1. Introduction
About MORE
Luxury More Hotels CC and Luxury More Hotels (Pty) Ltd, including all of its subsidiaries, a ffiliates and related companies (known collectively as “MORE”) is a group made up of di fferent business/ legal entities, a summary of which is found at the end of this policy document (refer ‘The World of MORE’). MORE’s official website is www.more.co.za, on which all related business units and their sites may be found.
About the policy
This policy serves to clarify how we collect, use, process, disclose, retain and protect personal information when:
i) we provide services to you
ii) we process personal information at your instruction that may be used as content to be viewed, uploaded, downloaded or otherwise
We are committed to protecting the privacy of all individuals who:
• Visit any of our digital platforms (including websites; mobile sites);
• Use any of our mobile applications;
• Interact with any of our ‘Live Sales Agents’ (including for quotes, reservations and booking information); or
• Subscribe to any of our news
Collectively termed our “Services”
Please note, those who act as intermediaries on behalf of others are responsible for communicating the content of this Privacy Policy. Bookings or enquiries made on behalf of third parties will assume acceptance of the terms and content of the document. By making a booking or an enquiry on behalf of a third party, you warrant and agree that you are fully entitled to authorize the transfer, storage and processing of personal information as necessary and fully indemnify MORE against any claims (including any penalties, damages, awards and legal costs) in this regard.
Any person who does not agree with the content of this Privacy Policy should not conduct business with MORE, or engage with our Services.
2.1 Account of data
Personal information you provide or we collect from you and your devices in connection with your access to and use of our Services (eg information you provide for the purpose of booking or communications; as well as information we collect about your browser when you connect to one of our Services). In legal terms, we collect and use this account data as a DATA CONTROLLER.
There are two categories of account data we collect in order to provide you with Services:
2.1.1 Information you provide
• Account information: You may provide us with information in connection with the creation and management of your profile, such as a name, email address.
• Billing information: For the purpose of securing a transaction (including, but not limited to accommodations, experiences, third party services). This includes billing details and credit card information, other account and authentication information.
• Other information: You may choose to provide us with information when you fill in a form, contact our client support, respond to surveys or use other features of our Services. You may also provide us with other optional information as part of your account profile (eg preferences, experiences, feedback, and links to your social profiles).
2.1.2 Information we automatically collect
• Log data and usage information. As with most websites, when you view content on or interact with our Services, our servers automatically record information, including information that your browser sends whenever you visit a website or that your application sends when you are using it. This log data may include your IP address, the address of the web page you visited before using the services, your browser type and settings, your device information, the date and time of your use of the services, information about your browser configuration and plug-ins, language preferences, unique identifiers and cookie data.
• Location information: When you use our services, we may collect information about your geographic location.
Cookies and similar technologies: We use cookies and similar technologies to provide and support our websites and services, as more fully explained in our Cookie Policy.
We will collect your information when you engage with our Services, send us an email, call our client service centre, visit a local o ffice, or contact us via another form of communication (such as through social media or an online chat tool with our Live Sales Agents).
2.2 Content
The content which you upload, download, or view on our Services, but does not necessarily contain personal information. When we refer to Content in this notice, we mean the personal information in the Content that we process.
We only process content at your direction. In legal terms, we act as DATA PROCESSORS for the personal information included in the content.
Our obligations and commitments as it relates to our processing of content on behalf of our users is outlined in the section below called CONTENT – MORE AS A DATA PROCESSOR.
3. Account data – How we use it
We use, store and process Account Data as a data controller to provide, understand, improve and develop our Services, keep our Services safe and to comply with our legal obligations. More particularly, we use it to:
– Identify our users, verify accounts and activity, maintain the integrity of our Services, and to keep the Services safe and secure;
– We use account data to identify you when you login;
– Improve and optimise our Services;
– Better understand your needs and the needs of users in the aggregate, diagnose problems, analyse trends, perform analytics, conduct research and improve features and usability of the Services, and better understand and market to our users;
– Analyse the website and the other services and information about our visitors and users, including research into our user demographics and user behaviour;
– Create aggregate (non-identifiable) statistics about users of the services with a view to introducing improvements and improving usability of the Services;
Provide the Services to you, including to:
• Enable your access to our Services;
• Allow you to communicate with us and with other users;
• Verify your transactions, for purchase confirmation, billing, security and authentication;
• Contact you about your account and provide customer service support, including responding to your comments and questions;
• Keep you informed about the Services, features, surveys, newsletters, o ffers, competitions and events we think you may find useful or which you have requested from us;
• Sell or market MORE products & services to you.
