Privacy Policy

Introduction

This Privacy Policy explains how TravelDen Nigeria Limited (“TravelDen,” “we,” “our,” or “us”) collects, uses, stores, transfers, and protects your personal information when you interact with us, whether through our website, mobile applications, customer service channels, or in the course of providing travel, aviation, and holiday services.

We are committed to safeguarding your privacy and handling your personal data responsibly in accordance with applicable data protection laws, including the Nigeria Data Protection Act 2023 (NDPA), the Nigeria Data Protection Regulation 2019 (NDPR), and where applicable, the General Data Protection Regulation (GDPR – EU/UK).

By using our services or providing your personal information, you consent to the practices described in this Privacy Policy.

Information We Collect

We may collect and process the following categories of personal information:

Identification and Travel Documents: Passport details, visa information, driver’s licence, national ID, and other identification documents.
Personal Information: Full name, address, email, phone number, gender, date of birth, nationality.
Financial Information: Payment details, billing address.
Travel Information: Itineraries, flight and hotel bookings, ticketing details, travel companions, frequent flyer details, and loyalty memberships.
Health and Medical Data: Where required for travel (e.g., vaccination records, medical clearance, special assistance requests).
Insurance Information: Policy numbers, claims, or coverage details.
Device and Online Data: IP address, browser type, device ID, geo-location, website usage patterns, cookies, and analytics.
Other Information: Any data you voluntarily provide (e.g., survey responses, complaints, communications).

Where you provide information on behalf of another individual (such as a travel companion), you confirm that you have their consent and have informed them of this Privacy Policy.

Lawful Basis for Processing

We process personal information under one or more of the following lawful bases:

Consent – where you have expressly agreed to our processing.
Contract – to perform our contractual obligations in providing travel services.
Legal Obligation – to comply with Nigerian laws, immigration, aviation, and tax requirements.
Legitimate Interests – to improve services, ensure fraud prevention, protect our systems, and manage operations.
Vital Interests – where processing is necessary to protect your life or health (e.g., in medical emergencies).

How We Use Your Information

We use your personal information for the following purposes:

To process and confirm bookings (flights, hotels, visas, transfers, insurance).
To comply with immigration, customs, and aviation regulations.
To provide customer service, support, and account management.
To communicate service updates, changes, or security notices.
To administer loyalty programmes, surveys, rewards, or promotional events.
To improve our website, apps, and services through analytics and research.
To send you marketing and promotional communications (you may opt-out at any time).
To comply with legal obligations, resolve disputes, and enforce agreements.

Sensitive Data

Certain data (passport details, health information, biometrics) are classified as sensitive personal data under the NDPA. We will only process such data with your explicit consent or where required by law (e.g., for visa issuance, medical clearance).

Sharing and Disclosure

We may share your personal information with:

Airlines, hotels, embassies, consulates, and travel partners – to fulfil bookings and visa processing.
Third-party service providers (IT support, payment processors, insurance companies) who process data on our behalf under strict contractual obligations.
Regulatory authorities (immigration, customs, aviation, security agencies) where required by law.
International affiliates or partners in connection with global bookings.

We require all third parties to process personal data in compliance with Nigerian data protection laws and, where applicable, GDPR

Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy or as required by law. For example:

Booking and travel records: minimum 5 years (aviation/tax compliance).
Financial records: minimum 7 years (tax purposes).
Sensitive data (passport/medical): deleted once travel is completed, unless legally required to retain.

Security of Data

We employ physical, technical, and organisational safeguards to protect data, including:

Encrypted storage and transmission of sensitive information.
Restricted access to personal data based on role.
Regular audits and penetration testing.
Compliance with NDPA requirements on security measures

Your Rights (Nigeria & International)

As a data subject, you have the following rights:

Right of Access – to obtain a copy of personal data we hold.
Right of Rectification – to correct inaccurate or incomplete information.
Right to Erasure – to request deletion where no longer necessary.
Right to Restrict Processing – in certain circumstances.
Right to Data Portability – to receive your data in a usable format.
Right to Withdraw Consent – at any time for data processed on the basis of consent.
Right to Object – to direct marketing or profiling.
Right to Lodge a Complaint – with the Nigeria Data Protection Commission (NDPC) or your local authority (if in the EU/UK).

Cookies and Tracking

We use cookies and similar technologies to enhance your browsing experience. You will be asked to provide consent before non-essential cookies (analytics/advertising) are placed on your device.

Children’s Data

We do not knowingly collect personal data of children under 18 without parental/guardian consent.

Updates to this Policy

We may update this Privacy Policy from time to time. Significant changes will be communicated via email or posted on our website with an updated effective date.

Contact Us

If you have questions, requests, or complaints regarding your personal data, please contact:

Data Protection Officer (DPO)
TravelDen Nigeria Limited
29, Toyin Street, Ikeja, Lagos State.
Email: dpo@finchglowholdings.com
Phone: +234 908 818 9806