1. Introduction
AZAO Resort & Spa (“AZAO”, “we”, “us”, or “our”) respects the privacy of our guests, visitors, employees, applicants, business partners and other individuals whose personal information we receive.
We are committed to handling personal information responsibly and taking reasonable steps to protect it against unauthorized access, misuse, loss, alteration or disclosure.
This Privacy Policy explains how we may collect, use, store, disclose, retain and protect personal information when you:
- Visit or stay at AZAO Resort & Spa;
- Make or manage a reservation;
- Use our accommodation, restaurant, spa, wellness or other services;
- Visit or use our website;
- Communicate with us by telephone, email, messaging services or social media;
- Submit an enquiry, complaint or service request;
- Participate in an event, promotion or loyalty programme;
- Apply for employment; or
- Otherwise interact with us.
We seek to handle personal information in a manner consistent with applicable privacy, data-protection and other legal requirements applicable to our operations.
Because we operate in Zanzibar, the application of particular Tanzanian data-protection requirements may depend on the nature of the relevant activity and whether the matter falls within Union or non-Union responsibilities. We will seek to comply with the legal requirements applicable to the relevant processing activity.
This Privacy Policy should be read together with any specific notice, consent form, booking terms, spa or wellness form, cookie notice or other information provided to you when we collect your personal information.
2. Who Is Responsible for Your Personal Information?
We are responsible for the personal information that we collect and process in connection with our operations.
Legal Entity: Azao resort & spa, Co. Ltd.
Trading Name: Azao Resort & Spa
Business Address: Pongwe, Zanzibar, Tanzania
For privacy-related questions, requests or concerns, you may contact us using:
Email: reservations@azaoresortzanzibar.com
Telephone: +255 779 567822.
3. Our Commitment to Privacy
We are committed to:
- Collecting personal information responsibly;
- Collecting information that is reasonably necessary for legitimate purposes;
- Using information for appropriate and identified purposes;
- Limiting access to personal information to authorized persons;
- Taking reasonable security measures;
- Retaining information only for as long as reasonably necessary;
- Responding appropriately to privacy concerns and requests; and
- Continually reviewing and improving our privacy and information-management practices.
This Policy describes our current approach to handling personal information and may be updated as our operations, technology and applicable legal requirements develop.
4. What Personal Information Do We Collect?
The information we collect depends on your relationship with us and the services you use.
We may collect the following categories of information.
4.1 Identification and Contact Information
This may include:
- Full name;
- Title;
- Telephone number;
- Email address;
- Postal or residential address;
- Nationality;
- Date of birth;
- Identification or passport information;
- Other information necessary for guest registration or legal requirements.
4.2 Reservation and Accommodation Information
When you make or use a reservation, we may collect:
- Reservation details;
- Arrival and departure dates;
- Room or accommodation preferences;
- Names of accompanying guests;
- Special requests;
- Dietary requirements;
- Accessibility requirements;
- Celebration or occasion information;
- Preferences relevant to providing requested services;
- Information relating to cancellations, changes or complaints.
4.3 Payment and Billing Information
We may process information necessary to:
- Process payments;
- Process deposits;
- Issue invoices;
- Process refunds;
- Maintain accounting records;
- Verify transactions;
- Prevent fraudulent or unauthorized activity.
Where payment is made through a third-party payment provider, that provider may process payment information under its own privacy policy and applicable requirements.
We will seek to avoid retaining full payment-card information where it is not reasonably necessary for our legitimate business or legal purposes.
4.4 Spa and Wellness Information
Where you request spa, wellness or treatment services, we may ask you to provide limited information that is reasonably necessary to provide those services safely.
Depending on the service, this may include:
- Allergies;
- Skin sensitivities;
- Treatment contraindications;
- Relevant medical information voluntarily provided by you;
- Previous treatment information;
- Other information relevant to the safe provision of a requested treatment.
We will seek to limit health-related information to what is reasonably necessary for the particular service.
If you do not provide information that is necessary to determine whether a treatment can safely be provided, we may be unable to provide that treatment.
4.5 Communications and Enquiries
When you contact us, we may collect and retain:
- Your name;
- Contact information;
- Correspondence;
- Enquiries;
- Complaints;
- Feedback;
- Requests;
- Information necessary to investigate and respond to your communication.
4.6 Website and Technical Information
When you use our website, we may collect certain technical and usage information, including:
- IP address
- Approximate location derived from technical information
- Browser type
- Operating system
- Device type
- Referring website
- Pages visited
- Date and time of visits
- Interactions with our website
- Cookies and similar technologies
- Information submitted through online forms
The actual information collected will depend on the technology and services operating on our website.
4.7 Employment Information
If you apply for employment with us, we may collect information reasonably necessary for recruitment and employment-related purposes, including
- Name and contact details
- CV
- Employment history
- Education and qualifications
- References
- Identification information
- Information required by applicable law.
