1. Information we collect

Depending on your interactions with us, we may collect your name, email address, telephone number, travel destination and dates, departure city, group size, budget, accommodation and travel preferences, and messages you choose to provide. We may also keep correspondence, booking-related records, service-fee invoices and payment confirmations. Our website and service providers may process technical information such as IP address, browser details and cookie data.

At launch, Gate 32 does not routinely request or collect passport copies or passport numbers through its inquiry form. If identification or other sensitive travel information becomes necessary for a booking, we will explain the purpose and arrange an appropriate secure collection method before requesting it. Please do not send passport copies, payment card numbers or sensitive personal details through ordinary inquiry forms or unsecured email.

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2. Why we use personal information

We use personal information to respond to inquiries; understand your travel requirements; research options; prepare proposals and itineraries; coordinate bookings through our host agency and travel suppliers; communicate updates; administer service fees and business records; respond to questions and complaints; protect our systems; and meet applicable legal obligations. We use information for marketing only where permitted by applicable law, and you may opt out of marketing communications.

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3. How information is shared

To provide requested travel services, we may share information as necessary with our host agency, Fora, and relevant travel providers such as airlines, hotels, tour operators, transportation providers and other booking partners. We may also use providers supporting our website, inquiry forms, email, payment administration and business operations, including Wix, Tally and Dropbox. Each recipient may process information under its own applicable privacy terms. We do not sell personal information. We may disclose information where required by law or to protect legitimate legal rights.

Where necessary to arrange travel services, Gate 32 may request passport copies or other travel documentation through a secure file upload service provided by Dropbox. Access to uploaded documents is restricted to authorized personnel, and information is retained only for as long as reasonably necessary for the relevant travel arrangements or applicable legal obligations. Dropbox may process and store information outside Bermuda in accordance with its applicable privacy and security arrangements.

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4. International processing and transfers

Travel planning often involves service providers and destinations outside Bermuda. Personal information may therefore be accessed, processed or stored in other countries, including where our technology providers and travel suppliers operate. We will take reasonable steps appropriate to the circumstances to protect personal information and address applicable Bermuda PIPA requirements for overseas disclosures.

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5. Cookies and website technology

Our website may use cookies or similar technology needed for website operation, security, analytics or other enabled features. The cookies used depend on our Wix website configuration and any third-party integrations. Where required, we will provide appropriate cookie information and choices. You may also manage cookies through your browser settings, although disabling some cookies can affect site functionality.

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6. Security

We take reasonable administrative and technical steps to protect personal information against unauthorized access, misuse, loss and disclosure. These include limiting access to business information, using secure accounts and authentication, and choosing suitable service providers. No internet transmission or storage system can be guaranteed completely secure. We will review and strengthen our arrangements as our business develops.

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7. How long we keep information

We retain personal information only for as long as reasonably necessary for the purposes described in this policy, including providing services, maintaining appropriate business records, handling disputes and meeting legal requirements. Retention periods may vary by record type. When information is no longer needed, we will securely delete it or otherwise dispose of it appropriately, subject to applicable retention obligations.

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8. Your privacy rights

Subject to applicable requirements and exceptions under Bermuda’s Personal Information Protection Act 2016 (PIPA), you may request access to personal information we hold about you, ask us to correct inaccurate information, request erasure in appropriate circumstances, or object to certain uses. We may need to verify your identity before acting on a request. We will explain any applicable limitation or lawful reason for retaining information.

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9. Marketing communications

If you choose to receive updates or offers from Gate 32, we may contact you using the details you provide, where legally permitted. You may unsubscribe or ask us to stop marketing at any time by contacting us. Transactional communications relating to an inquiry or booking may still be necessary.

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10. Children’s information

Our services may involve family travel. A parent or guardian should provide any personal information relating to a child where needed for travel arrangements. We do not intentionally invite children to submit their own inquiries through our website.

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11. Questions, requests and complaints

Gate 32 is responsible for handling privacy inquiries relating to its own operations. For questions, access or correction requests, objections or complaints, please contact:
Gate 32 — Privacy Officer
Email: hello@gate32travel.com
Bermuda

You may also contact the Bermuda Privacy Commissioner through www.privacy.bm if you have concerns about how your personal information is handled.

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12. Changes to this policy

We may update this Privacy Policy as our services, technology or legal obligations change. The current version will be published on our website with its effective date. Material changes will be communicated where appropriate.

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