Coronavirus Updates

Privacy Policy 

1. Background 

This Privacy Policy ("Policy") sets out how Caribbean and Latin Travel  Consultant Limited (collectively referred to in this document as "Caribbean  Latin Travel", "we" "our" or "us") protects the privacy of your personal  information. 

Caribbean Latin Travel is one of the Caribbean travel agency, with  exclusivity services to Cuba, Jamaica and Latin America as a travel  agency we need to collect, use and disclose personal information in order to  perform our business functions and activities, including making and managing  travel bookings on behalf of our customers. We are firmly committed to  protecting the privacy and confidentiality of personal information and to  maintaining various physical, electronic and procedural safeguards to protect  personal information in our care. 

There may be instances where your local data protection laws impose more  restrictive information handling practices than the practices set out in this  Policy. Where this occurs we will adjust our information handling practices in  your jurisdiction to comply with these local data protection laws. 

By providing personal information to us (either directly or allowing another  person to do so on your behalf), you agree that this Policy will apply to how  we handle your personal information and you consent to us collecting, using  and disclosing your personal information as detailed in this Policy. If you do  not agree with any part of this Policy, you must not provide your personal  information to us. If you do not provide us with your personal information, or if  you withdraw a consent that you have given under this Policy, this may affect  our ability to provide services to you or negatively impact the services we can  provide to you. For example, most travel bookings must be made under the  traveler's full name and must include contact details and appropriate  identification (e.g. passport details). We cannot make bookings for you without  that information. 

2. What personal information do we collect? 

Personal information has the meaning given under your local data protection  law. Personal information generally means information which relates to a living  individual who can be identified from that information, or from that information  and other information in a person's possession, including any expression of  opinion, whether true or not, and whether recorded in material form or not,  about an identified or reasonably identifiable individual, and any indication of  intention in respect of an individual. 

Generally, the type of personal information we collect about you is the  information that is needed to facilitate your travel arrangements and bookings  and to arrange travel related services and/or products on your behalf. For  example, we may collect details such as your name, telephone number, email 

address, credit/debit card details (including card type, card number, security  number and expiry date), passport details, loyalty program / frequent flyer  details, information about your dietary requirements and health issues (if any),  and other details relevant to your travel arrangements or required by the  relevant travel service provider(s) (e.g. airlines and accommodation or tour  providers). When you contact us for other purposes, we may also collect  personal information about you in relation to those purposes. For example, we  may collect your personal information so we can contact you about a  competition you have entered (e.g. if you win) or to respond to an inquiry or  feedback you have sent to us. We also collect information that is required for  use in the business activities of Caribbean Latin Travel Consultant Limited and our related entities, including for example, financial details necessary in  order to process various transactions. 

In some circumstances, we may collect personal information from you which  may be regarded as sensitive information under your local data protection  laws. Sensitive information may include (without limitation) your racial or  ethnic origin, philosophical or religious beliefs or affiliations, sexual  preferences or practices, criminal record and the alleged commission of an  offence, membership of political, professional or trade associations, biometric  and genetic information, passwords and financial information and health  information, and any personal information relating to a child under the age of  12. 

We will only collect sensitive information in compliance with your local data  protection laws, with your consent and/or where it is reasonably necessary  for, or directly related to, one or more of our functions or activities (e.g. to make  travel arrangements), unless we are otherwise required or authorized to do so  by law. To the extent permitted or required under your local data protection  laws, you consent to us using and disclosing your sensitive information for the  purpose for which it was collected, unless we subsequently receive your  consent to use it for another purpose. For example, if you provide health  information to us in connection with a travel insurance application you would  like to make, you consent to us using and disclosing that health information in  connection with arranging that travel insurance on your behalf. A further  example is if you disclose your religious beliefs to us because you are  interested in, for example, certain holiday packages, in which case you  consent to us using and disclosing that information in connection with  facilitating your request. We will not use sensitive information for purposes  other than those for which it was collected, unless we subsequently receive  your consent to use it for another purpose. 

