Privacy Policy

At New Adventure Travel ltd (hereafter referred to as the company or N.A.T) we recognize the
importance of protecting your personal information and are committed to processing it responsibly and
in compliance with applicable data protection laws in all countries in which the company operates.
This Privacy Statement describes N.A.T ‘S general privacy practices that apply to personal information
we collect, use and share about consumers and other individuals within our clients, business partners,
supplier and other organizations with which N.A.T has or contemplates a business relationship.

This Privacy Statement is supplemented by other policies which provides more information in the
online context, including recruitment. We may provide additional or more specific information on the
collection or use of personal information on websites or related to a specific product or service.

Why and how we collect and use your personal information

We may collect your personal information as an individual for various purposes, such as the following:

I. Access and use of websites or other online services
When entering one of our websites, or using an online service, we will record information
necessary to provide you with access, for the operation of the website and for us to comply with
security and legal requirements in relation to operating our site, such as passwords, IP address
and browser settings. We also collect information about your activities during your visit in order to
personalize your website experience, such as recording your preferences and settings, and to
collect statistics to help us improve and further develop our websites, products and services.

II. Responding to your request for information, order, or support
When you contact us (online or offline) in connection with a request for information, to order a
product or service, to provide you with support, or to participate in a forum or other social
computing tool, we collect information necessary to fulfill your request, to grant you access to the
product or service, to provide you with support and to be able to contact you. For instance, we
collect your name and contact information, details about your request and your agreement with
we and the fulfilment, delivery and invoicing of your order and we may include client satisfaction
survey information. We retain such information for administrative purposes, defending our rights,
and in connection with our relationship with you.

When you provide your name and contact information to register in connection with such a
request, the registration may serve to identify you when you visit our websites. For ordering of
most services and products, we require you to have registered an IBMid. Registration may also
allow you to customize and control your privacy settings.

III. Contacting employees of our clients, prospects, partners and suppliers
In our relationship with clients or prospects, partners and suppliers, they also provide us with
business contact information (such as name, business contact details, position or title of their
employees, contractors, advisors and authorized users) for purposes such as contract
management, fulfilment, delivery of products and services, provision of support, invoicing and
management of the services or the relationship.

IV. Visitor information
We register individuals visiting our sites and locations (name, identification and business contact
information) and use camera supervision for reasons of security and safety of persons and
belongings, as well as for regulatory purposes.

V. Marketing
Most information we collect about you comes from our direct interactions with you. When you
register for an event we may collect information (online or offline) in relation to the event
organization, and during an event, such as participation in sessions and survey results. We
combine the personal information we collect to develop aggregate analysis and business
intelligence for conducting our business and for marketing purposes. You can choose to receive
information by email, telephone or postal mail about our products and services, or sign-up for
subscriptions. When visiting our websites or using our services we may provide you with
personalized information. You can always opt-out from receiving personalized communication by
sending an e-mail to Steve Davies on [email protected] Where we reference that we use
your personal information in connection with a request, order, transaction or agreement (or
preparing for the same), or to provide you with services that you requested (such as a website),
we do this because it is necessary for the performance of an agreement with you.
Where we reference that we use your personal information in relation to marketing, improvement
or development of our products or services, for reasons of safety and security, or regulatory
requirements other than in connection with your agreement or request, we do this on the basis of
our or a third party’s legitimate interests, or with your consent. When we collect and use your
personal information subject to the EU Privacy Legislation this may have consequences for

Your Rights
Sharing of Personal Information

As an organization offering a wide range of products and services, with business processes,
management structures and technical systems that cross borders, N.A.T has implemented global
policies, along with standards and procedures, for consistent protection of personal information. As a global company, we may share information about you with our subsidiaries and associated or parent
companies and transfer it to countries in the world where we do business in accordance with this
Privacy Statement.

Between our controlled subsidiaries, we only grant access to personal information on a need-to-know
basis, necessary for the purposes for which such access is granted. In some cases,
Where appropriate, N.A.T may also share your personal information with selected partners to help us
provide you, or the company you work for, products or services, or to fulfil your requests, or with your
consent. When selecting our suppliers and partners, we take into account their data handling processes.

If N.A.T decides to buy, merge or otherwise reorganize businesses such a transaction may involve the
disclosure of personal information to prospective or actual purchasers, or the receipt of such information from sellers. It is N.A.T's practice to require appropriate protection for personal information in these types of transactions.

Please be aware that in certain circumstances, personal information may be subject to disclosure to
government agencies pursuant to judicial proceeding, court order, or legal process. We may also share
your personal information to protect the rights or property of N.A.T, our business partners, suppliers or clients, and others when we have reasonable grounds to believe that such rights or property have been or could be affected.

Information Security and Accuracy

We intend to protect your personal information and to maintain its accuracy N.A.T implements
reasonable physical, administrative and technical safeguards to help us protect your personal
information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive
personal information such as credit card information when we transmit such information over the
Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.

Retention Period

We will not retain personal information longer than necessary to fulfil the purposes for which it is
processed, including the security of our processing complying with legal and regulatory obligations (e.g. audit, accounting and statutory retention terms), handling disputes, and for the establishment, exercise or defence of legal claims in the countries where we do business.

How to contact us

If you have a question related to this Privacy Statement, please contact the Data Protection Officer
You can request to access, update or correct your personal information. You also have the right to
object to direct marketing. You can access the request process.

You may have additional rights pursuant to your local law applicable to the processing. For example, if
the processing of your personal information is subject to the EU General Data Protection Regulation
("GDPR"), and your personal information is processed based on legitimate interests, you have the right
to object to the processing on grounds relating to your specific situation. Under GDPR you may also
have the right to request to have your personal information deleted or restricted and ask for portability of your personal information.

Right to Lodge a Complaint

In the event you consider our processing of your personal information not to be compliant with the
applicable data protection laws, you can lodge a complaint:

I. Directly with N.A.T.
II. With the competent data protection authority.

Changes to our Privacy Statements

From time to time we may update this Privacy Statement, as well as any other specific privacy
statement. When making changes to this Privacy Statement, we will add a new date at the end of this
Privacy Statement.
New Adventure Travel Ltd
Privacy Policy
This Privacy Statement is effective as of May 2018.
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