Effective Date: June 30, 2025
TravelTrade.Today (“we,” “us,” or “our”) operates the website located at www.traveltrade.today (the “Website”), a news aggregation platform dedicated to providing updates and insights for the travel trade industry. We are committed to protecting the privacy of our users. This Privacy Policy explains what information we collect, how we use it, with whom we share it, and your rights regarding your personal information when you use our Website.
By accessing or using our Website, you agree to the terms of this Privacy Policy. If you do not agree with the practices described in this Privacy Policy, please do not use our Website.
1. Important Definitions (South Africa – POPIA)
- “Personal Information”: Means information relating to an identifiable, living, natural person, and where it is applicable, an identifiable, existing juristic person, including but not limited to:
- information relating to the race, gender, sex, pregnancy, marital status, national, ethnic or social origin, colour, sexual orientation, age, physical or mental health, well-being, disability, religion, conscience, belief, culture, language and birth of the person;
- information relating to the education or the medical, financial, criminal or employment history of the person;
- any identifying number, symbol, e-mail address, physical address, telephone number, location information, online identifier or other particular assignment to the person;
- the biometric information of the person;
- the personal opinions, views or preferences of the person;
- correspondence sent by the person that is implicitly or explicitly of a private or confidential nature or further correspondence that would reveal the contents of the original correspondence;1
- the views or opinions of another individual about the person; and2
- the name of the person if it appears with other personal information relating to the person or if the disclosure of 3the name itself would reveal information about the person.
- “Process” or “Processing”: Means any operation or activity or any set of operations, whether or not by automatic means, concerning Personal Information, including:
- the collection, receipt, recording, organisation, collation, storage, updating or modification, retrieval, alteration, consultation or use;4
- dissemination by means of transmission, distribution or making available in any other form; or5
- merging, linking, as well as restriction, degradation, erasure or destruction of information.6
- “7Responsible Party”: In relation to Personal Information, means a public or private body or any other person which, alone or in conjunction with others, determines the purpose of and means for Processing Personal Information. For the purposes of this Privacy Policy, TravelTrade.Today is the Responsible Party.
- “Data Subject”: The person to whom Personal Information relates. This is you, the user of our Website.
We collect various types of information for different purposes to provide and improve our service to you.
While using our Website, you may voluntarily provide us with certain Personal Information, including but not limited to:
- Contact Information: Your name, email address, company name, and job title when you subscribe to our newsletters, register for an account (if applicable), or contact us directly.
- Communication Content: Any information you include in your communications with us (e.g., emails, feedback forms).
- User Contributions: Any comments, posts, or other content you submit to interactive areas of the Website (if available).
As you navigate through and interact with our Website, we may use automatic data collection technologies to gather certain non-personal information about your equipment, Browse actions, and patterns, including:
- Usage Details: Information about your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.8
- Device Information: Information about your computer and internet connection, including your IP address, operating s9ystem, browser type, and referrer URL.
- Browse Behavior: Details of your visits, such as pages viewed, time spent on pages, clickstream data, and the paths you take through our Website.
The technologies we use for this automatic data collection may include:
- Cookies (or browser cookies): A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.10
- Web Beacons: Pages of our Website and our emails may contain small electronic files known as web beacons (also ref11erred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).
We use the information we collect for various purposes, including:
- To provide and maintain our Website: Including displaying aggregated news content and ensuring its functionality.
- To improve our Website: To understand user behaviour, identify popular content, and enhance user experience.
- To send you newsletters and promotional materials: If you have opted-in to receive them, providing industry updates, special reports, and relevant marketing communications.
- To respond to your inquiries: When you contact us for support or information.
- For analytics and research: To analyse trends, track user engagement, and gather demographic information for internal business purposes.
- For security and fraud prevention: To detect, prevent, and address technical issues, fraud, or other illegal activities.
- To comply with legal obligations: To meet our legal and regulatory requirements.
Under the Protection of Personal Information Act (POPIA) in South Africa and the General Data Protection Regulation (GDPR) for users in the European Union (EU)/European Economic Area (EEA), we process your Personal Information based on the following legal grounds:
- Consent: Where you have given us clear consent for specific processing purposes (e.g., subscribing to a newsletter). You have the right to withdraw your consent at any time.
- Legitimate Interests: Where the processing is necessary for our legitimate interests or the legitimate interests of a third party, provided those interests are not overridden by your fundamental rights and interests. Our legitimate interests include operating our Website, improving our services, understanding user engagement, and direct marketing.
- Legal Obligation: Where the processing is necessary for compliance with a legal obligation to which we are subject (e.g., tax laws, responding to legal requests).
- Contractual Necessity: Where the processing is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into a contract (e.g., providing a requested service).
We may disclose aggregated, non-personally identifiable information about our users without restriction.
We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
- To our subsidiaries and affiliates: For internal business purposes consistent with this Privacy Policy.
- To contractors, service providers, and other third parties: We use third-party service providers to help us operate our Website and deliver our services (e.g., hosting providers, email service providers, analytics providers). These third parties are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
- To fulfill the purpose for which you provide it: For example, if you subscribe to a newsletter, we may share your email with our email service provider to send you the newsletter.
- For legal reasons: To comply with any court order, law, or legal process, including to respond to any government or regulatory request. This includes responding to lawful requests from public authorities to meet national security or law enforcement requirements.
- To enforce or apply our Terms and Conditions and other agreements.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TravelTrade.Today, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- In the event of a merger, acquisition, restructuring, or sale of assets: Personal Information held by us may be among the assets transferred.
We do not sell your Personal Information to third parties.
6. Data Security
We have implemented reasonable technical and organisational measures designed to secure your Personal Information from accidental loss and from unauthorised access, use, alteration, and disclosure. However, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
7. Data Retention
We retain your Personal Information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
8. Your Data Protection Rights
You have certain rights regarding your Personal Information under POPIA and, if applicable, GDPR. These rights may include:
- The Right to Access: You have the right to request copies of your Personal Information that we hold.
- The Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or complete information you believe is incomplete.
- The Right to Erasure (Right to be Forgotten): You have the right to request that we erase your Personal Information, under certain conditions.
- The Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Information, under certain conditions.12
- The Right to Object to Processing: You have the right to object to our processing of13 your Personal Information, under certain conditions, particularly where we process based on legitimate interests or for direct marketing.
- The Right to Data Portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
- The Right to Lodge a Complaint: You have the right to lodge a complaint with the Information Regulator in South Africa or a supervisory authority in your country of residence if you believe your rights have been infringed.
To exercise any of these rights, please contact us using the contact details provided below. We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it.
9. Third-Party Links
Our Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
10. Children’s Privacy
Our Website is not intended for children under 13 years of age. No one under age 13 may provide any Personal Information to or on the Website. We do not knowingly collect Personal Information from children under 13. If you are under 13, do not use or provid14e any information on this Website or through any of its features. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.
11. Changes to Our Privacy Policy
It is our policy to post any changes we make to our Privacy Policy on this page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.15
To ask questions or comment about this Privacy Policy and our privacy pract17ices, contact us at:
Email: info (the at sign) traveltrade (dot)today.
