PRIVACY POLICY
KIMA SURF SRI LANKA

“Welcome to Kima Surf Privacy Policy. Thank you for taking the time to read it. The terms “we”, “us” and “our” refer to Kima Surf a global surf travel brand with head offices in Asia, Bali that manages an extensive portfolio of travel-focused services operating under the brand name “Kima Surf”. Our contact details can be found at the end of these Terms. The term “you” and “your” refers to the Customer using our services or website, booking a reservation through us or otherwise using our services. This policy outlines the information we collect from you — and what we do with it. Moreover, for the purposes of this privacy policy the following words or phrases have the meaning shown below, unless the context clearly indicates otherwise:

EFFECTIVE DATE: May 25, 2018

1. Definitions
2. Information collected when you use our services
3. Data Usage
4. Your Data
5. Data Retention
6. Transfer of Data
7. Your Consent
8. How We Use Your Information
9. What Information Do We Collect?
10. How we use your information
11. Who we share it with and why
12. Legal Requirements
13. Business Acquisitions & Mergers
14. Information Protection & Security
15. Other Information Collectors
16. Accessing, Correcting and Updating Your Personal Information
17. Notification of Privacy Statement Changes

DEFINITIONS

Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Usage Data
Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies & Session Storage
Cookies and session storage are small pieces of data stored on a User’s device.

Data Controller
A Data Controller means a person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed.

For the purpose of this Privacy Policy, Kima Surf are a Data Controller of your data.

If you live in the European Union, the company that is responsible for your information under this Privacy Policy (the “data controller”) is:

Kima Surf a business division of PT. Menikmati Distribusi whose registered office is Jl. Munduk Catu, Banjar Canggu , Kuta Utara , Badung, Bali 80361 Indonesia

Data Processor (or Service Providers)
Data Processor (or Service Provider) means any person (other than an employee of the Data Controller) who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject
Data Subject is any living individual who is the subject of Personal Data.

User
The User is the individual using our Service. The User corresponds to the Data Subject, who is the subject of Personal Data.

Information Collection and Use
We collect several different types of information for various purposes to provide and improve our Service to you.

Information collected when you use our services

Personal Data
We will only ask for personal information required to it to operate our service.

We do not share your personal information with any third party except to provide you with services, products, to comply with the law, or to protect our rights.

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address

• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Cookies and Usage Data

We may use your and your customers Personal Data to run anonymous reports on the spending and purchasing habits of various demographics.

Prior to sharing any personal information with Kima Surf, you will be asked for consent to process your personal data for limited and proportionate use in compliance with the General Data Protection Regulation (GDPR) and that you understand that you have the right to withdraw your consent by emailing Kima Surf.

Cookies and other similar data collection technologies
We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Kima Surf Service.

Examples of Cookies we use:

• Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
• Session Cookies. We use Session Cookies to operate our Service.
• Usage Data
• We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser version, browser type, the pages of our Service that you visit, the time and date of your visit, the time spent browsing on those pages, unique device identifiers and other diagnostic data.

Google Analytics
We employ the use of Google Analytics on our website. This service is provided by Google Inc. (“Google”) and uses “cookies”, which are text files stored on your computer in order to help analyse how you use our site. With these cookies, Google Analytics creates this information on your site use as well as your IP address, and transmits it to a Google server in the US, where it is stored. Google evaluates this information and provides reports and other services to the site operators based on your activities on the site. In the case that third parties are legally allowed to also access this material, Google may provide them with this information. Google does not connect your IP address with any additional information they hold.

Google Analytics can be deactivated through changing your browser settings, but be aware that this may prevent you from using all of the available features on our website.
By using www.kimasurf.com, you hereby agree to Google’s processing of your information that it collects for the purposes and in the manner described above. In the case that you do not wish for Google to gather information via your browser on websites such as ours, use the link for the Google Analytics opt-out solution here.

DATA USAGE

Kima Surf uses the collected data for various purposes:

• To provide and maintain our Service
• To allow you to participate in interactive features of our Service when you choose to do so
• To notify you about changes to our Service
• To provide you with customer support
• To gather analysis or valuable information so that we can improve our Service
• To monitor the usage of our Service
• To detect, prevent and address technical issues

You understand that by removing consent to process your personal information, your ability to access Kima Surf services will be restricted and affected.

Your Data
Your credit card information is not stored on our systems. Your personal information is protected and is never made available to any other Kima Surf client or third party. We safeguard all data collected with industry leading security practices.

Data Retention
Kima Surf will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Kima Surf will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to increase the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data
Your information, including Personal Data, may be transferred to and maintained on computers located outside of your province, state , country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located within the EU and choose to provide information to us, please note that we may transfer the data internally within the EU, to North America and/or Australia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Kima Surf will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

Your Consent
By accepting the Privacy Policy in registration or by visiting and using Kima Surf you expressly consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to our Terms of Service. In this Privacy Policy, we use the following terms to describe different types of visitors to Kima Surf.

How We Use Your Information
Providing we have your consent, we will use the data gathered about you for the following general purposes:

Fulfilling orders — We will use the gathered information to process transactions, process or product or service orders made through our website or other distribution channels, fulfil orders and fulfil expectations associated with associated expectations.

