This Privacy Notice lets you know how Vasco Worldwide DMCC and its worldwide companies and subsidiaries (“One Vasco”, “we” or “us”) handle any personal data that you give to us or we may obtain about you.
This Policy applies to processing personal data by One Vasco with respect to the personal data of our website visitors and/or our customers.
LAST UPDATED 5th November 2018
I. WHO WE ARE?
One Vasco specializes in simplifying the matrix of contemporary global travel through seamless value innovation. The avant-garde enterprise offers a comprehensive bouquet of travel-related services to global traveler with an end-to-end view. With a global footprint across 35 countries, the services offered by One Vasco ranges from travel facilitation such as hotel and airline booking, transportation and destination management, One Vasco’s support to best-of-breed telecommunication and travel retail products.
Contact details of us:
Vasco Business Concepts Ltd
No.1, Bernin-Kebbi Crescent,Garki-2,Abuja, Nigeria.
II.YOUR DATA PROCESSOR AND YOUR DATA CONTROLLER.
1.In regards of the provision of the services listed below we act as a Data Controller.
- Visa Assistance
- your personal data provided in job application process
- wifi hotspot services
- One Vasco’s centers surveillance
- website usage data,
- enquiry & feedback data OneVasco
2. In regards of the provision of the services listed below we act as a Data Processor.
- Travel Insurance Providers
- At destination transport/ logistic service providers
- Telecom companies providing the selected telecom solutions
- Flight and hotel booking services
The Data Controller for these services is the product or service provider. As they determine what personal data is required to deliver their services. The details of the respective service provider will be identified to you at the time of the provision of the relevant services.
III. DATA PROTECTION OFFICER
If you have any questions regarding this Privacy Notice or our privacy practices, please contact our Data Protection Officer e-mail: firstname.lastname@example.org
IV. WHAT PERSONAL INFORMATION DO WE COLLECT?
Below you can find the categories of personal information that we may process about you, depending on the services you have requested from us. If you want to know exactly what personal data we have been processing, please contact our Data Protection Officer.
Some examples of Personal Information that One Vasco may collect for providing its services:
- We only collect the information from you that is required by the client government of the country for which you are applying for a visa to. This may include your name, title, address, telephone number, passport number, date of birth, email address, nationality, gender, family information, employer. If required by the relevant government authorities we might ask you for sensitive information such as photos, race, religion, health related information, biometrics or information about criminal history. This list is not exhaustive and varies depending on the relevant government’s requirements and the type of visa requested.
- Depending on which Travel Insurance service provider you have chosen, in order to deliver to you the Travel Insurance requested we may collect: your name; date of birth, address, e-mail and telephone details, gender, marital status, family status, passport number, destination country, beneficiary name, relationship, medical condition, ailments.
3.At destination transport
- For the purposes of assisting you to apply for international driving license, car rentals we collect your personal data contained in your passport, ID details, driving license and photo. For Chauffeur & Airport pick & drop services we collect your name, telephone details.
- When you buy local/ International pre-paid SIM cards, cross-border top-ups or Internet connection we might need to process your mobile number, and in some cases details of your passport.
5.Flight & Hotel bookings
- For Airlines booking and hotel accommodation we may request you for your personal details as required by the airline or the hotel. This includes: your name, passport information, address, email address, phone number, date of birth.
6.Website usage data:
- We collect information about your browsing session on our website. We do this by using cookies.
We may process data about your use of our website and services. This data may include:
- The host name of the end device (also known as the IP address).
- The time and date you visited the website.
- The referrer-URL, meaning the website from which you are accessing our website.
- Information about the browser you use while accessing our website.
7.Enquiry & Feedback data.
- We process information contained in any enquiry and feedback that you communicate to us through our website or e-mail regarding our services.
8.Job Application Data
- If you apply for job with us through our website, we may process the data you submit. This data may include your full name, gender, nationality, place where you are currently located, your visa status, e-mail ID, mobile number, your current employment details such as work experience, employer, designation, monthly salary, your key skills and education details as well as data which you provide us in your CV.