5. Information About Other Guests
If you provide us with personal information concerning another person, such as a family member, travel companion or accompanying guest, you should ensure that you have the necessary authority or permission to provide that information.
Where appropriate, you should inform that individual that their information has been provided to us and make this Privacy Policy available to them. We may nevertheless process such information where it is required or permitted by applicable law.
6. How Do We Collect Personal Information?
We may collect personal information:
- Directly from you
- When you make a reservation
- During check-in or registration
- When you use our facilities or services
- Through our website
- By telephone
- By email
- Through messaging services
- Through travel agents
- Through booking and reservation platforms
- Through business partners
- Through payment providers
- Through social-media platforms
- From accompanying guests or authorized representatives
- From publicly available sources where lawful; or
- From government or regulatory authorities, where permitted or required.
7. Why Do We Use Personal Information?
We may use personal information for the following purposes.
7.1 Reservations and Guest Services
We may use information to:
- Process and manage reservations
- confirm bookings
- Manage check-in and check-out
- Provide accommodation
- Provide restaurant, spa, wellness and other requested services
- Manage cancellations and changes
- Communicate booking information
- Respond to guest requests
- Personalize services based on information voluntarily provided by guests
7.2 Spa and Wellness Services
We may use relevant information to:
- Schedule appointments
- Provide requested treatments
- Assess treatment suitability;
- Identify relevant contraindications
- Maintain treatment records where reasonably necessary
- Respond to treatment-related concerns or complaints.
7.3 Payments and Administration
We may use information to:
- Process payments
- Process refunds;
- Issue invoices;
- Maintain financial and accounting records;
- Verify transactions;
- Prevent fraud;
- Manage suppliers and service providers;
- Administer our business operations.
7.4 Safety and Security
We may use information to:
- Protect guests, employees and visitors;
- Protect our property;
- Prevent and investigate incidents;
- Operate security systems;
- Investigate suspected unlawful activity;
- Maintain physical and information security.
7.5 Legal and Regulatory Requirements
We may use or disclose personal information where reasonably necessary to:
- Comply with applicable law;
- Pomply with regulatory requirements;
- Respond to lawful requests from government authorities;
- Comply with court orders or legal processes;
- Establish, exercise or defend legal claims;
- Protect the rights, property or safety of our, our guests, employees or other persons.
7.6 Marketing and Communications
Where permitted by applicable law, we may use contact information to send:
- Resort news;
- Special offers;
- Promotional packages;
- Spa and wellness information;
- Event information;
- Loyalty-programme communications.
Where consent is required by law, we will obtain consent through an appropriate mechanism. You may opt out of marketing communications at any time.
Opting out of marketing will not normally prevent us from sending essential service-related communications, such as booking confirmations, payment information, safety notices or other communications necessary to provide services you have requested.
8. Legal Basis For Processing
Depending on the circumstances and applicable law, we may process personal information where:
- It is necessary to provide a service or perform an agreement with you;
- It is necessary to comply with a legal or regulatory obligation;
- You have provided consent where consent is required;
- It is necessary for a legitimate and lawful business purpose, subject to applicable legal requirements;
- It is necessary to protect the safety or vital interests of an individual;
- It is necessary to establish, exercise or defend legal claims; or
- Another lawful basis or condition permitted by applicable law applies.
Where processing is based on consent, you may withdraw consent, subject to applicable legal limitations and the consequences of withdrawal.
we will not rely on consent where another lawful basis is more appropriate.
9. Sensitive And Health-related Information
Certain categories of personal information may require enhanced protection under applicable law.
We may collect sensitive or health-related information where it is reasonably necessary for a legitimate service or purpose and, where permitted by applicable law.
In particular, spa and wellness services may require information regarding:
- Allergies;
- Skin conditions or sensitivities;
- Medical conditions relevant to a treatment;
- Treatment contraindications; or
- Other health information voluntarily provided by the guest.
Access to such information will be limited to authorized persons who reasonably need it for the relevant service or purpose.
We will seek to apply appropriate safeguards to sensitive information.
10. Photographs And Video
We may take photographs or record video at the resort for purposes including:
- Security;
- Operational purposes;
- Events;
- Documentation of resort activities;
- Promotional or marketing purposes.
Where identifiable photographs or videos of guests are used for promotional purposes and applicable law requires consent, we will seek the appropriate consent.
Guests may contact us regarding concerns about the use of their identifiable image. This does not prevent us from using photographs or video where their use is otherwise permitted by law or reasonably necessary for security, safety, operational or legal purposes.
11. Cctv And Security Surveillance
We may use CCTV or other security-surveillance systems in appropriate areas of the resort for purposes including:
- Protecting guests and employees;
- Protecting property;
- Preventing crime;
- Investigating incidents;
- Maintaining security;
- Complying with legal obligations.
