Privacy Policy

SEEK DHARMA PRIVACY POLICY

UPDATED October 23, 2023

Seek Dharma Limited (‘Seek Dharma’ or ‘our’, ‘us’, ‘we’) is committed to protecting and respecting your informational privacy.

The purpose of this Privacy Notice is to explain to you how, when and why we use your personal information. This Privacy Notice also explains your rights in relation to our use of your information as well as other specific information about us. This information is provided to you in accordance with the Data Protection Act 2018, the UK GDPR and the Privacy and Electronic Communications Regulations 2003 as well as other applicable regulatory requirements (‘UK data protection laws’). This Privacy Notice is for your benefit, therefore we ask you to read this document carefully and if you have any questions, enquiries, concerns or complaints about our data processing activities, please contact us at hello@seekdharma.com or write to us at Seek Dharma Limited, Second Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, United Kingdom.

Your personal information is described and referred to in this Privacy Notice as your ‘personal information’ or your ‘personal data’.

This Privacy Notice also explains how others, including other organisations we work with, may or will use your personal data in the course of our business operations. This includes, where necessary, third party service providers such as payment gateways (to facilitate payments), our affiliates and partners, as well as service providers local to your chosen holiday or travel destination.

This Privacy Notice applies to:

The users and visitors of our website at https://www.seekdharma.com and any others that we operate;
The subscribers to our newsletter, and participants in surveys, contests or other similar promotions;
The users and visitors of our social media channels;
Our customers, or prospective customers of our products and services;
The talent and hosts with whom we collaborate;
Our suppliers, service providers, business partners and any party with whom we contract;
Our employees and anyone interested in applying to work for Seek Dharma.

Who we are and what we do

We are a United Kingdom based independent travel and tour operator registered with ABTA (Y6752). We specialise in creating and facilitating travel experiences for our customers to worldwide destinations.

Identity of data controller

Seek Dharma Limited is a company registered in England and Wales under company number 13127983 (and whose registered office is at Second Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, United Kingdom). Seek Dharma Limited is registered with the Information Commissioner’s Office (the ‘ICO’) as a data controller with registration reference ZB343665.

The ICO is the United Kingdom’s independent statutory regulatory authority in relation to data protection and information rights.

The ICO provides a helpline and complaints service and can be contacted at: Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF or at www.ico.org.uk or by telephone on 0303 1231113.

Securing your personal information and your responsibilities

We take the security of your personal information very seriously and we use appropriate security measures to protect your informational privacy in the course of our business operations.

We have appropriate security measures in place to prevent personal information from being accidentally lost, used or accessed in an unauthorised way. We limit endeavour to access to your personal information to our staff and those who have a genuine business need to know it. Any processing of your information will only be carried out in accordance with the terms hereof and is subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

If you want detailed information on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.

Although it is our responsibility to ensure compliance with UK data protection laws, we also ask you to act responsibly with your own or your family and/or groups’ personal data. Therefore, please:

Make sure you read this Privacy Notice and that you and any other individuals you represent fully understand its contents. If you have any questions about it, please contact us at hello@seekdharma.com;
If you believe or are concerned that your informational privacy has been breached by using our website or in any dealings you have with us, please contact us immediately;
Although we use appropriate security measures to protect your informational privacy and follow industry best practice, you must understand that unfortunately, any form of data transmission which is based upon or which uses the Internet (including unencrypted emails) can never be guaranteed as completely secure.

Type of information we collect about you and how we use it

1 Visitors and users of our website – subscribers to newsletters, participants in surveys, contests and promotions

By accessing and using our website or completing an online contact form, subscribing to our newsletter, participating in our surveys or our competitions, we shall collect personal information about you and you agree to the collection, use, storage and transfer of your information by us under the terms of this Privacy Notice.

The type of personal information we may collect from you when you in this context, may include your name, postal address, e-mail address, country of residence and telephone number (if you complete the online contact sign up form). In addition, when you use our website, we shall collect information about your computer or mobile device, which we collate via the use of analytical software such as Google Analytics or other similar technologies. The information we collect includes details of your visits to our website, traffic data, location data, your IP address, operating system and browser type (please also see our Cookies Policy).

We use the personal information we collect about you as follows:

To contact you about any website-based enquiry you make to us or for your views on our services;
To keep you informed about our products and services that we offer and about our news and promotions;
To manage, maintain and improve the performance of our website and to provide targeted information to you about our products and services;
To send you our newsletters if you subscribe thereto;
To analyse the data that you submit when you participate in surveys;
To give effect to your participation in our promotions and contests.