3. How do we collect personal information? 

We will collect personal information directly from you unless it is unreasonable  or impracticable to do so. Generally, this collection will occur when you deal  with us either in person, by telephone, letter, facsimile, email, when you visit  any of our websites or when you connect with us via social media. We may 

collect personal information about you when you purchase or make inquiries  about travel arrangements or other products and services; when you enter  competitions or register for promotions; when you subscribe to receive  marketing from us (e.g. e-newsletters); when you request brochures or other  information from us; or when you provide information, or use our services, on  social media. Unless you choose to do so under a pseudonym or  anonymously, we may also collect your personal information (other than  sensitive information) when you complete surveys or provide us with  feedback. 

In some circumstances, it may be necessary for us to collect personal  information about you from a third party. This includes where a person makes  a travel booking on your behalf which includes travel arrangements to be used  by you (e.g. a family or group booking or a travel booking made for you by  your employer). Where this occurs, we will rely on the authority of the person  making the travel booking to act on behalf of any other traveler on the booking.  By providing your personal information to us, either directly or through a family  member, employer or other agent or representative in connection with a travel  booking or related service, you will be deemed to have consented to your  personal information being collected by us and used and disclosed in  accordance with this Policy. 

Where you make a travel booking on behalf of another person (e.g. a family  or group booking or a travel booking made for an employee), you agree you  have obtained the consent of the other person for Caribbean Latin Travel Consultant Limited to collect, use and disclose the other person's personal  information in accordance with this Policy and that you have otherwise made  the other person aware of this Policy. 

You should let us know immediately if you become aware that you’re personal  information has been provided to us by another person without your consent  or if you did not obtain consent before providing another person's personal  information to us. 

4. How do we use your personal information? 

We will only process your information, where: 

∙ you have given your consent to such processing (which you may  withdraw at any time, as detailed at section 8 below); 

∙ the processing is necessary to provide our services to you; 

∙ the processing is necessary for compliance with our legal obligations;  and/or 

∙ the processing is necessary for our legitimate interests or those of any  third-party recipients that receive your personal information (as detailed  in sections 5 and 6 below) 

Where you contact us in relation to a travel booking or query, the purpose for  which we collect your personal information is generally to provide you with 

travel advice and/or to assist you with booking travel and/or travel related  products and services. However, the purpose for collection may differ  depending on the particular circumstances as disclosed in this Policy (e.g.  collection of your personal information for the purpose of your participation in  a competition, provision of feedback, etc.). 

When we book and otherwise arrange travel related products and services for  you, we usually act as agent of the relevant travel service providers (e.g. for a  hotel). In this case, we process your personal information as necessary so as  to provide the services you requested from us. This usually includes collecting  personal information about you both for our internal purposes as described in  this Policy and for the travel service provider for whom we act as agent for  their internal purposes (e.g. to provide you with the booked services). For  example, if you book a flight through us, then we use your personal information  to enable your flight to be booked and disclose it to the airline to enable the  airline to provide the flight service to you. 

We may therefore share your information with our travel service providers  such as hotel, airline, car rental, or other providers, who fulfill your travel  bookings. Please note that these travel service providers also may use your  personal information as described in their respective privacy policy and may  contact you as necessary to obtain additional information about you, facilitate  your travel reservation, or provide you with your requested services. We  encourage you to review the privacy policies of any third-party travel service  providers whose products you purchase through us. We will provide you with  copies of all relevant travel service provider terms, conditions and privacy  policies on request. 

We act as agent for or on behalf of many thousands of travel service providers  around the world, so it is not possible for us to set out in this Policy all of the  travel service providers for whom we act or their locations. For more  information about the disclosure of personal information to travel service  providers located overseas, please refer to the section below titled "Is  personal information transferred overseas". 

If you have any concerns regarding the transfer of your personal information  to a travel service provider, or you wish to contact us for further information,  please refer to the "Feedback / Complaints / Contact" section below. 

