G Adventures Privacy Notice

Last Updated: September, 2023.

This privacy notice (the “Privacy Notice” or the “Notice”) explains how G Adventures Inc., its affiliates, and subsidiaries (“G Adventures”, “we”, “us”, “our”) process and handle personal information when you book a Tour with us, inquire about booking a Tour with us, visit our website, use our mobile app, or otherwise receive any related products or services from us.

Your privacy matters to us and we take our data protection and privacy responsibilities seriously. We follow the practices described in this Notice and treat your personal information in accordance with applicable law in the places where we operate. In some cases, we may provide additional data privacy notices specific to certain products, practices, or regions. Any such additional notices are to be read in conjunction with this Notice.

We may change this Privacy Notice from time to time. If we make changes, we will revise the date at the end of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Outline

What personal information we collect from you

When you book a tour or inquire about booking a tour with us…

We collect various pieces of personal information about you when you inquire about booking one of our Tours. This information may be collected via our website, our app, in speaking with a third-party travel agent or in working with one of our sales agents. Depending on which of our services you’re inquiring about, we will typically collect the following:

• Your first and last name, phone number, address, email address, & date of birth;

Once you have booked a Tour, we need more personal information to get you ready for your adventure as a part of a process we call “Good-to-Go”. This is needed in part, to be able to verify your identity, assess suitability of the selected Tour, provide notices and updates to you about your Tour, and to process your payment. The information we require for the ‘Good-to-Go’ process includes:

• gender, next of kin, travel insurance details, residency, emergency contact information, ISIC information (where applicable), payment information, nutrition preferences, passport details including (where applicable) a scanned copy of your passport, information required for a visa application; and
• Health and medical information such as pre-existing medical conditions, vaccination status, and special requirements concerning medication that may impact your ability to safely participate in the Tour.

We may also collect the personal information of co-travellers whose information you provide us on their behalf as a part of the booking process. By providing us with personal information about others, you certify that you have permission to provide that information to G Adventures for the purposes described in this Notice, and that they have read and understood how it applies to them.

When you place a call to us to inquire about purchasing a Tour, to ask questions or to resolve an issue, that call may be recorded and/or monitored for quality control, training, and customer service purposes. In so doing, we may collect information such as the identity of the caller, the date and time of the call, and the subject matter of the call.

When you visit our website or use our mobile app…

When you visit the G Adventures website or use our mobile app, we may collect various data points, some of which may be considered personal information. This information may include:

• Geo-location Information. Such as precise or approximate location determined from your IP address or mobile device’s GPS depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.
• Usage Information. Such as the pages or content you view, searches for tours, bookings you have made, and other actions on our app or website.
• Log Data and Device Information. Such as details about how you are using the website or app (including if you clicked on links to third party applications), access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, and the pages you have viewed or engaged with before or after using the website or app. We may collect this information even if you have not created a G Adventures account or logged in.
• Payment Transaction Information. Such as payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address, and other related transaction details.
• Cookies. Our website uses a technology called a “cookie” as described in our Cookie Policy. The Cookie Policy explains the ways we use cookies on our website and mobile app.

Photos and videos taken while travelling on a Tour…

While on a Tour, photos or videos may be taken by other travellers or by one of our CEOs that may contain you or your likeness and which may constitute personal information. Any photos or videos taken by a CEO or one of our representatives will not be used for marketing purposes without your prior knowledge and permission. We take care in handling and collecting your personal information, but we are not responsible for other travellers on your Tour who may take your photo without your permission.

Occasionally, a professional photographer may be scheduled on your Tour for the purposes of taking pictures and videos to be used for promotional purposes. In such instances, we will present you with consent and waiver form that you will have the option to accept or decline prior to your Tour departure.

When you apply for a job with us…

If you apply for a job with us, we will collect personal information such as your name and contact information, your employment history, and other personal information that may reasonably be required to verify your identity and evaluate your suitability for the job to which you have applied.