2 Users and visitors of Social Media Channels

We may collect your personal information and social networking contact details if you provide and/or post feedback reviews or provide information about your experiences on a past, current or future trips with us.

The type of personal information we may collect from you is:

Personal details (your name, age, gender, nationality and place of residence);
Contact details including your email address and telephone numbers.

By providing feedback reviews and submitting any content and related images to our social media channels or website, you are deemed to have consented to process this information, and we may use it and include it in our direct marketing activities such as:

Print materials;
Website, social media posts and content feeds;
Email communications and newsletters;
Images of our trips.

Please also note, that when you travel with us, photographs or video footage may be taken either by Seek Dharma or one of our third party suppliers for the purposes of marketing or as outlined in our General Terms & Conditions. If you do not wish to appear in any photographs or video footage please contact us to withdraw your consent to any further use, and we will stop such use as from receipt of your notice to that effect.

3 Customers and Prospective Customers

We shall collect personal information about you if you make an enquiry about any of our travel experiences, ask us for a quote, make a booking with us, make any claims (including insurance claims) or make a complaint, or, if you use our support and administrative services or ask for further information from us.

The type of personal information we may collect from you is:

Personal details (your name, age, gender, nationality and place of residence);
Contact details including your email address and telephone numbers;
Emergency contact information;
Financial details (credit/debit card and bank details);
Travel documents (passport and visa information, travel insurance);
Care needs (special needs, medical conditions, dietary requirements);
Trip destination information (including, travel itinerary, accommodation preferences);
Information about your social preferences and interests;
Meal preferences;
Clothing size for swag/ merchandise;
Any other personal information as requested by a host which is needed in curating and customising the experience.

If you are a group organiser or any other lawfully authorised individual (e.g. a parent or legal guardian) and you are providing personal information to us on behalf of any person under the age of eighteen, please also see the section below ‘Processing Special Category Data and Children’s Privacy’.

We use the information collected about you as follows:

To process and manage your enquiry, quote, booking, claim or administrative service;
To share your personal data with our third party suppliers including, our affiliates and business partners;
For account management, including payment, debt management and refunds including third party payment gateways (such as Stripe) and secure online payment sites;
For claims management and insurance purposes;
For record-keeping purposes;
To contact you and respond to your enquiries and complaints;
To notify you about important changes or developments relating to your booking;
To keep you informed about our products and services that we offer and about news and promotions.

4 The Talent with Whom we Collaborate

We shall collect personal information about you if you host a trip with us under a talent partnership agreement.

The type of personal information we may collect from you is:

Personal details (your name, age, gender, nationality and place of residence);
Contact details including your email address and telephone numbers;
Emergency contact information;
Financial details (credit/debit card and bank details);
Travel documents (passport and visa information, travel insurance);
Curriculum vitae or biography ;
Photos and video footage.

We use the information collected about you as follows:

To enter your details on a partnership agreement and a trip agreement to be signed with you;
To market the trip and inform the public about you;
To pay your talent’s cut under our partnership agreement.

5 Our Suppliers, business partners and service providers, and any party with whom we contract

We shall collect personal information about you if you enter into an agreement with us in the course of our business as a supplier, business partner, service provider or otherwise.

The type of personal information we may collect from you is:

Personal details (your name, age, gender, nationality and place of residence);
Contact details including your email address and telephone numbers;
Financial details (credit/debit card and bank details);
Your company’s details that may contain personal data;
Some details about your health and safety to ensure that you comply with standard health and safety as required by ABTA.

We use the information collected about you as follows:

To enter your details on any agreement to be signed with you;
To contact you in case of need;
To pay your dues under an agreement signed with you.

6 Our Employees and anyone interested in applying to work for Seek Dharma limited or an affiliate thereof

We shall collect personal information about you if we hire you or you make an enquiry about offering your services to us as a member of our staff.

If you wish to apply for a job with us, and/or if you are hired by us, then the type of personal information that we may collect from you is:

Your name and contact details;
Your current and up to date CV;
Residency, domicile and nationality information;
Copies of relevant qualifications and licences;
Background checks (e.g. DBS certificates and also see below the section on Criminal Offence Data);
Work permit and visa applications;
Hobbies and personal preferences;
Your photo;
Details of any relevant medical conditions including dietary requirements;
Bank account details.