The purposes for which we collect personal information further include: 

∙ providing you with services and tools you choose to use (for example,  saving travel preferences on our websites to a wish list or saving  personal information to allow for pre-population of online forms); 

∙ identification of fraud or error; 

∙ regulatory reporting and compliance; 

∙ developing and improving our products and services and those of our  related entities;

∙ servicing our relationship with you by, among other things, creating and  maintaining a customer profile to enable our brands to service you  better or presenting options on our website we think may interest you  based on your browsing and preferences; 

∙ involving you in market research, gauging customer satisfaction and  seeking feedback regarding our relationship with you and/or the service  we have provided; 

∙ to facilitate your participation in loyalty programs; 

∙ for research and analysis in relation to our business and services,  including, but not limited to, trends and preferences in sales and travel  destinations and use of our websites; 

∙ Internal accounting and administration; 

∙ to comply with our legal obligations and any applicable  customs/immigration requirements relating to your travel; and 

∙ Other purposes as authorized or required by law (e.g. to prevent a  threat to life, health or safety, or to enforce our legal rights). 

Where permitted by local data protection laws, we may use your personal  information to send you targeted marketing activities relating to our products  and services (and those of third parties) that we think may interest you, unless  you have requested not to receive such information. These may include, but  are not limited to, mail outs, electronic marketing and notifications as  described below, and telephone calls). We will only use your personal  information to send electronic marketing materials to you (including e newsletters, email, SMS , MMS and iM) with you consent (which consent may  be express or, where permitted by local data protection laws, inferred). 

Should you no longer wish to receive promotional/marketing material from us,  participate in market research or receive other types of communication from  us, please refer to the "Feedback / Complaints / Contact" section below  (section 13). You can unsubscribe from receiving electronic marketing  materials by following the unsubscribe prompt in your email, SMS, MMS, iM  or other form of electronic marketing. Please also see the "Your rights" section  of this Policy to learn about your ability, at any time, to opt out or limit the use  of your browsing behavior for online behavioral advertising purposes (section 8 below). 

5. Is personal information disclosed to third parties? 

We will only disclose your personal information to third parties in the ways set  out in this Policy and, in particular, as set out below, and in accordance with  your local data protection laws. Note that, in this Policy, where we say  "disclose", this includes to transfer, share (including verbally and in writing),  send, or otherwise make available or accessible your personal information to  another person or entity.

Your personal information may be disclosed to the following types of third  parties: 

∙ our contractors, suppliers and service providers, including without  limitation: 

o in each of the circumstances set out in the section titled "How do  we use and disclose your personal information?" ; 

o suppliers of IT based solutions that assist us in providing  products and services to you (such as any external data hosting  provider(s) we may use); 

o publishers, printers and distributors of marketing material; o event and expo organizers; 

o marketing, market research, research and analysis and  communications agencies; 

o mailing houses, freight services, courier services; and 

o external business advisers (such as lawyers, accountants,  auditors and recruitment consultants); 

∙ our related entities and brands; 

∙ travel service providers such as travel wholesalers, tour operators,  airlines, hotels, car rental companies, transfer handlers and other  related service providers; 

∙ a prospective purchaser, in connection with a merger, acquisition,  reorganization or sale of Caribbean Latin Travel Consultant Limited. 

∙ a person making your travel booking on your behalf, where you are  traveling on a booking made on your behalf by another person (for  example, a family member, friend or work colleague); 

∙ your employer, where you are an employee of one of our corporate,  business or government clients and you are participating in an event or  traveling for work purposes; 

∙ a person who can verify to us that they have a relationship with you  (e.g. a family member) where you are not contactable, the person  correctly answers our required security questions and the request is, in  our opinion, in your interest (for example, where the person is  concerned for your welfare or needs to undertake action on your behalf  due to unforeseen circumstances); 

∙ as required or authorized by applicable law, and to comply with our legal  obligations; 

∙ customs and immigration to comply with our legal obligations and any  applicable customs/immigration requirements relating to your travel;

∙ government agencies and public authorities, to comply with a valid and  authorized request, including a court order or other valid legal process; 

∙ various regulatory bodies and law enforcement officials and agencies,  including to protect against fraud and for related security purposes; and 

∙ enforcement agencies where we suspect that unlawful activity has been  or may be engaged in and the personal information is a necessary part  of our investigation or reporting of the matter. 