4. Account Data: Legal basis for use
Our legal basis for collecting and using Account Data as a Data Controller will depend on the specific context in which we collect it. However, as a data controller, we will collect personal information from you where:
• We have your consent to do so;
• Where we need the personal information to perform a contract with you (eg to deliver the Services you have requested);
• Where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms)
In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.
Where we rely on your consent to process Account Data, you have the right to withdraw or decline your consent at any time. Please note that this does not affe ct the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide Account Data to comply with a legal requirement we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interest, which are not already described in this notice, we will make clear to you at the relevant time what those legitimate interests are.
5. Account data – Access, control and correction
You may update or correct most of your Account Data. To make a request to have Account Data returned to you, removed, or to make additional corrections, please email our privacy team (privacy@more.co.za). Requests to access, correct or remove your information will be handled within thirty (30) days.
Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws with regards to the personal information MORE holds about you as a data controller, including:
• Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for as long as you maintain an account for our Services, or as needed to provide you with our Services, for record keeping purposes, to comply with our legal obligations, resolve disputes and enforce the Terms.
• Right to object to processing: You may have the right to request that MORE stops processing your personal information and/ or to stop sending you marketing communications.
• Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).
• Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine readable and commonly used format and to request that we transfer the personal information to another data controller without hindrance.
If you would like to exercise such rights, please contact us (privacy@more.co.za). We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verity your identity before complying with the request.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. We would, however, appreciate the opportunity to deal with your concerns beforehand, so please contact us via privacy@more.co.za.
6. Content: MORE as a Data Processor
Where we process content, we do so at your direction and on your behalf in accordance with the instructions you give us through the Services.
6. 1 Third-party Apps and Social Networks
Our Services may include links to third-parties, 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 these third-party platforms and are not responsible for their privacy policies. We encourage you to read the relevant privacy policies of every platform you visit.
6.2 Access, correction and deletion of Content
An individual who seeks access to, or who seeks to correct or amend inaccuracies in or deletion of content stored or processed by us should direct his/ her query to privacy@more.co.za. Upon receipt from one of our users for us to remove the data, we will respond to their request within thirty (30) days. Please note, however, that we may need to retain certain information on our systems for as long as you maintain an account for our Services, for record keeping purposes, to comply with our legal obligations, to resolve disputes, enforce our Terms, or as required or authorized by applicable law.
7. Privacy Information that applies to both Account Data and Content
7.1 When we may share personal information
MORE does not share any personal information gathered via the Services with third parties. We may however share Account Data or Content under the following circumstances:
• With your consent or at your direction
• With service providers (including payment processors) we engage to perform functions or provide services to us, where those service providers are subject to obligations that are consistent with this privacy notice and to appropriate confidentiality and security measures
• With MORE’s authorized resellers if you purchase the Services from an authorized MORE reseller who you authorize to access and process your personal information in order to support your user of the Services
• Where we believe that it is reasonably necessary to comply with a law, regulation or if we are otherwise legally required to do so, such as in response to court orders or legal process, or to establish, protect, or exercise our legal rights or to defend against legal claims or demands
• If we believe that it is necessary in order to investigate, prevent, or take action against illegal activities, fraud, situations involving potential threats to our rights or property (or to the rights or property of those who use our services), or to protect the personal safety of any person
• If we believe it is necessary to investigate, prevent, or take action regarding situations that involve the security of our Services, abuse of the Services infrastructure, or the internet in general (such as voluminous spamming, denial of service attacks, or attempts to compromise the security of the Services)
• To a parent company, subsidiaries, joint venture, or other companies under common control with MORE
• If we are acquired by or merged with another entity (in which case we will require such entity to assume our obligations under this privacy notice), if we are involved in a bankruptcy, or if the ownership or control of all or part of our Services or their assets changes
7.2 How long we keep personal information
We retain your Account Data for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, or enforcing our Terms.
