Introduction

 

Welcome to our Privacy Policy. The terms “we”, “us”, “our”, and “World of Difference” refer to World of Difference Inc., a stock corporation, its corporate affiliates, or any related entities. 

This privacy policy is referenced in our Website Terms of Use available on this site. We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you. You must accept the Website Terms of Use as well as this Privacy Policy in order to use the site and Service. Please note that the Website Terms of Use and this Privacy Policy are subject to change. Any changes to the Privacy Policy will be made available on this webpage. Your continued use of our website and services after the posting of the revised Privacy Policy means that you accept and agree to the changes. It is your responsibility to check this policy and make yourself aware of any changes.

 

Important information and who we are

 

Purpose of this privacy policy

This Privacy Policy aims to give you information on how World of Difference collects and processes your personal data through your use of this website and our services, including any data you may provide through this website when you download content, sign up to our newsletter or apply to join a program. 

This website is not intended for children and we do not knowingly collect data relating to children. If you are below the age of 18 then you must have your parent’s or legal guardian’s consent to submit any personal data at all. We will promptly delete any personal information relating to minors where we are informed that parental or guardian consent has not been granted. Should you be a concerned parent or guardian of a minor who has submitted their personal data without your consent please write to our Data Protection Officer for assistance.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them.

Controller  

World of Difference has corporate affiliates and related entities. This Privacy Policy is issued on behalf of the World of Difference family of companies so when we mention “World of Difference”, “we”, “us” or “our” in this Privacy Policy, we are referring to the relevant company in the World of Difference family of companies responsible for processing your data. The company controlling your data when you enquire about or purchase a World of Difference travel program will be World of Difference Inc., a registered stock corporation with offices and operations in the United States of America,  South Africa and in all locations where our travel programs are available. 

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights , please contact the DPO using the details set out below.

Contact Details

Our full details are: 

Full name of legal entity: World of Difference Inc. 

Name or title of DPO: Jess Smith

Email address: [email protected]

Postal address: 25 Franklin street, Boston, Massachusetts, 02110, United States

Telephone number: +1 888-653-6028

 

If you are a resident or citizen of the United Kingdom or European Union, you have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.

 

Your duty to inform us of changes

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

 

Third-party links and services

This website and our service may include links to third-party websites, plug-ins and services. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. Such services may include applications like Zoom or Canvas, as required to deliver services to you. Please note that your personal data as entered into any such service may be visible to other people using the same service and or other people enrolled for the same or a similar program to you. When you leave our website or use any of these third-party resources and services, we encourage you to read their Privacy Policies.

 

The data we collect about you  

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the person’s identity has been removed (anonymous data). 

We may collect, use, store and transfer (“process”) different kinds of personal data about you. Some of the data may constitute Personal Information only when combined with personal identifiers. We have grouped the data that we may process for your reference as follows:

• Identity Data, which may include first name, maiden name, last name, username or similar identifier, title, date of birth and gender.
• Contact Data, which may include email address and telephone numbers.
• Transaction Data, which may include details about payments to and from you and other details of products and services you have purchased from us.
• Technical Data, which may include internet protocol (IP) addresses, your login data, browser type and version, timezone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites and services.
• Usage Data, which may include information about how you use our websites, products and services.
• Marketing and Communications Data, which may include your preferences in receiving marketing from us and our third parties and your communication preferences.
• Special categories of personal Data, which may include health data relevant to your program, criminal history data that is relevant to your World of Difference program.

 

If You Fail To Provide Personal Data  

The supply of personal data to us is voluntary and not mandatory. However, where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to conclude or perform a contract with you. In this case, we may be unable to complete your booking or to provide other services to you. We will notify you if this is the case at the relevant time.

 

How Is Your Personal Data Collected?  

