PRIVACY
POLICY.

1. WHO WE ARE

Miremby Ltd (“Miremby”, “we”, “us” or “our”) is a UK-registered company, company number 15290971. We design and arrange travel experiences in Madagascar.

For data protection questions or to exercise your rights, email hello@miremby.com.

2. INFORMATION WE COLLECT

We may collect information you give us when you contact us, submit a tour enquiry or plan and book a journey. This may include your name, email address, telephone or WhatsApp number, travel dates, group size, budget range, journey preferences, accessibility requirements and anything else you choose to tell us.

If you make a booking, we may also need information required to arrange your trip, such as traveller details, identification or passport information, dietary requirements, emergency contact details and payment or transaction records.

Our website and service providers may also collect limited technical information, such as your IP address, browser type, device information, pages visited and security logs.

3. HOW WE USE YOUR INFORMATION

We use personal information to:

• respond to questions and tour enquiries;
• recommend, design, quote for and arrange journeys;
• manage bookings, payments and customer service;
• communicate important information about a proposed or confirmed trip;
• meet legal, accounting and safety obligations;
• protect our website, systems, customers and business from misuse or fraud; and
• improve our website and services using appropriate, proportionate information.

We do not sell personal information.

4. OUR LAWFUL BASES

Under UK data protection law, we rely on one or more of the following lawful bases:

• Steps before entering into a contract and performance of a contract — to respond to an enquiry, prepare a proposal and arrange a booked journey.
• Legitimate interests — to operate and improve our business, provide customer service, maintain appropriate records and keep our website and communications secure, where those interests are not overridden by your rights.
• Legal obligation — where we must retain or disclose information to comply with law.
• Consent — where we ask for it, including for certain optional communications or sensitive information. You may withdraw consent at any time.

5. SENSITIVE INFORMATION

Travel planning can sometimes involve health, dietary, mobility or accessibility information. Please share only what is reasonably necessary. Where information is classed as special category data, we will handle it with additional care and rely on an appropriate legal condition, which may include your explicit consent.

6. WHO WE SHARE INFORMATION WITH

We share personal information only where reasonably necessary. Recipients may include trusted website hosting, email, IT security, administration, payment, accounting and professional service providers.

For a proposed or booked journey, we may share limited practical information with the particular accommodation provider, driver, guide, transport operator or activity provider involved. We share only what that person or organisation reasonably needs to provide the agreed service. Guides and drivers are not given access to your complete enquiry or booking record.

We ask people and service providers handling information for us to protect it and use it only for the agreed purpose. We may also disclose information where required by law or to protect someone’s vital interests.

7. WORKING WITH PARTNERS IN MADAGASCAR

Arranging a journey in Madagascar may require us to send limited personal information from the UK to an independent guide, driver, accommodation provider or other selected local partner in Madagascar. Under UK data protection law, this can count as an international transfer even where only a small amount of information is shared.

We limit these transfers to information needed to organise or safely deliver your journey, consider the recipient and purpose before sharing, and use an applicable legal safeguard or exception where required. You can contact us if you would like more information about how your details will be handled for a particular journey.

8. HOW LONG WE KEEP INFORMATION

We keep personal information only for as long as needed for the purpose for which it was collected and to meet legal, tax, accounting and dispute-resolution requirements.

• Tour enquiries that do not become bookings are normally retained for up to 24 months after the last meaningful contact.
• Booking and transaction records are normally retained for up to seven years after the end of the relevant financial year.
• Security and technical records are kept only for a proportionate period based on their purpose and risk.
• Information used with your consent is kept until the purpose ends or you withdraw consent, unless another lawful basis requires us to retain it.

When information is no longer required, we securely delete or anonymise it.

9. HOW WE PROTECT INFORMATION

We invest in appropriate technical and organisational safeguards designed to protect personal information against accidental loss, misuse, unauthorised access, alteration or disclosure. These measures include access controls, secure systems and service providers, software maintenance, protective checks and limiting access to people who need the information for their work.

No website, email service or storage system can be guaranteed to be completely secure. We regularly consider our safeguards and update them where appropriate.

10. COOKIES AND WEBSITE DATA

Our website may use essential cookies needed for security and functionality. Where non-essential analytics or similar technologies are used, they should be controlled through the website’s cookie choices where required. You can also manage cookies through your browser settings, although blocking essential cookies may affect how the website works.

12. COMPLAINTS

Please contact us first if you have a concern so we can try to resolve it. You also have the right to complain to the Information Commissioner’s Office, the UK data protection regulator. Visit ico.org.uk/make-a-complaint.

13. CHANGES TO THIS POLICY

We may update this policy when our services, suppliers or legal obligations change. The latest version will be published on this page with its updated date.