We use the information we collect about you as follows:

To arrange an interview or make you an offer of employment;
To communicate with you about the recruitment process.
To assess your skills, qualifications and suitability for the role and/or to assess your work;
To contact the providers of your references;
To generate contractual agreements and other legal documents to support your engagement;
To contact next of kin in an emergency;
To monitor and record your performance during agreed periods of service with us;
To record training undertaken;
To record and monitor any work place accidents;
To prepare your residency paperwork in case of need;
To pay your salary;
To inform our investors and clients about our team (your information is shared in this case in “team deck” and “team presentations”.

Basis of our lawful processing

The obligations imposed on us by UK data protection laws mean that we can only use your personal data if we have a lawful reason to do so. In this section we explain the lawful reasons we have for using your personal data:

Our contract with you

We use your personal data because it is necessary for the purposes of: (i) the formation, performance or termination of our agreement with you; or, (ii) because we have asked you or you have asked us to take specific steps before entering into such an agreement.

In summary, processing your personal data is contractually necessary for:

The sale and supply of our products and services to you;
Managing your booking, delivery of our services, receiving and making payments and refunds;
Making bookings with third parties on your behalf such as airlines, hotels and other intermediaries;
Communicating with third party providers such as our affiliates and partners and local service agencies;
Account management, including providing and administering your holiday booking;
Administrative tasks relating to our contract with you, including providing customer service messages and notifications relating to processing payments, managing claims;
Where you are a member of staff, a talent, a supplier, business partner or service provider, for the formation, performance and termination of our agreement with you and for the payment of any fees and/or remuneration and/or salaries due to you.

Our legal obligations

In some cases, processing your personal data is necessary for us to do in order to fulfil a legal obligation that we are required to comply with. This may include adhering to the requirements imposed by UK legislation or other mandatory obligations imposed by the public law agencies of your holiday destination relating to e.g. border control, security and anti-terrorism controls as well as Income Tax Acts, VAT Acts, Companies Acts, the regulatory requirements imposed by HMRC and the ICO, anti-money laundering measures, the prevention and detection of fraud, responding to a request from the courts or the police, defending legal rights, our insurance obligations and ICO record keeping obligations.

Your consent

Where you have given us your consent for us to process your personal data for any of the purposes set out above. You are deemed to have given us your consent for us to process your personal data when you use our website, participate in our surveys, promotions, subscribe to our newsletter, purchase our products and services, enter into a contract with us, apply for a job on our website. Please also see the section below ‘Your consent to this Privacy Notice and its enforcement’.

Please note that if you are a parent of legal guardian, group organiser or any other lawfully authorised individual and you are providing personal information to us on behalf of any person under the age of eighteen, then you warrant and agree that:

You have the explicit consent of all individuals in your party, to provide the necessary categories of personal information to us, and;
All members of your party are aware of our Privacy Notice and that their information is to be passed to us for processing.

(Please also see the sections below on ‘Processing Special Category Data ’ and ‘Keeping You Informed’).

Our legitimate interests

Where processing your personal data is necessary for our own legitimate interests or the legitimate interests of a third party, provided that those interests are not outweighed by your individual rights and interests.

Our legitimate interests are:

Delivering, developing, and improving our products and services;
Our direct marketing activities, including determining whether our marketing activities are effective;
Recording and monitoring telephone calls for training purposes and to improve the quality of our services;
Improving customer facing services, including managing complaints;
Producing management information including carrying out internal auditing and the administration of our business;
Preventing crime and detecting fraud.

We do not make your personal details available to third party companies for marketing purposes. We do not rent or trade marketing lists with other organisations or businesses. You can withdraw your consent to our marketing emails at any time either by clicking on the ‘Unsubscribe’ link in our notifications, messages or emails (where applicable) or by replying to our email with the words ‘please unsubscribe’ or sending us an email to hello@seekdharma.com.

How long we keep your data

We will retain your information for 10 years or as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your information, the purposes for which we process your information, whether we can achieve those purposes through other means, and the applicable legal requirements.

Consulting or modifying or deleting your data

You have the right to ask us at any time to consult the data stored with us and/or modify it. For this purpose you can contact our customer support team on this email: hello@seekdharma.com. You may also contact us on the same email to ask us to delete your data from our systems.