We retain Content for as long as needed to provide the Services, or until you ask us to delete it pursuant to the Terms. We retain and use this Content as necessary to comply with our legal obligations, resolve disputes, and enforce the terms.
Please note that certain personal information may need to be retained by MORE for a period of time following the cancellation of your account where this is necessary for our legitimate business purposes or required or authorized by applicable law.
After it is no longer necessary for us to retain your personal information, we will dispose of it in a secure manner.
7.3 How we protect personal information
MORE follows industry best practices to protect personal information from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Account data and Content we collect, use, process and store, and the current state of technology.
7.4 International Transfers
MORE stores all personal information on secure servers in South Africa as well as the United States of America and the European Union. MORE, the entity which provides the Services, is a South African company with its head o office located in Johannesburg South Africa and a number of properties and sub-divisions located around the country (refer MORE and its subsidiaries), as well as in Zimbabwe.
The Services are mainly provided from our offi ces in South Africa. MORE uses third-party service providers (such as managed hosting providers, card processors, CRM systems, Sub-processors of Content and technology partners) to provide the necessary software, networking, infrastructure and other services that we use to operate the Services. These third party providers may process, or store, personal information on servers outside of the EU, including in the US.
Also, by the very nature of the Services provided, the data that is viewed, collected, stored or posted on or through the Services also needs to flow from wherever you are located in the world, to where our Social Networks are storing the same data.
By using any of the Services, or submitting or collecting any personal information via the Services, you authorize MORE and its authorized service partners to use, store and process Content and Account Data (including any personal information) in these countries.
7.5 Cookies and similar technologies
When you visit or interact with our Services, we, Third-Party Apps or our authorized third party service providers may use cookies and other similar technologies to help us provide you with a better, faster and safer experience, and for advertising and marketing purposes. We may collect some personal information from these Cookies. You can get more details on our use of cookies and similar technologies in our full Cookie Notice.
7.6 Your choices
• Processing of content: When we receive or access data from our various Social Networks, we do so at your request and within each Social Network’s terms and conditions.
• Marketing emails: You may opt out of marketing communications sent by MORE by managing your email preferences (accessed via links to update or unsubscribe on the email itself, or by contacting privacy@more.co.za).
• Customised advertising: We may use Account Data to customize advertising that we direct to you, utilizing third parties. You are free to disable the ability for cookies to be downloaded from your web browser.
7.7 Children
Our Services are not intended for use by children and must only be accessed by individuals of at least 18 years old. By using our Services you warrant that you are over the age of 18 (or the minimum age required for legal consent in your jurisdiction).
7.8 Changes to this Privacy Notice
MORE reserves the right to make changes to its privacy notice at any time. Any changes will be posed on our website and will be e effective immediately. Your continued use of our Services indicates your express consent to the updated privacy notice.
* The version of this policy is eff ective from 23 July 2018.
7.9 Contacting us
MORE’s Head O ce is located in Johannesburg, South Africa. You can contact our Privacy Team via email (privacy@more.co.za).
The world of MORE
Luxury More Hotels cc (MORE) comprises the following companies and business units:
Companies (legal entities)
Lion Sands Private Game Reserve (Pty) Ltd
Tinga Private Game Lodge (Pty) Ltd
Mopono Lodge Company (Pty) Ltd
MORE Concession I (Pty) Ltd
Huntrex 101 (Pty) Ltd
More Community Trust
Luxury More Hotels (Pty) Ltd
Aujan Zimbabwe (Pvt) Limited
Business Units
Lion Sands Game Reserve – Lionsands.com
Madikwe Safari Lodge – Madikwesafarilodge.co.za
Marataba South Africa – Marataba.co.za
Cape Cadogan Boutique Hotel – Capecadogan.co.za
More Quarters Hotel – Morequarters.co.za
Stanley & Livingstone – Stanleyandlivingstone.co.zw
More Community Trust – Morecommunitytrust.co.za
More Private Travel – Moreprivatetravel.co.za