- When you access our Wi-Fi services provided by us at venues, some information is collected automatically. This information includes e.g. the unique device identifiers know as MAC ID, start and stop timestamps of your connections, amount of traffic and the logout reason type. In some countries, where mandated by law we must keep the log books of users of our WiFi. For this purpose we might request your name, surname, ID number.
V. PURPOSES OF THE PROCESSING
We process your persona data only for the purpose/s it was collected for. If we plan to use personal data for a different purpose, we will inform you via our Privacy Notice. Please check this page regularly to ensure that you’re happy with any changes.
You are not obliged to give us your personal data, however if you do not do so we may not be able to provide you with the requested services. We may require some personal information in order to enter into contract with you to provide the requested services.
We process your Visa Assistance related data for the purposes of providing you with
- One Vasco’s support
- Document pre-verification
- Application form filling assistance
- Appointment scheduling
- Courier delivery of passport or other documents if you have opted for such service.
We process your personal data, related to travel insurance you applied for, for the purposes of assisting you with obtaining said travel insurance.
3.At destination transport
We collect and transfer this data for the purposes of assisting you to apply for international driving license, car rentals and chauffeur & airport pick & drop services, depending on the service you have chosen.
We collect and transfer this data for the purposes of assisting you to apply for local/ international pre-paid SIM cards, cross-border top-ups, internet connection, as you have chosen.
5.Flight & Hotel bookings
If you requested for flight and or hotel booking services from us, we will collect and transfer your personal data to airline booking and hotel booking accommodation providers.
6.Website contact form
We may use your personal data for the purposes of communicating with you and this could be in response to your requests and/or the provision of requested services.
7.Website usage data
Website usage data will be processed for the purposes of analysing the use of our websites and statistical purposes as well as to improve our online services. This website usage data will not be used to identify you. One Vasco may use website obtained data to prevent misuse of our websites.
We process your Wifi services related data for the purposes of providing you with the WiFi services at One Vasco’s venues.
By clicking "Accept Cookies", you agree to the storing of cookies on your device to enhance site navigation, analyse site usage and to personalize content for you. We anonymously share information about the use of our site with our analytics partners
For more information please check our Cookies Disclosure Notice
10. Job Application Data
This data may be processed for the purposes of managing your job application as well as to communicating with you in the matters related to your job application.
11.Vasco Centers Surveillance
We may use CCTV to monitor our One Vasco’s centers and record the data for safety reasons and this data may be used if required to protect One Vasco from criminal offences and attacks, which might affect the functionality of our business as well as evidence of criminal offences that may have occurred in our centers.
VI.HOW DO WE COLLECT INFORMATION ABOUT YOU?
We obtain information about you when you use our website or our services, for example, hotel and airline booking, transportation and destination management, One Vasco’s support, telecommunication and travel retail products. We get your personal information also when you apply for a position with OneVasco through our website.
We may obtain information about you from the companies, to whom we are providing our services eg. visa concierge services.
VII. LAWFUL BASIS FOR PROCESSING
TO PROVIDE YOU WITH REQUESTED SERVICES
We will only use your personal data when the law allows us to. By engaging us to provide a service(s) you will be deemed to have given your implied consent to the processing of your personal data to enable the performance of this contract. Where required by law we will seek your explicit consent to process your personal data for the provision of the requested service(s).
TO COMPLY WITH LEGAL OR REGULATORY OBLIGATIONS
Some personal information about you we need to process to fulfill our legal obligation e.g. storing invoices for tax purposes.
WHERE NECESSARY FOR OUR LEGITIMATE INTERESTS
The legal basis for processing website usage data is our legitimate interest namely monitoring and improving our website and services, provided those interests do not override your fundamental rights and interests.
Our One Vasco’s Centers are under CCTV Surveillance, this is in our legitimate interest to ensuring the security of our One Vasco’s centers, crime prevention and detection as well as protection of your vital interests or the vital interests of another person.