Processing Special Category Data

Where we collect, process and store any of your special category data, we only do so with your explicit consent or because:

Processing is necessary in the event of emergency, to protect your vital interests if you become physically or legally incapable of giving consent;
It is necessary for reasons of public interest in the area of public health such as protecting against serious cross-border threats to health;
It is necessary for the establishment, exercise or defence of legal claims either when we are faced with any legal claims made against us or where we pursue legal claims ourselves;
It is necessary for the purposes of carrying out our obligations and exercising specific rights in the field of employment, social security and social protection law, including preventive or occupational medicine, the working capacity of an employee, medical diagnosis or treatment.

Criminal Offence Data

Candidate applications which we progress for certain roles with Seek Dharma require us to conduct Disclosure and Barring Service (‘DBS’) checks in order to meet the safeguarding and due diligence criteria policies which the business has assessed and adopted in order to meet our legal obligations.

We are lawfully entitled to carry out a DBS check for the following purposes:

Employment;
Protecting the public against dishonesty;
Consent;
Legal claims.

Children’s Personal Data

Children’s personal data (which we consider to be the personal information of a person under the age of 18) is processed in accordance with the standards and published guidance of the ICO and in accordance with the terms of this Privacy Notice. For the avoidance of doubt, we do not send marketing communications to children nor do we use automated decision-making about children.

Storage of data

All data collected by Seek Dharma is mainly stored within the European Union or the United States of America. It may also be stored in the Google workspace cloud. In some instances, we may choose to engage other companies to store or process your personal data on our behalf. In every case, where we choose to do that, we will ensure that any company that we engage with is subject to the same standards of data security and provides you with the same level of personal data protection as we provide to you.

Where we may transfer or store your information outside the UK or the European Union, we will take steps to ensure that your privacy rights continue to be protected as outlined in this Privacy Notice (please also see the section ‘Sharing and transferring your personal data with or to third parties’ below).

Keeping you informed

If you are an existing customer and/or have bought or enquired about our products or services before, we may also use the information we collect to let you know about our other products and services which may be of interest to you and to keep you updated with information about promotional offers.

However, if you no longer want to receive material from us you can withdraw your consent at any time either by clicking on the ‘Unsubscribe’ link in our notifications, messages or emails (where applicable) or by replying to our email with the words ‘please unsubscribe’ or by replying to our email with the words ‘please unsubscribe’ or sending us an email hello@seekdharma.com.

Sharing and transferring your personal data with or to third parties

Depending on the services that we provide to you, we may be required to share and/or transfer your personal data with or to other organisations and companies in order to provide our contracted services to you and/or to meet our legal obligations.

We will only provide your personal information to those third party organisations and companies in order to deliver the service you have instructed us to perform and that we have engaged the third party to provide or that we are required to do by law. These services may include but are not limited to meeting our contractual obligations owed to you, the discharge of our own legal obligations, answering your questions about our products or services, sending postal mail and e-mails to you and to others, and, where necessary, to obtain professional advice.

Your personal data may be used to:

Process booking confirmation;
Request support or assistance in an emergency;
Provide necessary health and safety documentation to third party providers;
Settle invoices associated with our bookings;
Contact any of our employees involved with the tour.

And your personal data may be shared with:

Hosts;
Airlines;
Coach and other transport suppliers;
Hotels and local agents;
Insurance companies;
Security or credit checking agencies;
Public authorities and government entities (Customs and Immigration Agencies);
Venues and attractions;
Service providers or contractors;
Data analytics providers and data analytics tools or services;
Advertising or marketing companies;
Third-party application providers or outside professionals or advisers.

We share information under the following principles:

With your consent or at your direction — We will share your information with entities outside of Seek Dharma when we have your consent to do so, or it is done at your direction.
For external processing — We sometimes employ third parties outside of Seek Dharma to process information on our behalf in compliance with this Privacy Notice and using other appropriate security and confidentiality measures.
For legal purposes — We share your information when we believe that the disclosure is reasonably necessary to (a) comply with applicable laws, regulations, legal processes, or requests from law enforcement or regulatory authorities, (b) prevent, detect, or otherwise handle fraud, security, or technical issues, and (c) protect the safety, rights, or property of any person, the public, or Seek Dharma.
On a non-personal or aggregate basis — We may share information with third parties on both a non-personally identifying basis and an aggregate basis.
For business purposes — We may share your information in order to properly deliver our products or service to you, or in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. We may also share your information between and among Seek Dharma and its current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.

