Privacy Policy

This Privacy Policy of Pepper Life (Private) Limited (hereinafter “the Company”) relates to personal information and the use of cookies on the website(s) of the Company. This Policy extends to the collection and use of personal information received by the Company, regardless of the medium of receipt.

Background

  • The Company uses cookies on its Web-site.
  • The Web-site permits Users to view the products and services offered by the Company, to make Communication with the Company and enter into binding contracts with the Company or a principal of the Company.
  • The Company recognizes that the Website is not the only medium of Communication and that any transaction may be completed by any legally accepted method(s) based on Communication(s) via the Web-site.
  • The Company further recognizes that Personal Information can be received by the Company in the course of any Communication, the making and performance of any contract.

Definitions

Unless otherwise stated or intended, the following terms as used in this document shall have the meanings and interpretations assigned to it

  • “Affiliate” - means any holding company, subsidiary or other company with common shareholding or control as of the Company, which include and is not limited to Red Dot Tours Lanka (Private) Limited and Yaana Travels (Private) Limited;
  • “Company” - means Pepper Life (Private) Limited, a limited liability company incorporated in Sri Lanka;
  • “Communication” - means statement, declaration, demand, notice or request between the Company and any individual, who may be User and/or the originator of any Personal Information.
  • “Device” - means any computer, tablet, mobile phone or other equipment used to access, view and carry out transactions on the Website by means of human interaction.
  • “Personal Information” - means any information such as name, gender, address, email address, telephone number, date of birth capable of directly identifying any living individual;
  • “Related Brands” - means SriLankaInStyle, YAANA, Red Dot Tours, Red Dot Sports, InStyle Incentives and The Fabulous Getaway;
  • “Sensitive information” - relating to any individual means any information relating to any medical condition, pregnancy, allergies, disabilities or any special needs, racial / ethnic origin, sexual orientation, political or religious belief;
  • “User” - means any individual viewing, browsing, making any Communication or transaction on the Website;
  • “Web-site” or “Website - refers to the Pepper Life website and all pages therein under the pepper.life domain.

The Web-site

The Web-site (including the domain) is owned by the Company and is directly operated as a marketing tool in its business of being a travel agent. The Web-site is used for the purpose of promoting and developing and business of the Company (and its Affiliates as appropriate) and to enable some Communication and interaction with the Company.

The following tools will be used on the Web-site for purposes set-out

  • Cookies are deployed on Web-site the purpose of identifying each User and enabling an improved user experience; and
  • Certain Google Analytics Advertising Features are used for the purpose for collecting user behaviour on the website; and
  • User is permitted to Communicate with the Company for travel related inquiry or booking

The use of cookies and Google products are within the terms of use set out in this Privacy Policy.

Consent of Users

The access and browsing of the Website, any Communication with the Company (including those from the Website) with the Company relating travel, bookings, ticketing or inquiries therefore are acts voluntarily carried out by the User, (which may involve the transfer of Personal Information to the Company) and is entirely at the discretion of the User.

The access and use of the Website by the User is subject to the following terms and conditions –

  • Consent to Cookies - By the access, browse or visit of the Website, User agrees to the storing and running cookies on Devices of the User (including cookies from Google Analytics Advertising Features) subject however to the option of the User to disable any Cookie(a), as described herein;
  • Submission of Personal Information – By making any inquiry, Communication or booking or completion of any booking on basis of a Communication via the website the User agrees to the submission of Personal Information to the Company and to its uses and utilization;
  • Intellectual Property – all content hosted on the Website are owned by the Company (unless otherwise acknowledged) and subject to copyright laws;
  • Consent – by accessing the Website and/or upon making any inquiry, Communication the User is considered to have accepted the terms and conditions relating to the use of the Website.

If the User is not in agreement to the terms and conditions set out herein (including and not limited to the use of cookies on the Website or the submission of any Personal Information) the User must refrain from using this Website or entering into any Communication or transaction with the Company.