Most of the cookies are automatically deleted from your hard drive at the end of a session, however some cookies remain in place across multiple visits on One Vasco website until you delete them, or they expire within a maximum of 13 months. For information how to find and accept/reject cookies, please read your browser help manual. User is always free to decline One Vasco's cookies if their browser permits, although doing so may interfere your use of our website.
For more details please read our Cookies Disclosure Notice.
IX. AUTOMATED DECISION-MAKING
As a rule, we do not make decisions based solely on automated processing. We only use automated decision making during the recruitment process. This automated decision making is used to scan the job applicants’ CV or resume to assess suitability with the role. You have the right to request human intervention in this process.
For more information contact our Data Protection Officer.
X.WHOM WE CAN SHARE YOUR PERSONAL DATA WITH?
One Vasco will not disclose your personal data to others unless, it is necessary for the performance of a contract with you, we have your permission to do so, in order to protect our legitimate interest or it is required by law.
Internal group sharing
We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes, and on the legal bases, set out in this Policy.
Third Party Service Providers
As you have opted for our service(s) we will provide certain of your personal details to third party service provider(s) depending the service you have chosen, in order to provide you with the service(s) requested by you. The details of the respective service provider will be identified to you at the time of the provision of the relevant services.
We may pass your personal information to other third-party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing services to you on our behalf (for example to process payments or deliver your documents to you by courier if you request so). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires the service provider(s) to keep your information secure and not to use it for their own direct marketing purposes.
We will not share your information with third parties for marketing purposes unless you have explicitly given us permission to do so. You can withdraw your consent for this at any time by contacting our Data Protection Officer.
Employment recruitment agencies
We use online platform powered by Naukrigulf.com to process application provided through our website by candidates seeking employment in our organization. When you provide your details and upload your CV through our website all these data will be processed by Naukigulf.com, however Naukrigulf will not share your personal data with other employers than OneVasco. The data you provide through Career tab on our website is subject to analytics, profiling and automated decision making performed by Naukrigulf.com. For more details of the security of your data processed by Naukrigulf.com please refer to Naukrigulf.com Privacy Notice available at https://www.naukrigulf.com/ni/nilinks/nkr_links.php?open=privacy&flag=&con=
If you wish not to be subject of automated decision making or profiling in course of recruitment process, please contact our HR department directly (HR@onevasco.com)
Other Parties who process data on our behalf include:
- Outsourced payroll providers
- IT support
- Storage service providers including cloud
- Background screening providers
When, required we might share personal information to comply with legal obligations and respond to requests from government agencies, including law enforcement and other public authorities which may include authorities outside your country of residence. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
One Vasco shall disclose information in good-faith only when it is necessary to comply with a court order, any on-going judicial proceeding, or other legal process served on One Vasco or to exercise the legal rights or defend against legal claims.
We may also disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of obtaining said professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
One Vasco may also disclose the information if the disclosure is reasonably necessary to enforce our terms and conditions in accordance with the applicable law. Further, One Vasco may disclose the information in the event of a merger, sale or re-structuring, acquisition, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, shares (including in connection with any bankruptcy or similar proceedings). In this case One Vasco will endeavor to ensure an appropriate protection of your data.
XI. INTERNATIONAL TRANSFERS OF YOUR PERSONAL DATA
As part of the services offered to you, the information which you provide to us will, in some circumstances, will be transferred outside the country of your residence. By applying for visa or other type of travel document your personal information will be sent to the country you are applying to visit. These countries may not have similar information protection laws to your country.
We will seek your consent to transfer your personal information “off-shore” if required by local law. We may transfer your personal information, internally within One Vasco to one of our data centres in the UK and India.
If we transfer personal information internally within the group companies from one country to another, where the data protection laws may not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection, e.g. we use European Commission approved standard contractual clauses, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about data transfer matters, please contact our Data Protection Officer.
XII. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. We review our retention periods for personal information on a regular basis.
We will hold your personal information on our systems only for the minimum time as is necessary for the relevant activity.