We have listed below some of the different methods used to collect data from and about you. However, we will always collect personal data about you directly from you, as far as possible:  

• Direct interactions. You may give us your identity and contact details by filling in forms or by corresponding with us by post, phone, email, in person or otherwise. This includes personal information you provide when you: apply for our Programs or register on the site for our services; request marketing to be sent to you; respond to a survey or enter into our promotions and competitions; engage with us via social media; and/or use the Message Board features of the services and include personal information directly or indirectly (eg. via a display name).
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy below for further details.
• Third parties or publicly available sources. We may receive Technical Data about you from various third parties and public sources as set out below :
  • analytics providers such as Google Analytics
  • advertising networks such as Google Adwords, Facebook and Bing

 

How We Use Your Personal Data  

We will only use your personal data when the law allows us to and for a specific, explicitly defined lawful purpose relating to our services. Most commonly, we will use your personal data in the following circumstances: 

• Where we need to perform in terms of the contract we are about to enter into or have entered into with you. This might include using your contact data (email address and telephone numbers) to communicate with you via email, telephone call, text message and/or WhatsApp.
• Where it is necessary for our legitimate interests (or those of a third party), provided that your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.
• For direct marketing purposes (only if you have opted in to receiving direct marketing material). You have the right to withdraw consent to marketing at any time by contacting us. 

 

We will only collect and process personal data about you where we have one or more lawful bases to do so. Lawful bases include consent (where you have given express consent), contract (where processing is necessary for the performance of a contract with you (e.g. to process your application or complete your booking)), and to protect your or our own legitimate interests (unless you have objected in writing to the processing activities on reasonable grounds). 

If we intend to process your personal data for any other purposes not mentioned above, or which is otherwise not automatically permitted by law, we will ensure that we obtain your consent to do so.

 

Marketing  

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional Offers From Us  

You will receive marketing communications from us if you have opted to do so while requesting other information from us or when making a booking.

 

Third-party Marketing  

We will get your express opt-in consent before we share your personal data with any company outside the World of Difference family of companies for marketing purposes.

 

Opting Out  

You can ask us or third parties to stop sending you marketing messages at any time by using the unsubscribe link included in the footer of all marketing messages. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of booking or enrolling in a program. 

 

Cookies  

A cookie is a small file with information that your browser stores on your device. The types of information a cookie collects includes the date and time of visits to a website, browsing history and user preferences.

Our website will not use cookies (besides first party cookies that are necessary for the website to function) without your prior and explicit consent. 

World of Difference uses Google’s Advanced Consent Mode. This means that by default, cookie consent is denied and only anonymised data is sent by Google tags. Personalised data is only collected from users of our website, when they grant consent. You can provide consent for specific purposes, such as analytics, advertising, and third-party cookies, giving you more control over your data privacy preferences. Therefore, you can decide if you will allow all or some cookies to collect your personal data for different purposes.

If you consent to the use of cookies, then:

• anonymised data will be shared with our marketing and analytics partners. 
• we may use your anonymised data on our marketing platforms to send you marketing messages (provided that you have expressly agreed to receive newsletters and/or marketing communications).
• you may change or withdraw your consent at any time.  

 

Further information on how cookies will be used is included in our Cookie Policy below. 

If you disable or refuse cookies, then:

• no data will be sent to our marketing partners, but Google Analytics will still collect information on your consent status and certain non-identifying data. This information allows Google to adjust their behaviour and respect your choices. 
• you may not be able to take full advantage of our Websites. 

 

Please note that the provisions of this clause and the cookie policy below are only applicable to cookies used by us. In some instances, third-party service providers may use cookies on the website. We cannot and do not control or access cookies used by third party service providers and take no responsibility in this regard.

 

Change Of Purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

Disclosures Of Your Personal Data

We may have to share your personal data with the parties set out below for the purposes of providing services to you or performing our contract with you. 

