This is a summary of our privacy & personal information policy and contains the most important and relevant
points for you.
1. How we collect information
We may collect certain information during any of the following:
when engaging with third party service providers;
making use of our real-time reporting tools;
making use of any reservation services;
making use of any other goods or services offered by us;
during the booking process;
during any online session from your web browser;
from cookies we may send to your computer and from web beacons on our website to track how you use our
website and to try and give you a personalised experience; and
optional information, that you provide when you upload or download content from our website or when you
enter competitions, take advantage of promotions, respond
to surveys or register and subscribe for certain additional services use.
2. We may use your information:
to send you administrative messages and email updates to you regarding the website;
for marketing purposes;
for targeted content in certain, specified instances directly or via third party service providers; and
for business purposes, which may be deemed beneficial to you.
If you’re using the mobile device we may collect data that identifies settings and locations.
We might disclose your information in the specific circumstances mentioned in this policy.
We endeavour to protect your information. In this regard you have the following choices:
You can turn off cookies in your browser; or
You can opt-out of marketing communications with us by clicking on unsubscribe link in any marketing email
that has been sent you.
Travelstart Privacy & Personal Information Policy
This policy applies to all visitors to our website and customers, potential customers and customers or
potential customers of our affiliates or partners ("you" and "your").
2. Purpose of this policy
This policy disclaims the personal information and privacy issues that affect you and any potential
customers. It describes the way we collect, store, use, and protect information that can be associated with
you, your business or a natural person and can be used to identify any of the above (“personal information”).
3. Personal information:
certain information collected on registration;
additional information accessed through your interactions with us; and
optional information that you voluntarily provide to us.
information that has been made anonymous so that it does not identify a specific person;
permanently de-identified information that does not relate or cannot be traced back to you specifically;
non-personal statistical information collected and compiled by us and information that you have provided
voluntarily in an open, public environment or forum including (without limitation) any blog, social media
account, chat room, community, classifieds or discussion
board. Because the information has been disclosed in a public forum, it is no longer confidential and does
not constitute personal information subject to protection under this policy.
4. Acceptance of terms
You must accept all the terms of this policy when you visit our website or register for any of our services.
If you do not agree with anything in this policy, then you may not register for and use any of the services.
You may not access our website or use our services if you are younger than 18 years old or do not have legal
capacity to conclude legally binding contracts. By accepting this policy, you are deemed to have read,
understood, accepted, and agreed to be bound by all its terms.
We may change the terms of this policy at any time. We will notify you of any changes by placing a notice in
a prominent place on the website or by email. If you do not agree with the change you must stop using the
services. If you continue to use the services following notification of a change to the terms, the changed
terms will apply to you and you will be deemed to have accepted such terms.
6.1 On registration
Once you register on our website, you will no longer be anonymous to us as you will provide us with personal
This personal information will include:
your name, surname, company name, company registration number, and VAT number;
your postal address, email address, telephone number, and postal code;
your user ID and password;
your social media details or related user accounts;
FICA details; and
Payment details, bank account(s) and credit card number(s).
6.2 Collection on use
In order to provide the services to you, you will be asked to provide us with additional information on a
voluntary basis such as:
profile management details;
flight, hotel, card reservations;
real-time reporting details;
personal account details;
details relating to skills and knowledge transfer from us to you; and
expense management details.
6.3 Optional details
You may also provide additional information on a voluntary basis such as value added services or third party
services provided by our partners or affiliates or any further information you provide to us (“optional
information”). This includes content or products that you decide to upload or download from our website or
when you enter competitions, take advantage of promotions, respond to surveys, register and subscribe for
certain additional services, or otherwise use the optional features and functionality of the website.
6.4 Collection from browser
We automatically receive and record Internet usage information on our server logs from your browser, such as
your Internet Protocol address (“IP address”), browsing habits, click patterns, version of software installed,
system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search
and times that you visit the website, paths taken, and time spent on sites and pages within the website
(“usage information”). Please note that other websites visited before entering our website might place
personal information within your URL during a visit to it, and we have no control over such websites.
Accordingly, a subsequent website that collects URL information may log some personal information.
When you access our website we may send one or more Cookies (small text files containing a string of
alphanumeric characters) to your computer to collect certain usage information.
We use session Cookies (which disappear after you close your browser) and persistent Cookies (which remain
after you close your browser and which can be removed manually) which may be used by your browser on
subsequent visits to our website.
We use information gathered by Cookies to improve the website. Please note that some of our business partners
(e.g. advertisers) use their own Cookies or widgets on our website. We have no access to or control over them.
created it, and not by us.
Cookies cannot contain malicious code such as viruses. All information is anonymous and we do not use the
collected information to create visitor profiles.
Refusing a Cookie may, in some cases, preclude you from using, or negatively impact, the display or
function of our websites or certain areas or features of our websites.
Travelstart uses Google Analytics and Cookies to target our advertising on third party sites. For example, it
may be ads on Facebook, LinkedIn, Google AdWords or other websites.
Google Analytics is a web analysis service that analyses how users interact with the site. On behalf of
Travelstart and based on your consent, Google will use this information to assess your use of the website, to
compile reports on website activity and to provide the website operator with other services related to website
and internet use.
We use the IP anonymization tool offered by Google Analytics in order to ensure anonymous collection
of IP addresses (so-called IP masking).
The IP address transmitted by your browser in the context of Google Analytics is not merged with other
In addition, the User can manage preferences for Cookies directly from within their own browser and prevent –
for example – third parties from installing Cookies.