Collection of Personal Information

Personal Information (Including any sensitive information of any individual) may be collected in the following manner, inter alia

  • Filling out of any form, contact page or submission of any inquiry, request for booking, payment information within the payment centre or any Communication made on or through the Website;
  • Disclosures made, where the required booking or travel arrangements are dependent on availability of sensitive information of any individual;
  • The entering of any competition, promotion or completion of any survey or questionnaire hosted on the Website or completion of any questionnaire or feedback form relating to the services of the Company or any service provider;
  • Lodging of any problem relating to the Website or lodging any compliant relating to the services of the Company;
  • Responding to a request for contact details specifically requested by the Company for marketing use for the transmission of promotional emails, webcasts or newsletters all of which will carry of option to terminate the receipt of the same;
  • Names, contact information and any sensitive information for the completion and performance of any booking / travel arrangements by the Company (or service providers) including the receipt of any alerts to any Device by means of an app, “sms” or email;
  • Any email address, IP address, phone numbers, postal addressed plus the recoding of any phone conversations of any person depending medium of contact relied upon by the User to contact the Company and at which a response is to be provided by the Company;

Use of Personal Information

The Company collects Personal Information for the primary purpose of providing travel services (including undertaking, securing and completing any booking) to its clients and customers. In doing so, the Company shall use all or such parts of Personal Information in the following manner -

  • To respond to any inquires received by the Company (including the gathering of information from service providers to formulate any response and where any customized or personalized arrangements are required);
  • In the performance of any obligations under any booking to be carried by the Company and/or with any service provider including the sending of any notifications, reminders, alerts and prompts;
  • To enable the User to engage in any interactive features on the Website or any other software application or app to be placed on a Device of the User before, during and after any travel or travel related service by the Company or service provider, at the option of the User;
  • To respond to and resolve any complaints from clients, customers including escalation of the complaint to service providers for resolutions, rectification and improvements to service standards;
  • To inform User of the services of the Company and or its Affiliates and Related Brands, changes to the services, promotions and new destinations / products;
  • To assist and aid with development and improvement of the services provided by the Company, formulate products and review and set service standards of the Company and Related Brands;
  • To assist and aid with development and presentation of content on the Website including changes thereto arising from the User preferences and choice of Devices utilized;
  • and for the purpose of improvement of the quality of services and products offered by the Company and Related Brands;
  • To carry out any research, marketing activities and customer profiling;
  • For preventing and detecting fraudulent or criminal activity and assist in any state investigation of any fraud or criminal activity (including and not limited to money laundering, human trafficking, child abuse);
  • To process payments and for recovery of debts including financial evaluation for purpose of credit;

Confidentiality of Personal Information

All Personal Information (and sensitive information) will be held and stored by the Company subject to following

  • No disclosure will be made any third party for any reason other than for such disclosures that are necessary for the performance of any confirmed bookings to service providers, principals of the Company, employees and agents or resolution of any complaints by a customer or client;
  • All information will be stored on secure server with reasonable measures of security to protect against unauthorized access, with access database / server being restricted only permitted employees, agents of the Company and other persons under the control of the Company, who need to use the Personal Information in the manner stated in this Policy.

Service providers will mean and include those persons undertaking to perform / provide services relating to the travel arrangements such as hotels, carriers (air and land transport), ground handling agents, shops, restaurants, historical sites, amusement parks, places of interest, recreational facilities and other similar services providers.

Third Party Activity and Use of Personal Information

  • Use of Personal Information by the Company is solely for the business of the Company to exclusion of all third party activity subject to the following -

    • Affiliates of the Company
      To Affiliates of the Company, who may use Personal information for provision of supplementary services to the booking made or to be made and to enable provision of cross-products and enhanced travel services under Related Brands of the Affiliates (or of the Company) subject to the same standard of confidentiality and security of any Personal Information; and
    • Advisors and Consultants
      To travel professionals, consultants and other business advisors who may be retained by the Company from time to time service development, marketing and development activities (all of whom will be subject to confidentiality agreement relating to the use of Personal Information of clients and customers).
    • Statutory Disclosures
      Where the Company is be called upon provide or release any part of Personal Information under an order of a Court or directive by any person or authority acting under the power of a statutory instrument (or at its own discretion) to provide to statutory authorities such as customs department, immigration and emigration department, airport and aviation authorities.
  • The cookies and links hosted on the Website are subject to the following with regard to third party activity -

    • Third Party Websites Accessed by Users
      The Cookies used on the Website cannot track any browsing activity of the User on any other websites.
    • Links to Third Party Websites
      The Website may contain links websites of Affiliates or permitted service suppliers or principals of the Company, which links may be followed by the User. The User must be aware that such websites may or may not use cookies, which are subject to their own respective privacy policies for which no responsibility or liability can be placed upon the Company.