Responding to queries — It is possible that we might contact you via email telephone or post in order to address any queries from you. It is also possible that, in order to assist you with making alternative arrangements, we use the contact details you supply us with in order to provide you with follow-up information regarding a booking. In order to assess and respond to the results of surveys, suggestions or contests you have participated in, we might contact you through the above channels to respond in appropriate ways. We may record customer telephone calls for the purposes of our quality assurance and training. We may use some information such as customer e-mails for testimonials, however we will never publicly display your personal information, e-mail address or other contact details.

Enhancing user experience and supplying information on products and services, deals and promotional offers — With the use of data gathered via your permanent cookie file (see above our Cookies Policy) together with personal information you provide, enables us to improve our website through evaluating site use and traffic. In this way we try to provide an experience more customised to your preferences, by assisting site navigation, and providing personalised product displays. By registering an account or placing an order via our website or an affiliated channel, we might use your data in order to contact you with offers, promotions or information including newsletters or other items of interest, provided we have your full consent to send this type of communication. You always have the option of changing your preferences or unsubscribing from these kinds of communications whenever you wish by accessing our preference centre, by contacting us via through our contact information supplied at the bottom of the privacy policy or through the unsubscribe link included in the emails we send to you.

For internal operations and analysis — Your personal information may be used for internal administration, quality assurance an analysis, including guarding our company against fraud. Besides processing, confirming and carrying out requested services, some data may be used for the purposes of analysis and administration; accounting, billing, auditing, systems management, etc. Your personal information may be used to provide you with additional service like email notifications to inform you of promotions, specials, information about the status and details of your travel or opportunities provided by our marketing partners.

What Information Do We Collect?
Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customised experience. This allows us to provide services and features that most likely meet your needs, and to customise our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose.

Once you become a customer, we require you to provide various contact and identity information, billing information, and other personal information as indicated on the relevant forms. Where possible, on these forms we indicate which fields are required and which fields are optional.

Our add-on section provides connections to third party systems. Although it may appear that you are within Kima Surf please be aware that you are also providing data to these third parties systems. You should review privacy and terms of services with any third-party system before using it with Kima Surf.

Payments
We do not store or collect your payment card or bank account details. That information is provided directly to our third-party booking service provider & payment processors whose use of your personal information is governed by their Privacy Policy.

Children’s Privacy
Our Service does not address anyone under the age of 16 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. Any capture of such data will be immediately removed

Who we share it with and why
By using our site and providing us with personal information, you enable us to complete your order (travel reservations, etc.), carry out customer requests, and supply travel-specific or promotional information via email. Your information will not be shared with outside parties unless it is necessary to fulfil your order and travel arrangements. These parties include (in addition to others), credit card companies, travel suppliers, and other global distribution systems.

Information regarding your traveller profile may be provided by the aforementioned service providers (Data Processors) to travel suppliers you have purchased from. We do our best to work only with reputable travel suppliers and enact contractual restrictions on third party partners regarding personal customer data in order to make sure they comply with this Privacy Policy and relevant data protection laws, we make no guarantees that these travel suppliers will not disclose or use your personal information without your expressed permission. We therefore urge you to go over the individual privacy policies and/or practices of any travel suppliers you purchase from via our website. Additionally, said travel suppliers may also need to contact you in order to acquire further information regarding any reservations that have been confirmed.

In order to improve service and gain a better understanding of our customers, we observe how users navigate our site. While we do not give out personal information, we sometimes provide anonymous statistical data to select third party partners for the purposes of marketing, delivery, administration, operations, quality assurance and other related reasons. We will only share personal data, as per this Privacy Policy, with you’re your expressed consent. Any third party that has access to your personal information for the above purposes is limited to use it only for those functions and nothing more.

Legal Requirements
Kima Surf may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Kima Surf
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Business Acquisitions & Mergers
If Kima Surf is involved in an acquisition, merger or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Information Protection & Security
Kimasurf.com is committed to data protection and instilling confidence in customers who use our site. We have applied suitable security procedures in order to protect the personal information we need to conduct business with our customers. Access to personal information is only given to authorised employees and only in cases of performing business-related. We also encrypt your sensitive information for transmission between systems, as well as use firewalls and intrusion detection systems (IDSs) in order to stop those without permission from accessing your data.

Other Information Collectors
Except as otherwise expressly included in this Privacy Policy, this document only addresses the use and disclosure of information we collect. To the extent that you disclose your information to other parties through Kima Surf, different rules may apply to their use, collection and disclosure of the personal information you disclose to them. Since we do not control the information use, collection or disclosure policies of third parties, you are subject to their privacy policies. We encourage you to ask questions before you disclose your personal information to others.

Accessing, Correcting and Updating Your Personal Information
Kima Surf aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you require updates to your Personal Data, please contact us to make the required changes.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us on info@kimasurf.com.

In certain circumstances, you have the right:

• To access and receive a copy of the Personal Data we hold about you
• To rectify any Personal Data held about you that is inaccurate
• To request the deletion of Personal Data held about you

You have the right to data portability for the information you provide to Kima Surf. You can request to obtain a copy of your Personal Data in a commonly used electronic format so that you can manage and move it.

Please note that we may ask you to verify your identity before responding to such requests.

Notification of Privacy Statement Changes
We may update this privacy statement to reflect changes to our information practices. We will do our best to notify you when these terms change through our usual channels. We encourage you to periodically review this page for the latest information on our privacy practices.”