Other than the above, we will not disclose your personal information without  your consent unless we reasonably believe that disclosure is necessary to  lessen or prevent a threat to life, health or safety of an individual or to public  health or safety or for certain action to be undertaken by an enforcement body  (e.g. prevention, detection, investigation, prosecution or punishment of  criminal offences), or where such disclosure is authorized or required by law  (including applicable privacy / data protection laws). 

On our websites, you may choose to use certain features that can be  accessed through, or for which we partner with, other entities that are not  otherwise affiliated with us. These features, which include social networking  and geo-location tools, are operated by third parties, including social  networks, and are clearly identified as such. These third parties may use or  share personal information in accordance with their own privacy policies. We  strongly suggest you review the third parties’ privacy policies if you use the  relevant features. 

When you engage us to book flights on your behalf, we will provide your  personal information (i.e. name, email address and/or mobile number) to the  relevant airline. This enables airlines to advise passengers of irregular flight  operations and disruptions (e.g. flight cancellations, schedule changes)  directly. 

6. Is personal information transferred overseas? 

We may disclose your personal information to certain overseas recipients, as  set out below, which we will do in accordance with your local data protection  laws. 

It is possible that information will be transferred to an overseas recipient (other  than any of our overseas related entities) located in a jurisdiction where you  will not be able to seek redress under your local data protection laws and that  does not have an equivalent level of data protection as in your jurisdiction. To  the extent permitted by your local data protection laws, we will not be liable for  how these overseas recipients handle, store and process your personal  information. 

(a) Our overseas related entities 

Caribbean Latin Travel Consultant Limited operates a global business,  including operations in Jamaica, Cuba Panama, Mexico, Colombia, and  Dominican Republic. Your personal information may be disclosed to our  overseas related entities in connection with facilitation of your travel booking 

and/or to enable the performance of administrative, advisory and technical  services, including the storage and processing of such information. 

(b) Travel service providers located overseas 

In providing our services to you, it may be necessary for us to disclose  personal information to relevant overseas travel service providers. We deal  with many different travel service providers all over the world, so the location  of a travel service provider relevant to your personal information will depend  on the travel services being provided. The relevant travel service providers  will in most cases receive your personal information in the country in which  they will provide the services to you or in which their business or management  is based. 

(c) Our third party service providers located overseas 

We may also disclose your personal information to third parties located  overseas for the purpose of performing services for us, including the storage  and processing of such information. Generally, we will only disclose your  personal information to these overseas recipients in connection with  facilitation of your travel booking and/or to enable the performance of  administrative and technical services by them on our behalf. 

We use key service providers located in Jamaica, Cuba Panama, Mexico,  Colombia, and Dominican Republic, among other jurisdictions. We also deal  with many different service providers all over the world, so it is not possible for  us to set out in this Policy all of the different countries to which we may send  your personal information. However, if you have any specific questions about  where or to whom your personal information will be sent, please refer to the  "Feedback / Complaints / Contact" section below. 

7. Security of information 

Caribbean Latin Travel Consultant Limited has implemented appropriate  technical and organizational measures in order to protect the personal  information it holds from loss and misuse, and from unauthorized access,  modification, disclosure and interference. Caribbean Latin Travel Consultant  Limited regularly reviews security technologies and will strive to protect your  personal information as fully as we protect our own confidential information. 

Caribbean Latin Travel Consultant Limited is not responsible for any third  party’s actions or their security controls with respect to information that third  parties may collect or process via their websites, services or otherwise. 

We will destroy or de-identify personal information once we no longer require  it for our business purposes, or as required by law. 

8. Your rights in relation to the personal information we collect. If you wish to:

∙ access, update, modify, rectify, erase, object to, or obtain a copy of the  personal information that we hold on you; or

∙ restrict or stop us from using any of the personal information which we  hold on you, including by withdrawing any consent you have previously  given to the processing of such information; or 

∙ where any personal information has been processed on the basis of  your consent or as necessary to perform a contract to which you are a  party, request a copy of such personal information in a suitable  machine-readable format or have that personal information transmitted  by us to another controller 

you can request this by contacting us as set out in section 13 below. You will  receive acknowledgement of your request and we will advise you of the  timeframe within which you will receive your information pack. 