How do we use your personal information?

We collect, hold and use your personal information (subject to the selections you make and applicable laws) for a variety of business purposes but in general to provide, improve, customize, support and market Tours and any connected or related services we may provide to you. These purposes include:

To provide, improve, and develop our Tours and any related services…

Our primary use of your personal information is to arrange and provide you the Tours you have booked and any associated services connected to delivering these Tours. Some examples of the use of your personal information include:

• To enable the presentation of booking information in your account on our website or in our mobile app;
• To enable the functionality of the ‘Tree-for-days’ components of our website and the personalization of these elements on your g.com account, where applicable;
• To create a personal identifier for booking services so that we may identify you and distinguish you from our other customers;
• To create a personal identifier for chat functionality and for notifications;
• To provide our staff with the required information to operate G Adventures services booked by you;
• To perform analytics, & debug our technology (e.g. our website or our mobile app) to ensure that it operates as intended and without interruption;
• To send you messages, updates, security alerts, and account notifications about any Tour or connected services that you have requested; and
• To provide you ongoing service and support, including to assist in the resolution of any issues you may experience.

To comply with our legal obligations and to carry out the administration of our business…

In certain limited instances, G Adventures may be required to use your personal information to comply with our legal obligations, for example, to comply with local laws in the countries you visit on Tour. We may also use your personal information to conduct the internal administration of our business such as to carry out internal accounting.

To provide, personalize, measure and improve our advertising and marketing…

G Adventures also uses your personal information to tell you about our Tours, special offers, and related products and services. Such marketing purposes include:

• To send you promotional messages, marketing, advertising, and other information based on your preferences and social media advertising through social media platforms;
• To personalize, measure, and improve our advertising;
• To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events;
• To invite you to events and other relevant opportunities.

Promotions for these products and services may be offered by us or our brand partners.

How do we share your personal information?

There are a few different circumstances where we may share your personal information with a third party. No matter what, we take great care in ensuring that our business partners & third parties with whom your information may be shared, will treat it with the same degree of a care and attention that we do. We will not sell, distribute, or otherwise share your personal information unless we (i) have your permission and consent, or (ii) are required or permitted by law to do so. We may share your personal information or other information we have collected about you in connection with the following purposes:

• Sharing with your consent or at your direction. Where you provide consent, we share your information as described at the time of consent, such as when authorizing a third-party application to access your account, when using a third-party payment processor to process a payment or when participating in G Adventures’ promotional activities.
• On Tour Service providers. We share personal information with affiliated and unaffiliated service providers to help us run our business and to provide you with the services you direct us to provide. This includes service providers that help us: (i) provide accommodations, (ii) provide transportation, (iii) provide activities on Tour, (iv) sell Tours and confirm which services you have requested (e.g. travel agencies and our branded partners). We share your information internally with employees who have a need to know, and with our internal contractors which include our Chief Experience Officers (or CEOs). These providers are contractually bound to keep personal information confidential, secure, and to use it only for the purposes for which we disclose it to them. In some cases, we may share your personal information with government authorities (e.g. for border crossings and visa requirements).
• IT and Support Services. We also use a range of third parties to help us operate, provide, improve, customize and market our Tours and services. These include IT service providers who provide things such as website and application development, technology hosting (for example, to enable functionality of the ‘Trees-for-days’ elements of the website), maintenance, backup and storage, along with payment processing and other related services. Additionally, we work with a network of partners (both affiliated and unaffiliated) who help us market and promote our Tours, who send marketing materials on our behalf, who generate leads and resell our services.
• Business transfer or corporate reorganization. If G Adventures undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g. for due diligence purposes).
• National Geographic Journeys with G Adventures. If you are travelling on a “National Geographic Journeys with G Adventures” or a “National Geographic Family Journeys” Tour, then we may share your personal information with National Geographic Partners, LLC in compliance with our contractual obligations and in support of providing you a Tour or an associated service.

