Privacy Notice

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Sanguinetti & Company, LLC respects your privacy and is committed to protecting your personal data. This Privacy Notice applies to sanguinetticompany.com, visiteastafrika.com and/or any Website owned, operated, licensed or controlled by Sanguinetti & Company, LLC (referred to in this Privacy Notice as the "Site"). This Site is intended for use by persons who are residents of the United States of America and who are over 18 years of age. By using this Site, you accept the practices described in this Privacy Notice. This Privacy Notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) or when you otherwise provide personal data to us via other means (such as over the telephone or by fillable form) (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

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Please also use refer to the Glossary that we have set out at the end of the Notice, if there is any terminology used in this Privacy Notice that you are unfamiliar with or that you don’t fully understand.

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Purpose of this Privacy Notice

This Privacy Notice aims to give you information on how Sanguinetti & Company, collects, managers and processes your personal data, including any data you may provide through this website or via any other means (such as over the telephone or by fillable form) when you purchase travel arrangements through us or otherwise provide personal data to us.

This website is not intended for children, and the only circumstance in which we collect data relating to children is when you make a booking of arrangements and you have children in your party.

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It is important that you read this privacy notice together with any other Privacy Notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements the other notices and is not intended to override them.

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Sanguinetti & Company, LLC is the controller and in certain circumstances a processor and responsible for your personal data (collectively referred to as "Sanguinetti & Company", "we", "us" or "our" in this Privacy Notice).

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If you have any questions about this Privacy Notice, including any requests to exercise your legal rights, please contact the COMPANY: info@sanguinetticompany.com

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You have the right to make a complaint at any time, please contact us in the first instance.

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Changes to the Privacy Notice and your duty to inform us of changes

This version was last updated on February 2019 and historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if any of the details you provide to us should change during the course of your relationship with us.

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Third-party links

This website may include links to third-party websites, 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 websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

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The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data from which the identity has been removed (anonymous data).

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We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

(A) Identity - This includes data relating specifically to your identity, such as your first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender.

(B) Contact Data - This includes data relating to how you may be contacted, such as your home address, business address, email address and telephone numbers.

(C) Financial Data - This include data relating to your means and methods of payment, such as your bank account and payment card details.

(D) Transaction Data - This includes data relating to the transactions you have carried out with us, such as details about payments to and from you and other details of products and services you have purchased from us.

(E) Technical Data - This includes more technical data that we may obtain when you make use of our website, such as your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

(F) Profile Data - This includes the data that we receive if and when you create a profile on our website and make use of that profile, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

(G) Usage Data - This includes information about how you use our website, products and services.

(H) Marketing and Communications Data - This includes your preferences in relation to whether or not you want to receive marketing from us and our third parties and also your communication preferences.

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We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Privacy Notice.

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Special Categories of Personal Data

During our interactions we may collect special categories of personal data about you as detailed below. This may be because you want us to have the information or inadvertently as result of a group you travel with. It may also be because we need to know certain personal data about you which is special category data in order that we can provide you with the best possible service and advise you whether a trip is suitable for you. Health is one of the best examples of this.

Example, If we receive a group booking from a specific religious association we will inadvertently have details of religious beliefs of those individuals. The same can be said for groups from political associations and trade union associations.

Example, We are sometimes asked whether certain medication is allowed to be taken into certain jurisdictions which discloses certain medical conditions.

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Other special category of personal data which we may end up receiving from you include details about your:

• dietary requirements which may disclose your religious or philosophical beliefs;

• health;

• race or ethnicity;

• sex life or your sexual orientation;

• political opinions;

• trade union membership;

• genetic and biometric data.

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We collect and process the above data only where it is strictly necessary to do so. Furthermore, we will only collect and process the above special categories of sensitive personal data where you have provided us with your explicit consent to do so.

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You are not under any obligation to consent to us processing your sensitive personal data. If you consent to our use of your sensitive personal data, you will also be able to withdraw your consent at any time.

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We use different methods to collect data from and about you including through:

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(A) Direct interactions

You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• make a booking of arrangements;

• request a quote for arrangements;

• subscribe to our newsletter or other publications;

• request marketing;

• enter a competition, promotion or survey;

• give us some feedback; or

• use our online payment and client portals.

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(B) Automated technologies or interactions

As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns.

• We collect this personal data by using cookies, or other similar technologies. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

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(C) Third parties

We may receive personal data about you from various third parties as set out below:

• Technical Data from the following parties:

(i) analytics providers such as Google;
(ii) advertising networks such as Google; and

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(D) From time to time we may run competitions with third parties where we would collect data about you however, all participants have the option to opt in or out to receive any information from us.

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4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where we need to comply with a legal or regulatory obligation.

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Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us at info@sanguinetticompany.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the following table.

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Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

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Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

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Opting out

You can ask us to stop sending you marketing messages at any time by following the opt-out unsubscribe links on any marketing message sent to you or by contacting your travel consultant at any time or by sending an email to info@sanguinetticompany.com. Where you opt out of receiving these marketing messages, you will still receive communications that are required as a result of a purchase of arrangements or other such transactions.

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Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, email info@sanguinetticompany.com

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

(A) Internal Third Parties as set out in the Glossary.

(B) External Third Parties as set out in the Glossary.

(C) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.

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We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

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We do transfer your personal data outside the United States in order to satisfy our contract with you when you are travelling outside of the USA.

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We strive to put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

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We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Details of retention periods for different aspects of your personal data are available by contacting us: info@sanguinetticompany.com.

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In addition to the above, we may by law, have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for ten years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data; see Request erasure below for further information. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

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Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out below, please contact us at info@sanguinetticompany.com:

(A) Request access to your personal data.

(B) Request correction of your personal data.

(C) Request erasure of your personal data.

(D) Object to processing of your personal data.

(E) Request restriction of processing your personal data.

(F) Request transfer of your personal data.

(G) Right to withdraw consent.

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No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

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What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. You will be required to show your identification to a Sanguinetti & Company, LLC representative at the head office.

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Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

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Glossary

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LAWFUL BASIS

• Legitimate Interest

means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us at info@sanguinetticompany.com.

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• Performance of Contract

means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

• Comply with a legal or regulatory obligation

means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

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THIRD PARTIES

• Internal Third Parties

Other companies in the Sanguinetti & Company, LLC group acting as joint controllers or processors and who are based globally and provide travel related services, IT and system administration, Human Resources Related services, finance and legal.

• External Third Parties

i. Service providers acting as processors based globally and providing travel related services.

ii. Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, information technology service providers and insurers based globally who provide consultancy, banking, legal, insurance and accounting services.

iii. HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based globally who require reporting of processing activities in certain circumstances.

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YOUR LEGAL RIGHTS

You have the right to:

• Request access

to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

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• Request correction

of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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• Request erasure

of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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• Object to processing

of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.

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• Request restriction of processing

of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

(a) if you want us to establish the data's accuracy;

(b) where our use of the data is unlawful, but you do not want us to erase it;

(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

(d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

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• Request the transfer

of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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• Withdraw consent at any time

where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

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