If you do not agree to us sharing or transferring your personal information in this way, then we will not be able to provide the holiday or tour.

Cookies

To obtain further information relating to the Cookies operating on our website, please view our Cookies Policy.

Other Websites

Our website contains links to other sites such as sponsors, our business partners and affiliates, accreditation companies and/or official regulating bodies. Seek Dharma is not responsible for the privacy practices or the content of any such linked websites.

Your Information Rights

The UK GDPR gives you a number of important information rights which in most cases you can exercise free of charge. However, your ability to exercise your information rights depends on various factors, and in some cases, it will not be possible for us to agree to your request e.g. where legal exemptions apply or where the specific right you seek does not apply to the type of information we hold.

In summary, your information rights are:

The right to obtain confirmation from us as to whether or not we are processing your personal data and if we are, the right to be provided with certain supplementary information about our processing activities; however, please note that this Privacy Notice is already designed to provide you with that supplementary information;
The right to ask us to correct any mistakes contained in the information we hold about you;
The right to require us to erase your personal data in certain situations;
The right to data portability, which means the right to receive (or for a third party you have chosen to receive) an electronic copy of the personal data you have given to us;
The absolute right to object at any time to processing your personal data where we only use it for direct marketing;
The right to object to decisions being taken about you based solely on automated means which produce legal effects concerning you or are similarly significant in how they affect you;
The right to object in certain other situations to our continued processing of your personal information;
The right to otherwise restrict our processing of your personal information in certain circumstances.

For further information on each of these information rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation, the link is here

https://ico.org.uk/your-data-matters/your-right-to-get-copies-of-your-data/

If you would like to exercise any of the information rights set out above, please contact us at hello@seekdharma.com or write to us at Seek Dharma Limited, Second Floor, Nucleus House, 2 Lower Mortlake Road, Richmond, Surrey, United Kingdom. Please provide us with enough information to identify you and let us know the information to which your request relates.

We always want to make sure that the personal information we hold about you is accurate and up to date. Therefore, if you think any information we hold about you is incorrect or incomplete, please email or write to us at the addresses given above as soon as possible so we can update our records.

Applicable law and dispute resolution

This Privacy Notice, and any dispute, controversy, proceedings or claim of whatever nature arising out of or in any way relating to this Privacy Notice or its formation (including any non-contractual disputes or claims), shall be governed by and construed in accordance with English law and the exclusive jurisdiction of the English Courts.

Insolvency

In the event of our insolvency we, or any appointed insolvency practitioner, may disclose your personal information to the CAA, and/or ABTA so that they can assess the status of your booking and advise you on the appropriate course of action under any scheme of financial protection. The CAA’s

General Privacy Notice is at https://www.caa.co.uk/Our-work/About-us/General-privacy-notice/ ABTA’s Privacy Notice is at https://www.abta.com/privacy-notice

Your consent to this Privacy Notice and its enforcement

YOU CONFIRM AND AGREE THAT BY USING OUR WEBSITE, SUBSCRIBING TO OUR NEWSLETTER, PARTICIPATING IN OUR SURVEYS, CONTESTS OR PROMOTIONS, USING OUR SOCIAL MEDIA CHANNELS, BUYING OUR PRODUCTS AND SERVICES, COLLABORATING WITH US AS A HOST, APPLYING FOR A JOB WITH US, ENTERING INTO AN AGREEMENT WITH US OR BY PARTICIPATING IN ANY TRIP, YOU:

(A) UNCONDITIONALLY CONSENT TO AND AGREE TO ALL OF THE TERMS AND CONDITIONS OF THIS PRIVACY NOTICE, INCLUDING WITHOUT LIMITATION AUTOMATICALLY CONSENTING TO THE COLLECTION, USE AND SHARING OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS PRIVACY NOTICE; AND
(B) FURTHER AGREE THAT NO PROVISION OF THIS PRIVACY POLICY SHALL LIMIT, CONDITION, ALTER, OR AMEND, IN ANY WAY WHATSOEVER, ANY RIGHTS THAT YOU MAY HAVE SEPARATELY GRANTED TO US PURSUANT TO ANY OTHER AGREEMENT THAT YOU MAY HAVE SEPARATELY ENTERED INTO WITH US.

Changes to this Privacy Notice

We keep our Privacy Notice under regular review and if we change our Privacy Notice we will post those changes on this page so that you are always aware of what personal information we collect and how we use it. You should therefore refer to this policy regularly.