Through browser preferences, it is also possible to delete Cookies installed in the past, including the
Cookies that may have saved the initial consent for the installation of Cookies by this website.
If you use different devices to access our website, you will need to ensure that each browser of each device
is set to your Cookie preference.
To find information about how to manage Cookies in the most commonly used
browsers, visit the following addresses below:
If you are in need of further assistance, please email [email protected] and an agent will
contact you within 24 hours.
6.6 Tracking Tools
Travelstart and Flapp use third party tracking tools, such as WebEngage, in order to improve your customer experience.
6.7 Web beacons
Our website may contain electronic image requests (called a “single-pixel gif” or “web beacon” request) that
allow us to count page views and to access cookies. Any electronic image viewed as part of a web page
(including an ad banner) can act as a web beacon. Our web beacons do not collect, gather, monitor or share any
of your personal information. We merely use them to compile anonymous information about our website.
6.8 Recording calls
We will monitor and record telephone calls that you make to our call centre which is mandatory in order for
us to provide services to you.
6.9 Purpose for collection
We may use any service information and optional information provided by you for such purposes as indicated to
you at the time you agree to provide such service information or optional information. We may use your usage
information for the purposes described above and to:
remember your information so that you will not have to re-enter it during your visit or the next time you
access the website;
monitor website usage metrics such as total number of visitors and pages accessed;
provide any services, which may be useful or beneficial to you; and
track your entries, submissions, and status in any promotions or other activities in connection with your
usage of the website.
7.1 Messages and updates
We may send administrative messages and email updates to you regarding the website. In some cases, we may
also send you primarily promotional messages. You can choose to opt-out of promotional messages.
7.2 Targeted content
While you are logged into the website, we may display targeted adverts and other relevant information based
on personal information. In a completely automated process, computers process personal information and match
it to adverts or related information. If you click on an advert, we may send a referring URL to the
advertiser’s website identifying that a customer is visiting from the website. If you click on a third party
or affiliate or advertiser’s website however, the advertiser is able to collect your personal information.
8.1 Sharing your information
We may share your personal information with:
Other divisions or companies within the group of companies to which we belong, or third-party advertisers,
affiliates or service provides so as to provide joint content or services like registration or for
transactions and customer support, to help detect and prevent potentially illegal acts and violations of our
policies, and to guide decisions about their products, services and communications.
An affiliate, in which case we will seek to require the affiliates to honour this privacy and personal
Our service providers under contract who help with parts of our business operations (including fraud
prevention, bill collection, marketing, technology services). Our contracts dictate that these service
providers only use your information in connection with the services they perform for us and not for their
Credit bureaus to report account information, as permitted by law; and
Banking partners as required by credit card association rules for inclusion on their list of terminated
merchants (in the event that you utilise the services to receive payments and you meet their criteria).
8.2 In the process of various activities recorded in this policy we may
receive a fee or compensation from third parties and you expressly consent and approve our engagement in
If you contact us regarding your experience with using any of our products, we may disclose your personal
information as required by law or governmental audit.
8.4 Law enforcement.
We may disclose personal information if required:
by a subpoena or court order;
to comply with any law;
to protect the safety of any individual or the general public; and
to prevent violation of our service terms.
8.5 Marketing purposes
We may disclose aggregate statistics (information about the customer population in general terms) about the
personal information to advertisers or business partners.
We may need to disclose personal information to our employees that require the personal information to do
8.7 Change of ownership
If we undergo a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity,
we may assign our rights to the personal information we process to a successor, purchaser, or separate entity.
We will disclose the transfer on the website. If you are concerned about your personal information migrating
to a new owner, you may request us to delete your personal information.
9. Security of personal information
Generally we use computer safeguards such as firewalls and data encryption to protect personal information
and we enforce physical access controls to our buildings and files. We authorize access to personal
information only for those employees who require it to fulfil their job responsibilities. Our hosting company
will host our website in a secure server environment that uses a firewall and other advanced security measures
to prevent interference or access from outside intruders. We authorize access to personal information only for
those employees who require it to fulfil their job responsibilities.
10. Accurate and up to date
We will try to keep the personal information we collect as accurate, complete and up to date as is necessary
for the purposes explicitly defined in this policy. From time to time we will request you to update your
personal information on the website. You are able to review or update any personal information that we hold on
you by accessing your account online, by emailing us, or by phoning us. Please note that in order to better
protect you and safeguard your personal information, we take steps to verify your identity before granting you
access to your account or making any corrections to your personal information.
11. Retention of personal information
We will only retain your personal information for as long as we determine is necessary to fulfil the purposes
explicitly set out in this policy, unless:
retention of the record is required or authorised by law; or
you have consented to the retention of the record.
During the period of retention, we will continue to abide by our obligations. Unless explicitly directed
otherwise, your access of our website or use of our services is deemed consent to retain records of the
information outlined in this privacy and personal information policy.
12. Transfer of personal information outside Kenya
We may transmit or transfer personal information outside Kenya to a foreign country. Personal information may
be stored on servers located outside Kenya in a foreign country whose laws protecting personal information may
not be as stringent as the laws in Kenya. You consent to us processing your personal information in a foreign
country whose laws regarding processing of personal information may be less stringent.
13. Updating or removing
You may choose to correct or update the personal information you have submitted to us by logging into your
We are not responsible for, give no warranties, nor make any representations in respect of the privacy
policies or practices of linked or any third party websites.
If you have any questions or concerns arising from this privacy & personal information policy or the way in
which we handle personal information, please contact us at: [email protected]