CCTV will not intentionally be operated in locations where guests would reasonably expect a high degree of privacy, such as bedrooms, bathrooms or changing areas.
Access to CCTV footage will be restricted to authorized persons. CCTV footage may be disclosed where reasonably necessary for:
- Investigation of an incident;
- Protection of guests or employees;
- Insurance purposes;
- Iegal proceedings;
- Law-enforcement purposes; or
- Compliance with a lawful request.
CCTV footage will generally be retained only for as long as reasonably necessary for its security purpose, subject to longer retention where necessary because of an incident, investigation, legal claim or legal requirement.
12. Cookies And Website Technologies
Our website may use cookies and similar technologies. These technologies may be used to:
- Enable essential website functions;
- Maintain website security;
- Remember preferences;
- Support online booking functionality;
- Understand website usage;
- Monitor website performance;
- Improve our website;
- Support marketing activities where permitted.
The specific cookies and technologies used may change as our website develops. Where applicable law requires consent for non-essential cookies or tracking technologies, we will provide an appropriate mechanism for managing such consent.
You may also manage cookies through your browser settings. Disabling certain cookies may affect website functionality.
13. Marketing
We may send marketing communications, where permitted by applicable law. Marketing communications may include:
- Special offers;
- Promotional packages;
- Newsletters;
- Resort news;
- Spa and wellness promotions;
- Events;
- Loyalty programmes.
You may stop receiving marketing communications by:
- Using the unsubscribe function included in a marketing communication; or
- Contacting AZAO using the details provided in this Policy.
Stopping marketing communications does not prevent us from sending necessary service-related communications.
14. Who May Receive Personal Information?
We may share personal information with third parties where reasonably necessary for a lawful purpose.
These parties may include:
14.1 Service Providers
- Booking and reservation platforms;
- Payment processors;
- Banks and financial institutions;
- Website hosting providers;
- IT and technology providers;
- Email and communication providers;
- Security providers;
- Maintenance providers;
- Professional advisers;
- Auditors;
- Legal advisers;
- Insurance providers;
- Other contractors providing services to AZAO.
14.2 Government And Regulatory Authorities
We may disclose personal information to government authorities, law-enforcement authorities, courts, regulators, tax authorities or other authorities where disclosure is required or permitted by law.
14.3 Business Transactions
If AZAO or its business is involved in a merger, acquisition, restructuring, financing, sale of assets or similar transaction, personal information may be transferred as part of that transaction where legally permitted. We do not sell personal information as a commercial commodity.
15. Third-party Service Providers
Where third parties process personal information on behalf of AZAO, we seek to ensure that they are required, as appropriate, to:
- Process information only for authorized purposes;
- Maintain confidentiality;
- Apply appropriate security measures;
- Comply with applicable legal requirements;
- Notify AZAO of relevant security incidents;
- Assist AZAO where reasonably necessary to respond to privacy requests;
- Return or delete information when no longer required, where appropriate.
Where appropriate, we may enter into written agreements with service providers dealing with personal information.
16. International Data Transfers
Some service providers, booking platforms, technology providers, payment providers or other business partners may operate outside Tanzania.
Where personal information is transferred outside Tanzania, we will seek to take the steps required by applicable law to ensure that the transfer is lawful and that appropriate safeguards are applied.
Depending on the circumstances, these safeguards may include:
- Assessing the recipient and destination;
- Limiting the information transferred to what is reasonably necessary;
- contractual safeguards;
- Technical and organizational security measures;
- Obtaining any required authorization or permit;
- Other safeguards required by applicable law.
We will not intentionally transfer personal information internationally for the purpose of avoiding applicable privacy or data-protection requirement
17. Data Security
We take reasonable administrative, technical and physical measures to protect personal information against:
- Unauthorized access;
- Unauthorized disclosure;
- Loss;
- Destruction;
- Misuse;
- Alteration; and
- Unauthorized processing.
These measures may include:
- Access controls;
- Confidentiality obligations;
- Secure systems;
- Staff awareness;
- Physical security;
- Procedures for handling information;
- Appropriate backup and recovery measures;
- Incident-response procedures.
Access to personal information is intended to be limited to persons who require it for an authorized business, service, security or legal purpose. However, no method of electronic transmission or storage can be guaranteed to be completely secure. Accordingly, we cannot guarantee the absolute security of information transmitted over the internet.
18. Data Security Incidents And Breaches
We will take reasonable steps to identify, investigate and respond to suspected personal-data security incidents. Where an incident occurs, AZAO may:
- Identify and contain the incident;
- Assess the information involved;
- Assess potential risks to affected individuals;
- Investigate the circumstances;
- Take measures to reduce potential harm;
- Document the incident;
- Notify relevant authorities where required; and
- Notify affected individuals where required.