Service providers & business partners that process personal information on our behalf do so for our purposes only, and must agree to certain privacy obligations in their contracts with us. These include complying with privacy laws, safeguarding the personal information, and only processing that information under our direction for permitted purposes.

Cross-border transfers…

G Adventures operates worldwide to deliver its Tours. It is necessary to share your information within the G Adventures group of entities and with third parties, many of which are located around the world and in the countries in which our Tours operate.

Because of this, please note that if you are a resident in the United Kingdom, European Union or European Economic Area (“EEA”) we may transfer and hold your personal information outside of the EEA. When we transfer your information overseas, we seek to ensure appropriate privacy, confidentiality and security measures are in place, and that we comply with all applicable data protection and privacy laws. Our Tours, and the service providers who provide components of those tours (e.g. the local hotels, and local transportation providers), operate in over 100 countries and across all regions of the world, so it is not possible to list of all these countries in this Notice.

Regardless of what region, and to whom we transfer your personal information, we take appropriate steps to ensure that it receives an adequate level of protection (for example by implementing technical security measures and enforcing data protection related contractual clauses). You may contact our Privacy Officer via the method described below for more information about the safeguards we have put in place.

Your rights

You have the right to access, update, and correct inaccuracies in your personal information in our custody and control, subject to certain exceptions prescribed by law. A more fulsome description of these rights is as follows:

• You may ask us to correct any inaccurate, incomplete or out-of-date information that we have about you;
• You may ask us to provide a copy of the information that we hold about you, or that we transfer that information to another service provider;
• You may request that we stop processing or using your information;
• You may request that we delete any/all information that we hold about you; or
• You may withdraw consent that you have previously provided us.

If you are a resident of the United Kingdom, European Union, or the EEA, you may also (subject to certain exceptions):

• Withdraw your consent to our use of information for marketing purposes;
• Object to the processing of your information, where that information is collected for a legitimate purpose; or
• Request that your personal information be transferred to you or a third party in a format that is commonly used and accessible.

If you are a resident of California, you may also (subject to certain exceptions):

• request to know more about the categories and specific pieces of personal information we collect, use, and disclose;
• request deletion of your personal information;
• opt out of any “sales” of your personal information that may be occurring; and
• not be discriminated against for exercising these rights.

You may exercise these rights by contacting our Privacy Officer via the method described in the following section. We will only perform the activities outlined above to the extent that such activities will not contravene our legal or security interests or the privacy interests of other persons.

Your exercising of these rights may impede our ability to provide you the services you have contracted for or may make it impossible. We will always communicate with you about any consequences of actioning your requests before proceeding, or give you written reasons for any refusal.

How to contact us

G Adventures has a dedicated Privacy Officer who is responsible for responding to questions about this Privacy Notice and for addressing a request from you concerning your rights listed above.

We treat privacy matters seriously. If you have any concerns or questions, we invite you to contact our Privacy Officer.

You may do so by mail or e-mail. By mail you may reach us at:

Attn: Privacy Officer
G Adventures
19 Charlotte Street
Toronto, Ontario, Canada
M5V 2H5

By e-mail you may reach us at: privacyofficer@gadventures.com

We may contact you within a reasonable time frame after receiving your inquiry to verify who you are, or to ask any follow up questions we may have to better understand your inquiry.

Security

G Adventures is committed to keeping your personal information secure. We implement and maintain various security measures designed to protect your personal information that we have in our custody and control. We maintain reasonable administrative, technical and physical safeguards to protect against unauthorized access, use, modification and disclosure of personal information. We have put in place adequate procedures to deal with any actual or suspected personal information breach and will notify you and any applicable regulator of any data breach where we are legally required to do so. Unfortunately, no collection or transmission of information over the internet or other publicly accessible communications networks can be guaranteed to be 100% secure, and therefore, we cannot ensure or warrant the security of any such information.

Retention

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability, we may have to you. If you would like to know more about our data retention practices, please contact our Privacy Officer via the method described above.