Collection of Personal Information by use of Cookies

The use of cookies is only for the purpose of enhancing User experience on the Website and for collecting information relating to preferences of potential travellers or customers of the Company.

Cookies are not used for the purpose of extracting Personal Information of the User without specific consent or authority of the User.

Use and Effect of Cookies

Primarily cookies are used to identify and set apart each User from the others. Cookies deployed on the Website are designed to enable the User to browse and use features of the website and to enhance User’s experience on the Website.

Cookies used on the website help and assist to identify the User’s behaviour on the Website with regard to

  • Specific parts of the website visited or used by the Visitor;
  • information to measure effectiveness of any content or advertisements of the Company and effectives of Website (and its content including advertisements) in relation to a web search by the User;
  • information relating user behaviours and preferences on the website in order to improve the functionality of the Website.

Google Analytic Advertising Features

The use of Google Analytics on the Web-site is for the purpose of obtaining information on user preferences and customer profiling, to be used for product development and marketing activities of the Company. There is no requirement for identification of the User.

  • Use of Google Advertising Products and Cookies
    Google advertising cookies and identifiers are used in the following manner.

    • Google’s Analytic Advertising Features used on the website are ‘Remarketing with Analytics’, ‘Demographics and Interests Reporting’ and ‘Segments’, all of which are products provided by Google under contract.
    • These products, as in other cookies, operating by storing and accessing cookies on the Devices of the User to collect data.
    • These do not collect any Personal Information nor any information capable of identifying a User. Google reports derived from these products, are always aggregated data and never the data of a particular User.
  • Cookies used by these Google Advertising Products may be disabled by the User on each Device, which has no effect on the access and use of the website.

Disabling Cookies

The User can choose to accept or decline cookies from her/his Device. Most web browsers automatically accept cookies, but User is permitted to modify the browser settings on her/his Device so as to decline cookies.

Please review the following settings of your device:

Cookie settings in Internet Explorer
Cookie settings in Firefox
Cookie settings in Chrome
Cookie settings in Safari web and iOS.
For other browsers, check with your provider to find out how to disable cookies.

Note however that disabling any cookies may cause certain parts of the website to not function as intended because cookies are used throughout the Website to improve the user experience.

Categorization of Cookies

While it is not possible list each of the Cookies used by the Website, this following paragraphs categorises Cookies broadly based on the purpose and function, information collected and its use and effect of disabling Cookies.

  • Category 1 — Strictly Necessary Cookies
    These cookies are essential to enable the Visitor to browse around the websites and use its features.

    Effect of Disabling the Cookies:
    Functionalities such as the Quick Finder menus, Itinerary calculator and Contact Us forms will not work.
  • Category 2 — Performance Cookies
    The aim of these cookies are allow User to navigate between pages efficiently, storing preferences, and improving experience of a website.. They make interaction between User Websites faster and easier. Performance cookies DO NOT collect any information that could identify User (or Personal information of the User) but prevent the User from for example using a log-in code every time User moves from one page to another

    Effect of Disabling the Cookies:
    The User will be required to authenticate himself through-out the entire session, and at each step will be recognized as a new user.
  • Category 3 — Functionality Cookies
    The Website does not use any functional cookies.

Security Measures

This Privacy Policy must not interpreted as a guarantee of complete security of any Personal Information. Transmission of information by electronic means (i.e internet/web-based transmission) is not completely secure though the Company will adopt reasonable measures for the security of all Communications and the content thereof. Hence all transmission is and must necessarily be at the risk of the User. Once any Communication is received by the Company all reasonable measures as practically possible will be adopted for the security of Personal Information at the minimum standard set-out in this Policy.

Applicable Laws

Any Communication or transaction shall not be denied legal validity or enforceability purely on the grounds of such Communication or transaction being in electronic form alone and shall deemed to be legal valid in accordance with the provisions of the Electronic Transactions Act, No 19 of 2006 of Sri Lanka.

The Company is outside the European Economic Area and is therefore not subject to any laws relating to data protection and privacy as implemented in the EEA though some Affiliates, service providers and principals may be domiciled or operate in jurisdictions within the EEA.

The Company carries on business in Sri Lanka and is subject to the laws of Sri Lanka.

This Policy was last updated on July 14, 2017.