• Suppliers: such as insurance providers,service providers and other entities we work with in order to fulfill our contract with you. 
• Third-party vendors: who provide services or functions on our behalf, such as credit card processing, business analytics, support and fraud prevention. Such vendors are not permitted to share or use the information for any other purpose other than performing the specific functions they provide.
• World of Difference-controlled entities and third party partners: that provide on-the-ground support at our various global program bases.
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

 

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

World of Difference may contact you via email to invite you to review your World of Difference experience in order to receive your feedback and improve our programs (the “Purpose”). We use an external company, Trustpilot A/S (“Trustpilot”), to collect your feedback which means that we will share your name, email address and reference number with Trustpilot for the Purpose. World of Difference may also use such reviews in other promotional material and media for our advertising and promotional purposes. If you want to read more about how Trustpilot processes your data, you can find their Privacy Policy here. 

 

International Transfers  

As an international travel company and tour operator, World of Difference has operations in various locations across the world including all the places where our programs are based. As part of the process of processing your application for a program and performing our contract with you, your personal data will be transferred outside the United States of America (USA). This could include places whose laws may provide for a lesser standard of protection for your personal data than that provided under US Law. 

Examples of situations where we are required to transfer your data may include, but are not limited to:

• Transfers to suppliers and partners when World of Difference assists with flights, insurance, visa applications and/or renewals;
• Transfers to partners where certain licenses, permissions and/or authorisations are required in order to participate in our programs and/or enter certain controlled areas (such as national parks, partner schools and dive locations); 

 

Suppliers and partners are required to adhere to the same standards as World of Difference when dealing with personal data. 

In all cases of transfers, we will implement appropriate safeguards to ensure your privacy rights are protected, such as using standard contractual clauses approved by the European Commission or obtaining your consent to the transfer.

 

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

Data Retention

 

How long will you use my personal data for? 

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances you can ask us to delete your data. 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

Your legal rights  

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. 

You have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms. 
• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

 

If you wish to exercise any of the rights set out above, please contact us using our above contact details. 

No fee usually required 

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you  

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond  

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

Notice For California Residents

 

Categories of Personal Information that We Collect

Below are the categories of personal information about California consumers that we collect and disclose for a business purpose. We do not sell personal information.  

We collect and disclose for a business purpose the following categories of personal information:

• Contact Information and Identifiers, including real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, phone number, account name, or other similar identifiers.
• Customer Records, including paper and electronic customer records containing personal information, such as name, signature, address, telephone number, education, employment, employment history, financial information relevant to your payments, or medical information relevant to your participation in our programs.
• Usage Data, including internet or other electronic network activity information, such as browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
• Education Information, including information about education history or background.
• Protected Classifications, including characteristics of protected classifications under California or federal law such as race, color, sex, age, religion, national origin, disability, and citizenship status may also be collected.

 

Categories of Sources of Personal Information 

The categories of sources of personal information we collect are described in the section How Is Your Personal Information Collected above.

Purposes for Collecting Personal Information

We collect the personal information identified above to communicate with you, for advertising and marketing purposes, to provide and improve our services, and other purposes set forth in How We Use Your Personal Information above.

Categories of Third Parties with Which Personal Information is Shared

We share personal information identified above with the following categories of third parties:

• Our educational partners,
• Third-party providers that serve business, professional or technical support functions,
• Potential employers (as directed by you), or
• Third parties for legal matters or safety purposes.

California Consumer Rights

California law gives California consumers the right to make the following requests:

• The right to opt-out of the sale of your personal information.  We do not sell personal information.
• The right to request a copy of the personal information that we have collected about you in the prior 12 months.  
• The right to request deletion of the personal information that we have collected from you, subject to certain exemptions (for example, where the information is used by us to detect security incidents, debugging or to comply with a legal obligation).
• The right to request more details about the personal information we collect and how and why we use and share it, including the categories of personal information we have collected about you, the categories of sources for personal information we collect, the business or commercial purposes for collecting personal information, and the categories of third parties with which we share personal information.

 

You can submit a copy, deletion, or right-to-know request online by emailing [email protected] or by contacting us at +1 888-653-6028.