We endeavor to respond to such requests within a month or less, although we  reserve the right to extend this period for complex requests. 

We reserve the right to deny you access for any reason permitted under  applicable laws. Such exemptions may include national security, corporate  finance and confidential references. If we deny access or correction, we will  provide you with written reasons for such denial unless it is unreasonable to  do so and, where required by local data protection laws, will note your request  and the denial of same in our records. 

You have the right to lodge a complaint with a relevant governmental authority. 

Further correspondence regarding your request should only be made in  writing. 

Please note that, if you request that we restrict or stop using personal  information we hold on you or withdraw a consent you have previously given  to the processing of such information, this may affect our ability to provide  services to you or negatively impact the services we can provide to you. For  example, most travel bookings must be made under the traveler's full name  and must include contact details and appropriate identification (e.g. passport  details). We cannot make bookings for you without that information. 

You must always provide accurate information and you agree to update it  whenever necessary. You also agree that, in the absence of any update, we  can assume that the information submitted to us is correct, unless we  subsequently become aware that it is not correct. 

You can at any time tell us not to send you marketing communications by  email by clicking on the unsubscribe link within the marketing emails you  receive from us or by contacting us as indicated below (section 13). 

In any of the situations listed above, we may request that you prove your  identity by providing us with a copy of a valid means of identification in order  for us to comply with our security obligations and to prevent unauthorized  disclosure of personal information. 

We reserve the right to charge you a reasonable administrative fee for any  manifestly unfounded or excessive requests concerning your access to your 

personal information, and for any additional copies of the personal information  you request from us. 

9. Social Media Integrations 

Our websites and mobile applications may use social media features and  widgets (such as "Like" and "Share" buttons/widgets) ("SM Features"). These  are provided and operated by third party companies (e.g. Facebook) and  either hosted by a third party or hosted directly on our website or mobile  application. SM Features may collect information such as the page you are  visiting on our website/mobile application, your IP address, and may set  cookies to enable the SM Feature to function properly. 

If you are logged into your account with the third party company, then the third  party may be able to link information about your visit to and use of our website  or mobile application to your social media account with them. Similarly, your  interactions with the SM Features may be recorded by the third party. In  addition, the third party company may send us information in line with their  policies, such as your name, profile picture, gender, friend lists and any other  information you have chosen to make available, and we may share  information with the third party company for the purposes of serving targeted  marketing to you via the third party social media platform. You can manage  the sharing of information and opt out from targeted marketing via your privacy  settings for the third party social media platform. 

Your interactions with these SM Features are governed by the privacy policy  of the third party company providing them. For more information about the  data practices of these third party companies, and to find out more about what  data is collected about you and how the third party uses such data, please  refer to their privacy policy directly. 

10. IP addresses 

When you access our website, use any of our mobile applications or open  electronic correspondence or communications from us, our servers may  record data regarding your device and the network you are using to connect  with us, including your IP address. An IP address is a series of numbers which  identify your computer, and which are generally assigned when you access  the internet. Alone, IP addresses are not personal information, as any one  computer or device may be used by multiple people (i.e. it is not possible to  ascertain the identity of a user simply from the computer or device being  used). 

We may use IP addresses for system administration, investigation of security  issues and compiling anonymized data regarding usage of our website and/or  mobile applications. We may also link IP addresses to other personal  information we hold about you and use it for the purposes described above  (e.g. to better tailor our marketing and advertising materials, provided you  have opted in to receive electronic marketing). 

11. Tracking Technologies / Cookies

(a) What Do We Use Cookies For? 

At Caribbean Latin Travel Consultant Limited, we use cookies to identify a  visitor’s browser, to anonymously track visits or to enhance the experience of  the website. 

We use both session ID cookies and persistent cookies. A session ID cookie  expires when you close your browser. A persistent cookie remains on your  hard drive for an extended period of time. When a visitor revisits the website,  we may recognize the visitor by the cookie and customize the visitor's  experience accordingly. You can remove persistent cookies by following  directions provided in your Internet browser’s “help” file. 