Your personal data and any other documents, hard copies, forms or other records containing personal information will be destroyed by a secure process within thirty (30) days of fulfilling the service that you have requested.
The CCTV related data we store as per local applicable laws.
Notwithstanding the above mentioned, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject (for example; invoices for taxation legislation), or in order to protect your vital interests or the vital interests of another natural person.
XIII. SECURITY OF PERSONAL DATA
One Vasco treats data as an asset that must be protected and uses tools like encryption, passwords, physical security, firewalls, and other security features and measures to protect users personal information against unauthorised disclosure, access, misuse, abuse, hacking etc.
XIV. YOUR RIGHTS IN RELATION TO PERSONAL DATA
You have certain rights with regards to how your personal information is processed. You may exercise any of your rights in relation to your personal data by written notice to our Data Protection Officer.
Some of the rights are complex, and not all of the details have been included in our summaries. Your principal rights are:
The right to be informed about the collection and use of your personal data.
Where personal data relating to you is collected, we inform you about the following: the identity and the contact details of the controller, the contact details of the data protection officer, details of the purposes of the processing, legal basis for the processing, the categories of personal data concerned and the recipients of the personal dataand where applicable about transfer personal data to a third country.
- The right of access to your personal data
- The right to rectification.
- The right to erasure your personal data (Right to be forgotten)
- Right to restrictions of processing
- Right to notification regarding rectification or erasure your personal data or restriction
- Right to data portability
- Right to object
- Rights in relation to automated decision making and profiling.
- The right to withdraw your consent
- The right to lodge a complaint with a supervisory authority
If at any time you believe that One Vasco has not adhered to the Privacy Notice, please inform us by e-mail at email@example.com and we will make all commercially reasonable efforts and steps to promptly determine and resolve the issue.
If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the country of your habitual residence, your place of work or the place of the alleged infringement.
XV. WITHDRAWING YOUR CONSENT
To the extent that the legal basis for our processing of your personal information is consent, you can anytime withdraw your consent that was given to One Vasco earlier. However, without your consent in most of the circumstances we cannot continue to process the services that you have requested. Withdrawal of your consent will not affect the lawfulness of processing before the withdrawal.
In regard to marketing purposes we will not contact you for marketing purposes unless you have given us your explicit permission to do so, nevertheless you have right at any time to withdraw your consent for marketing purposes without effect on our services, provided to you. In any of the above cases, please notify your withdrawal via an E-Mail to [firstname.lastname@example.org].
When you approve Cookies pop-up alert, while accessing the One Vasco website. You are always free to decline/turn off One Vasco's cookies if your browser permits the same, although doing so may interfere your use of our website.
XVI. LINKS TO OTHER WEBSITES
Our website may contain links to other websites run by other organisations. These links are provided as a courtesy of One Vasco and by accessing those links, you will leave One Vasco’s website. This privacy notice applies only to One Vasco’s website. We are not responsible for the policies, security and practices of other sites even if you access them using links from our website. In addition, if you linked to our website from a third-party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that you check the privacy notice of that third-party site.
We encourage you to review the privacy policies of any third-party website(s) before providing any personal data.
One Vasco does not share opinions which might be contained on linked websites. Each operator of the linked website is solely responsible for its content. One Vasco does not verify the information contained on the linked Websites on a regular basis.
We link to our social networking websites to interact with international audiences. Our social networking websites are used to facilitate seamless services, to publish events or notices related to our services, as well as to help you to apply to jobs in our organization that match your skills and contact with us.
XVII. PERSONAL DATA OF CHILDREN
Our website and services are targeted at persons over the age of 18.
If we have reason to believe that we hold personal data of a person under that age in our databases, without valid parental consent, we will delete that personal data.
One Vasco shall not be held responsible for the authenticity or accuracy of the information provided by the user. It shall be the duty of the user to ensure that the information provided to One Vasco is accurate.
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
XX. CONTACT US
If you have questions about this Policy Notice or our privacy practices or you want to update your personal data, please feel free to contact us in the one of the following ways: One Vasco’s Data Protection Officer: