Dodi World

DODI WORLD Cruises Privacy Information Notice pursuant to Data Protection Act 2012 Act 843

1. Who we are: Akosombo Hotels Limited (Dodi World )

Akosombo Hotels Limited (herein referred as Dodi World) is committed to providing quality service to our guests, potential customers, business partners, employees and future employees, respect the privacy of all our internal and external customers and business partners, and treat all personal information as confidential. This personal data privacy policy (the “policy”) applies to personal data and information regarding guests and other individuals with whom we do business with and to the management of that data and information in any form, whether electronic or written. This policy gives effect to our commitment to protect your personal information. We limit the collection, use and retention of the data to the specific information we need for legitimate purposes to administer our business, to provide you with quality service and offer various products or services from Volta Hotel Akosombo (Dodi World). In order to provide you with a great cruise and water sports experience, we collect personal data about you on different occasions, such as when you browse the website www.dodiworld.com.gh, when you book a cruise or when you make on-board purchases. Please read carefully this information notice, which is based on Data Protection Act 2012 (Act 843) For any doubts regarding the content of this document, please refer to our FAQ document available here or contact our designated Data Protection Officer via email at dpo@dodiworld.com.gh. / info@dodiworld.com.gh. You can also send requests in writing to Akosombo Hotels Limited, Dodi World P.O.Box 25,Ghana. Akosombo.

2. Why, When and How we collect personal data about you.

Our main objective is to provide you with a great experience during your cruise and water sports activities. Below you will find the main purposes why your data is processed.

a. Providing you with information regarding your requests about our cruises (via website, call centre, sms or email)

We need to know your name, contact details as well as the content of your request. Without this data, we cannot provide you with the requested information. We will only use this information to answer your request. This processing is carried out to take steps at the request of the data subject prior to entering into a contract (Article 17,18,19 DPA 2012 Act 843). In addition, and only where you indicate your express and specific consent, we will use your contact details to send you newsletters and marketing communications via email or SMS about our products and services that may interest you. This processing is based on your consent, pursuant to Art. 20 DPA 2012 Act 843), and you can revoke the consent at any time emailing us using the contact email address provided in section 1 above.

b. Completing and handling the booking of a cruise

To travel on-board our boats, you need to provide your name, contact details, date of birth and nationality at booking stage. We also register some information about your cruise choices, such as chartered type and type of cruise experience. We process this data on the basis of our contract with you (Article 22, 23 DPA 2012 (Act 843). During the booking, in some cases, you could communicate data revealing information about your health or even your religious preferences (for example, food preferences that indicate the observance of a specific religion – such as kosher or Vegetarian food – or medical conditions requiring special attention on-board – such as disabilities or celiac disease). We collect this data in our Special Needs form and process it only on the basis of your informed and specific consent (Act. 22 DPA 2012 (Act 843). It is not mandatory to provide this data, but please be informed that if you do not provide it, we are unable to accommodate your needs on-board. When you make a booking with a Travel Agency, that Travel Agency will insert the above data into our booking systems, acting as autonomous data controller; the Travel Agency will be responsible for the processing it carries out on your personal data and for taking the adequate data protection measures. Please contact your local Travel Agency for information about how it processes your personal data.

c. Sending you personalized newsletters and communications according to your preferences

When you write us a message using the “Contact us” page and indicate that you wish to receive personalized information about our products and services, we will contact you via email or SMS to let you know our latest offers and cruise products that we think might be of interest to you. Similarly, you have the opportunity of providing your informed and specific consent to receive personalized information from us when you sign up for our Newsletter, when you enroll in the Dodi World Cruise Club, when you request a brochure or a call from us, as well as when you sign up for a Boat visit or participate in one of the promotions we organize on our Website. In all the cases above, it is not mandatory to provide your consent to receive personalized messages and offers from us, but without your consent we will not be able to send you personalized offers. Since the processing of your data for the purposes indicated above is based on your specific consent (Article 22 DPA 2012 (Act 843), you can revoke this consent at any time by clicking on the “unsubscribe” link at the bottom of a marketing email received. In addition, when you browse our Website, we use profiling cookies that can track some information about you, provided that you consent to our use of such cookies. We use this information to make the Website more intuitive and to suggest products or services that may be of interest to you. You can find more information about our use of cookie and other tracking technologies used on the Website below.

d. Sending you information about similar products and services to the ones you already booked

When you give us your email in the context of booking a cruise with us, we will send you information about products or services that are similar or related to the ones you booked, unless you exercise your right to opt out of receiving marketing communications from us at the time of booking. For example, we will send you information about drinks package deals that are available on the cruise you booked. If you do not wish to receive this kind of information, please select the opt-out box when booking or click the relevant “unsubscribe” link in any of the emails that we sent you.

e. Handling requests, complaints and comments

We keep track of the comments and complaints that you make on board in order to adequately respond to your requests. We process these data in connection with our provision of services to you, therefore on the basis of the booking contract. You have the option of making an anonymous complaint or comment, but please be aware that in such case it will be impossible for us to follow up on the complaint or to provide assistance and support. In addition, we can use the content of the request, complaint or comment to improve our services on board. We limit as much as possible the use of data that may identify you personally in this case. This processing is carried out on the basis of our legitimate interests in developing our services in a way that ensures our guests get a pleasant experience on board, in accordance with Article 35 section .1 (a) (b) (c), section .2 DPA 2012 Act 843.

f. Ensuring on-board security

We keep track of the people who are on board at all times in order to be able to handle crisis situations and to ensure everybody’s security throughout the cruise. We therefore record your name, CCTV surveillance on board the boat (video taken when you come on board), date of birth, people you are cruising with and information about special needs that may require specific assistance in case of emergencies. For security reasons, we operate CCTV cameras onboard our boat, including all access points and in all public areas . These CCTV cameras are continuously recording 24 hours a day. We may perform screening of your personal data against publicly available databases to ensure security on board of our boats. We process these data on the basis of the need to ensure public security and to manage potential crisis situations (Article 30 section (1) DPA 2012 Act 843). g. Additional data processing activities on-board

Some additional information about you may be collected during the cruise on paperback forms, in order to enable you to participate in specific activities (for example, the island games or onboard games and activities) or to handle the request of specific packages (for example, the Romantic Sunset package). The data processed varies depending to the specific activity on board, however, we make sure to only collect the strictly necessary data to achieve the specific purposes. You will be required to complete the form if you want to receive that specific offer/event/package requested and we will process the data on the basis of our contract with you (Article 22 DPA 2012 Act 843). This data processing is conducted on the basis of our legitimate interests in ensuring that all passengers are assigned adequate seating on-board (Article 23 DPA 2012 Act 843). The information collected on board is stored for as long as necessary for each purpose.

h. Retention of records

In accordance with Article 24 section (1)(2)(3)(5) DPA 2012 Act 843 , the personal data that we collect is kept in a form which permits the identification of data subjects for no longer than is necessary for the purposes for which the personal data are collected and processed in each specific case, and in any case not longer than as specified by the relevant applicable laws. We have defined a Corporate Data Retention Policy that specifies the time frame for data processing at the end of which all copies of the personal data are either destroyed or anonymized using adequate techniques that do not permit the re-identification of the data subject. I. Your Data Subject Right

The Data Protection Act 2012 Act 843 provides for enhanced rights and is committed to giving you the appropriate control of your own personal data. In particular, you have the following rights in connection to your personal data:

a. The right to access your personal data and obtain specific information about how we process it, in accordance with Article (20)(23) GDPR; please be aware that you can only exercise this right in relation to your own data or to the data of a minor or another vulnerable person, where you have provided such data as a holder of parental authority or legal responsibility. Dodi World reserves the right to ask for proof of identity, as well as to refuse to provide the personal data if the identity or relevant connection to the data subject cannot be proven. b. The right to rectify your personal data, in accordance with Article 33 DPA 2012 Act 843, including by means of providing a supplementary statement. c. The right to obtain the erasure of personal data concerning you, in accordance with Article 44 section (1) DPA 2012 Act 843, unless the data are necessary for exercising the right of freedom of expression and information; for compliance with a legal obligation which requires processing by Union or Member State law to which Akosombo Hotels Limited (Dodi World) is subject or for the performance of a task carried out in the public interest or in the exercise of official . d. The right to obtain the restriction of the processing of your personal data. In accordance with Article (36) (39) DPA 2012 Act 843, this right may be exercised in the following cases: Temporary restriction, where you are contesting the accuracy of the personal data; in this case, we will restrict the processing of your data for a period enabling us to verify the accuracy of your data and we will provide feedback to you as to the lifting of the restriction; The processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead; Akosombo hotels Limited (Dodi world) no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims; Where you have objected to processing pursuant to Article 39 Section (1) DPA 2012 Act 843, the processing is restricted pending the verification whether our legitimate grounds override your rights as data subject. e. The right to data portability. In accordance with Article (40) (41) DPA 2012 Act 843, you may exercise this right in those cases where the processing is based on your consent or on your contractual relationship with Dodi World or one of the companies of our group, and the processing is carried out by automated means. f. The right to object, at any time, to the processing of the personal data concerning you. In accordance with Article 21 DPA 2012 Act 843, you may exercise this right where the processing is based on the performance of a task carried out in the public interest or in the exercise of official authority vested in us, or where the processing is based on our legitimate interests. g. The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or which similarly significantly affects you. In accordance with Article 41 DPA 2012 Act 843, you may exercise this right unless the processing is necessary for entering into, or performance of, a contract between you and Dodi World or one of the companies of our group; or is authorized by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests; or if the processing is based on the your explicit consent. h. The right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement, if you consider that the processing of personal data relating to him or her infringes the GDPR, in accordance with Article 42 DPA 2012 Act 843. J. Changes to this information notice

We reserve the right to update, modify, add or remove portions of this information notice at any time. In such case, we will post the reviewed Information Notice on this page; the date of the “Last update” will also be changed below and a banner will be displayed on the Website to draw your attention to the fact that changes have been made. Each version of the information notice takes effect from the moment it is published on the Website. Significant changes to the processing of your personal data will require your approval, in accordance with the applicable legislation. You are responsible for reviewing this document from time to time in order to make sure that you are aware of the current version. If you would like to obtain a prior version of the information notice, please contact us using our contact details provided on the contact us form.

K. Our Website Cookies

Cookies are small text files sent by websites to users’ browsers for the purpose of automatic authentication, session tracking and storing of specific information regarding users. There are essentially three types of cookies used on this website: • Technical cookies Required for navigation within the site and to use some of its functions (e.g. timing the display of certain pages in so-called “pop-up” mode etc.). • Statistical cookies (Google Analytics) Supplied and managed by Google to provide a statistical analysis of access to the website. The information is solely collected anonymously and in aggregate form and no personal user data is retained. You can decide not to use Google Analytics cookies by following the instructions at the following link: https://tools.google.com/dlpage/gaoptout?hl=en • Profiling cookies Supplied and managed by third parties to generate specific advertising messages based on browsing habits and the interests of individual users. These cookies do not, however, use sensitive user data. Cookie functions can be disabled via the appropriate page made available by the EDAA (European Interactive Digital Advertising Alliance) http://www.youronlinechoices.com/ or by checking the "Privacy" settings of your Internet Browser. Please note that disabling cookies may impair the correct functioning of the certain website sections. Last update: 1st December,2019