If you reject cookies, you may still have access to our website, but your ability  to use some areas of our website, such as contests or surveys, may be limited. 

Web Beacons / Gifs 

We employ a software technology called clear gifs (a.k.a. Web Beacons), that  help us better manage content on our website by informing us what content is  effective. Clear gifs are tiny graphics with a unique identifier, similar in function  to cookies, and are used to track the online movements of Web users. In  contrast to cookies, which are stored on a user’s computer hard drive, clear  gifs are embedded invisibly on Web pages and are about the size of the period  at the end of this sentence. We do not tie the information gathered by clear  gifs to our customers’ personal information. 

3rd Party Tracking 

The use of cookies by our partners, affiliates, tracking utility company or  service providers is not covered by this Policy. We do not have access or  control over these cookies. Our third party partners employ clear gifs (a.k.a.  Web Beacons/Web Bugs), images, and scripts that help them better manage  content on our website. We do not tie the information gathered to our  customers’ or users’ personal information. 

Behavioral Targeting / Re-Targeting 

We partner with third party ad networks to either display advertising on our  websites or to manage our advertising on other websites. Our ad network  partners use cookies, Web beacons and other technologies to collect non personally identifiable information about your activities on this and other  websites to provide you targeted advertising based upon your interests. 

If you wish to not have this information used for the purpose of serving you  targeted ads, you may opt-out by emailing info@caribbeanlatintravel.com Please note this does not opt you out of being served advertising. You will  continue to receive generic ads or targeted ads where third parties do not  honour opt-out capabilities. 

(a) What Are Cookies?

A cookie is a small text file that is stored on a user’s computer for record keeping purposes. We may link the information we store in cookies to any  personal information you submit while on our website. Cookies save data  about individual visitors to the website, such as the visitor's name, password,  username, screen preferences, the pages of a website viewed by the visitor,  and the advertisements viewed or clicked by the visitor. 

(c) Third Party Cookies 

When you visit certain sections of our website and/or use our mobile  application, third parties may place cookies on your computer’s browser  and/or make use of web beacons to collect information. This information may  include things such as your use of the website or mobile application, device  and browser information and ad data. The information generated by the  cookies and web beacons about your use of the website is transmitted to those  third parties. This information is then used for the purpose of compiling  statistical reports to enable us to measure and analyze the number of visits to  the site and its pages, the average time spent on the site and the pages  viewed; serving targeted advertising to you (including use to target advertising  on other sites or applications based on your online activity); providing us with  services and enhancing/improving our website, mobile application and the  third party’s technology products and services. 

Our current providers, and information regarding their data practices and how  to opt out, include any one of the following as may be updated from time to  time: 

1. Google Analytics: When you visit certain sections of the website, Google Analytics, a website analytics service provided by Google, Inc (“Google”), will place cookies on your computer’s browser. The  information generated by the cookies about your use of the website is  transmitted to Google. This information is then used for the purpose of  compiling statistical reports to enable us to measure and analyse the  number of visits to the website and its pages, the average time spent  on the site and the pages viewed. We will not (and will not allow any  third party to) use Google Analytics to track or to collect any personal  data of visitors to our website. We will not associate any data gathered  via use of cookies with any personal data from any source as part of  our use of Google Analytics. 
2. Criteo is a company specialising in targeted advertising. For further information about Criteo, please visit www.criteo.com and for details of Criteo’s Privacy Policy, please visit www.criteo.com/us/privacy-policy.  For information on how to disable Criteo services and/or to opt out of  Criteo, you can visit http://www.criteo.com/privacy/ and use the opt-out  feature.
3. Linked Sites 

Our websites may contain links to third party websites over which we have no  control. We are not responsible for the privacy practices or the content of such  websites. We encourage you to read the privacy policies of any linked third  party websites you visit as their privacy policy and practices may differ from  ours. 

13. Changes to our Policy 

We may amend this Policy from time to time. If we make a change to the  Policy, the revised version will be posted on our website at websites as  follows: 

https://www.caribbeanlatintravel.com 

It is your responsibility, and we encourage you, to check the website from time  to time in order to determine whether there have been any changes.