The timing and nature of any notification will depend on the circumstances of the incident and applicable legal requirements.
19. Data Retention
We do not intend to retain personal information indefinitely. We retain personal information only for as long as reasonably necessary for purposes including:
- Providing services;
- Maintaining business records;
- Accounting and financial requirements;
- Complying with legal obligations;
- Resolving complaints and disputes;
- Preventing fraud;
- Maintaining security;
- Establishing, exercising or defending legal claims.
Different categories of information may be retained for different periods. Retention periods may also be affected by legal, accounting, regulatory, insurance or dispute-resolution requirements. When information is no longer reasonably required, we will seek to securely delete, destroy or anonymize it, where appropriate and permitted by law.
20. Your Privacy Rights
Subject to applicable law and lawful limitations, you may have rights concerning your personal information, including the ability to:
- Request access to personal information held by AZAO;
- Request correction of inaccurate information;
- Request deletion where legally permitted;
- Request restriction of certain processing;
- Object to certain processing;
- Withdraw consent where processing is based on consent;
- Object to direct marketing;
- Request information about how your personal information is processed; and
- Make a complaint concerning the handling of your personal information.
These rights are not absolute.
For example, we may need to retain information because of legal obligations, legitimate security requirements, accounting requirements, disputes or legal claims. Where we cannot comply fully with a request, we will explain the applicable limitation where appropriate.
21. How To Make A Privacy Request
If you wish to make a privacy request, complaint or enquiry, contact:
Azao Resort & Spa
Pongwe, Zanzibar, Tanzania
Email: reservations@azaoresortzanzibar.com
Telephone: +255 779 567822
Please provide sufficient information to allow us to understand your request. For security purposes, we may request reasonable information to verify your identity before providing personal information or making changes to information. We will seek to respond within a reasonable period and in accordance with applicable legal requirements.
22. Automated Decision-making And Profiling
We do not currently intend to use personal information for automated decision-making that produces legal or similarly significant effects on individuals. If this changes, we will review the applicable legal requirements and provide appropriate information and safeguards where required.
23. Children’s Information
We provide hospitality services that may be used by families and guests of different ages. Where information relating to a child is collected, we will handle that information responsibly and in accordance with applicable law.
Where authorization, consent or other safeguards are required for the collection or use of a child’s personal information, we will seek to apply the appropriate requirement. Parents or legal guardians may contact us regarding personal information concerning a child in their care. We do not knowingly collect children’s personal information for purposes that are unnecessary or unrelated to our legitimate services and operations.
24. Third-party Websites And Services
Our website may contain links to third-party websites, booking platforms, payment services, social-media platforms or other third-party services. These third parties operate independently from AZAO and may have their own privacy policies and terms. We are not responsible for the privacy practices, security or content of third-party websites or services that we do not control. We encourage you to review the privacy policy of any third-party service before providing personal information to that service.
25. Complaints And Privacy Concerns
If you have a concern about how we have handled your personal information, we encourage you to contact us first so that we can investigate and attempt to resolve the matter. Privacy concerns may be submitted to:
Azao Resort & Spa
Pongwe, Zanzibar, Tanzania
Email: reservations@azaoresortzanzibar.com
Telephone: +255 779 567822
We will review privacy-related complaints and take reasonable steps to address legitimate concerns. Nothing in this section prevents an individual from exercising any right to complain to a relevant government or regulatory authority where such a right exists under applicable law.
26. Changes To This Privacy Policy
AZAO may update this Privacy Policy from time to time. Changes may be made because of:
- Changes to our services;
- Changes to our website or information systems;
- Changes in applicable laws or regulations;
- Changes in the way we collect or use information;
- Changes to our security practices; or
- Improvements to our privacy procedures.
When we update this Policy, we will update the “Last Updated” date shown at the beginning of the Policy. Where applicable law requires additional notice or consent for a material change, we will provide the appropriate notice or seek the appropriate consent. We encourage guests and website users to review this Policy periodically.
27. No Waiver Of Legal Rights
Nothing in this Privacy Policy is intended to:
- Remove or restrict a legal right that cannot lawfully be excluded;
- Prevent us from complying with a legal obligation;
- Prevent us from disclosing information where disclosure is legally required or permitted;
- Prevent us from protecting guests, employees, property or systems;
- Prevent us from investigating suspected fraud, misconduct or unlawful activity; or
- Prevent us from establishing, exercising or defending legal claims.
Where a provision of this Privacy Policy conflicts with a mandatory requirement of applicable law, the mandatory legal requirement will prevail.
28. Contact Information
For all privacy-related questions, requests and concerns, you can write us at:
Azao Resort & Spa
Pongwe, Zanzibar, Tanzania
Email: reservations@azaoresortzanzibar.com
Telephone: +255 779 567822