to contact you at the point of collection and return.
- We will share your name and dates of birth with ski lift operators to enable the production and delivery of ski passes to your accommodation in time for your arrival.
These examples are not exhaustive and if you should require more information, please contact the data processor at Zuba Ltd via our contact form.
Managing and Deleting Your Information.
We store information until it is no longer necessary to provide our services, or until your account is deleted, whichever comes first. This is a case-by-case determination that depends on things like the nature of the information, why it is collected and processed, and relevant legal or operational retention needs.
If you would like to manage, change, limit, or delete your information, we allow you to do that by logging into your Zuba account online from where you can remove all your personal information.
If there is other information which you find you cannot remove, then please contact the data processor at Zuba Ltd via our contact form.
Zuba Ltd cooperates with law enforcement inquiries and other third parties to enforce laws, Intellectual Property Rights and other rights. Local and international law enforcement agencies can request and may receive your personally identifiable information.
Suppliers and Other Service Providers.
From time to time we use third party Suppliers and Service Providers to facilitate our services. Where any Service Provider collects information directly from you (such as the situation where we ask a Service Provider to conduct a survey for us) you will be notified of the involvement of the Supplier or Service Provider, and all information disclosures you make will be strictly optional.
We are committed to ensuring that your information is secure. In order to try to prevent unauthorised access or disclosure, we have put in place strict procedures and security features around the App and websites. All services have active SSL Certificates in place. However, transmission of information via the internet is not completely secure. We do our best to protect your personal data, but we cannot guarantee the security of your data transmitted to our sites. Any transmission is at your own risk.
Where you have set a password to access the App and certain areas of the websites, please make sure you keep this secure.
The data that we collect from you will be typically transferred to, and stored at, a destination inside the European Economic Area (“EEA”). It will also be processed by staff operating inside the EEA who work for us or for one of our suppliers. This includes staff engaged in, among other things, the fulfilment of your order and the provision of support services.
We do use the services of several companies who are not located in the EEA. We are only using the services of providers who are recognised as market leaders in their field. This includes but is not limited to the following organisations. All of these organisations have subscribed to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework (collectively, "Privacy Shield"). The links provided are to the relevant privacy information for each service.
- Dropbox - For file storage
- Google - Google’s Cloud Platform for the cloud storage of data, Google Analytics, GSuite email, GDrive
- Brevo - for the secure transmission of marketing emails.
- Sendgrid - for the secure transmission of emails from our booking system
- Webflow - for the hosting of our website
- Felloh - payment services
- Travel Trust Association - insuring your monies are held in trust
- WhatsApp - for direct communication between clients, mountain guides and suppliers
- Xero - for Zuba Ltd Accounting
Optimisation of our sites (for example Google for the purpose of its Google Analytics service);
If we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer of such business or assets;
If we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets; and if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply Acceptable Use Policy, our Service
Terms and Conditions and other agreements; or to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
Security and where we store your personal data
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.