Klunga Limited is the controller and responsible for your personal data (collectively referred to as “SimplyMaldives.ie”, “island-marketing.ie”, “we”, “us” or “our” in this privacy notice).

Introduction

This is a notice to inform you on how we collect and process your personal data, including any data you may provide through this website or via any other means (such as over the telephone) when you make an enquiry via our website, when you make a travel booking or when you sign up to our email newsletter.
We regret that if there are one or more points below with which you are not happy, your only choice is to leave our website immediately.
We undertake to preserve the confidentiality of all information you provide to us.
Our policy complies with the Data Protection Act 2018 (Act) accordingly incorporating the EU General Data Protection Regulation (GDPR).
The law requires us to tell you about your rights and our obligations to you in regards to the processing and control of your personal data. We do this now, by requesting that you read the information provided at knowyourprivacyrights.org
Except as set out below, we do not share, or sell, or disclose to a third party, any information collected through our website.
If you are not happy with our privacy notice or if have any complaint then you should tell us by email at info@simplymaldives.ie. If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Data Protection Commissioner. This can be done at dataprotection.ie

The bases on which we process information about you

Data protection laws require us to determine under which of six defined bases we process your personal information, and to notify you of the basis. In order to provide you with this detail, we have prepared the following table which describes the purpose to which we are using your data and the legal basis for doing so.

Purpose	Legal Basis
To provide you with information for a travel holiday and arrange your booking	Processing is necessary for the performance of a contract and in order to take steps at your request prior to entering into a contract
To transfer your personal data to those suppliers fulfilling or providing travel arrangements you have booked	Processing is necessary for the performance of a contract
To comply with laws and regulations	Processing is necessary to comply with legal obligations
For direct marketing purposes to make suggestions and recommendations to you about travel arrangements that may be of interest to you	Processing is based on your specific consent
To make back-ups of your data in case of emergencies and for disaster recovery purposes	Processing is necessary for the performance of a contract and to comply with legal obligations

If a basis on which we process your personal information is no longer relevant then we shall immediately stop processing your data.

If the basis changes then if required by law we shall notify you of the change and of any new basis under which we have determined that we can continue to process your information.

Data we collect about you

We will only collect the data necessary in order to provide you the travel services you request, such as, your first name, last name, title, date of birth, gender, email, contact numbers, passport details.

We only collect data relating to children when you make a booking with us and you have children in your party.

We collect the following special categories of personal data about you:

Dietary requirements; and
Health information.

We collect and process the above special categories of personal data only where it is necessary to do so in order to provide you with the travel service you have requested and only where you have provided us with your explicit consent to do so. You can withdraw this consent at any time however that may mean we are unable to make the necessary travel arrangements that you have requested.

Your email address is also collected for the purpose of direct marketing if you sign up to our newsletter. This is based on your consent, which you can withdraw at any time.

Information we share with third parties

We may share your details with a number of external parties in order to provide you with travel services and provide marketing services. For example: our Third Party Service Providers such as technology suppliers and storage providers.

Many of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Controls on data protection may not be the same as the legal requirements within the EEA. When you request a booking for travel arrangements which are located outside the EEA, we will have to transfer your personal data to those suppliers fulfilling or providing those travel arrangements in order to make your booking and for those suppliers to be able to provide you with the travel arrangements you have booked. In order to transfer your data, we will rely on the derogation under Article 49 of the GDPR in order to transfer your personal data to countries outside the EEA (as the transfer relates to the performance of a contract for your benefit), and you hereby permit us to do so.

We may also share your personal information that we hold as a result of our legal and regulatory obligations. This can include An Garda Siochána, other official agencies and on foot of a Court Order or Subpoena.

Your Rights

You have the following rights about the date we hold about you.

Request a copy of your personal data in a commonly used electronic format (or hard copy if you wish).
Request correction of your personal data.
Request erasure of your personal data.
Object to processing of your personal data.
Request restriction of processing your personal data.
Request transfer of your personal data to another company (using a commonly used electronic format).
Right to withdraw consent for marketing

All requests are free of charge. We aim to respond within one month of receipt of your request but if we cannot meet this time frame, we will tell you when we expect to respond. To exercise any of your rights, please send a request to info@simplymaldives.ie

Requests to restrict the use of your information or to object to the processing of your data may lead to us being unable to continue to offer you a service.

When we receive any request to access, edit or delete personal identifiable information, we shall first take reasonable steps to verify your identity before granting you access or otherwise taking any action. This is important to keeping your information safe.

How you can complain

If you are not happy with our privacy policy or if have any complaint then you should tell us by email. Our address is info@simplymaldives.ie

If a dispute is not settled then we hope you will agree to attempt to resolve it by engaging in good faith with us in a process of mediation or arbitration.

If you are in any way dissatisfied about how we process your personal information, you have a right to lodge a complaint with the Data Protection Commissioner. This can be done at https://www.dataprotection.ie/docs/complaints/1592.htm

Retention period for personal data

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We will delete it securely after 2 years.

Review of this privacy policy

We may update this privacy notice from time to time as necessary. The terms that apply to you are those posted here on our website on the day you use our website. We advise you to print a copy for your records.