The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data. 

Please note that third parties may, however, collect personal information about your online activities over time and across different websites when you visit our Site or use the Service.

 

Glossary

 

Lawful Basis  

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

Cookie Policy

 

Information about our use of cookies

As mentioned above, where you provide us with your consent (except in the case of strictly necessary first-party cookies which may be processed without your prior consent for the normal operation of our websites and services), our websites and services (hereafter ‘Site), may use cookies to distinguish you from other users. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

Where authorised, we may collect information about your computer including, where available, your IP address, operating system and browser type for system administration as part of our audit trail process.

If you provide us with your consent, we may use the following cookies: 

• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily. 
• Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
• Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

 

Cookie	Description
Analytics cookies	We use Google Analytics, which sets a first-party cookie in order to anonymously identify when users return to specific websites.   Google uses the information sent with this cookie to store a history of website pages visited in a user’s session. This data will not be used to associate any part of your identity, anonymous or not, with any other data held by Google. Further information about this cookie can be found at https://www.google.com/intl/en/policies/privacy/partners/
Advertisement cookies	From time to time, advertisers may include digital assets which set cookies on an advertiser’s domain or on the domain of our Website. These cookies will only store anonymous information about your interaction with a specific advert and will not be used to personally identify you. We may also share anonymised behavioural data with advertising partners, to improve the quality and relevance of our advertising. This means that when you are on other websites, you might be shown advertising based on your behaviour on our Website. We may also show you advertising on our site based on your behaviour on other sites. You may find out more information by visiting http://www.youronlinechoices.com/uk/your-ad-choices
Google Advertising cookies	We use Google Double Click to serve advertisements. Advertisements are received from Google Double Click servers to your browser along with a cookie to anonymously identify you as you visit websites which serve advertising from Google Double Click servers. In addition to providing website usage data as described above, Google Analytics may also collect anonymous demographic data such as age, gender and interests by placing a Google DoubleClick cookie in your browser. This data is aggregated and anonymised and helps us understand the types of users who visit our site. This cookie may also help us serve advertising tailored to your interests and preferences when you visit our sites or other sites that we advertise on. More information about this cookie at http://www.google.com/settings/ads/onweb/ If you do not consent to the use of this cookie, you will still see advertising when you visit our sites, but the content of the ads may not be as relevant to you.
Facebook Pixel	We use Facebook technologies such as the Facebook Pixel to show you interest-based marketing content from our brands and selected advertisers if you have viewed a World of Difference website. Data collected by the Facebook Pixel may also be anonymised and used in aggregate to help improve the quality and effectiveness of our websites and marketing efforts. You can find out more about Facebook Advertising at https://www.facebook.com/ads/about/
Facebook Like Button cookies	When you create or log in to an account on http://www.facebook.com cookies are stored on your computer in order to remain logged-in to your facebook account when visiting http://www.facebook.com again. The Facebook Like Button used on our Website is hosted by Facebook and your browser therefore sends this cookie data to Facebook when creating the button inside your browser. This data is used by Facebook in order to associate the Facebook Like Button with your Facebook account. This information is not accessible to us, and is not sent to us by Facebook. More information about this cookie and Facebook’s Privacy Policy can be found at https://www.facebook.com/about/privacy/your-info-on-other#socialplugin

 

Our website may include sharing buttons for social media platforms, such as Facebook, WhatsApp and LinkedIn. These buttons allow you to share content from our website on these platforms. If you use these sharing buttons, your personal data may be collected by the relevant social media platform and used in accordance with their privacy policy. We do not control the collection, use or storage of personal data by these platforms, and you should review their privacy policy before using the sharing buttons.

We may also collect information about your use of these sharing buttons, such as the number of times you share content from our website, and use this information for internal purposes, such as to improve our services. This information will be used in accordance with this privacy policy, where we are authorised to do so.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) the site may not perform as expected.