Privacy Policy
1. Who we are
TOWNR LLC (“TOWNR”, “we”, “us”) operates educational travel programs for students aged 11–17 in Australia, Brazil and Japan. We are the controller of the personal information described in this policy.
- Registered address: [REGISTERED ADDRESS]
- Email: privacy@townrcamps.com
- Privacy contact: [NAME OF THE SISTER RESPONSIBLE]
2. The information we collect
When you enquire
If you contact us through our website form or by email, we collect your name, email address, organization, country, and whatever you tell us about the group you are planning.
When a student is enrolled
To run a camp safely and legally we collect, from a parent, guardian or school rather than from the student directly:
- Name, date of birth, nationality and passport details
- Parent or guardian contact details and emergency contacts
- Medical information: allergies, medical conditions, medication, dietary requirements, and consent for emergency medical treatment
- Travel insurance details
- Photographs and video, only where media consent has been given
Medical information is sensitive personal data. We collect only what is necessary to keep a participant safe, we share it only with the people who need it to do that, and we delete it after the program.
When you visit the website
[IF YOU ADD ANALYTICS, DESCRIBE IT HERE.] Our website does not set advertising or tracking cookies. Typeform, which powers our enquiry form, and Heyzine, which hosts our program brochures, each set their own cookies when you use them.
3. Children’s privacy
Where a participant is under 13 and located in the United States, we handle their information consistently with the Children’s Online Privacy Protection Act. Where a participant is in the UK or European Economic Area, we rely on parental or guardian consent as required by data protection law.
4. Why we use it, and on what basis
| Purpose | Legal basis |
|---|---|
| Responding to enquiries and preparing quotes | Legitimate interests; steps toward a contract |
| Delivering a booked program | Performance of a contract |
| Participant safety, supervision and emergency response | Vital interests; explicit consent for health data |
| Visas, airlines, accommodation and activity providers | Performance of a contract; legal obligation |
| Insurance and safeguarding records | Legal obligation; legitimate interests |
| Photographs used in marketing | Consent, which can be withdrawn at any time |
5. Who we share it with
We share personal information only where it is needed to run a program or where the law requires it:
- Accommodation providers, transport operators and activity providers in the destination country
- Local partners and coordinators who deliver the program on the ground
- Insurers, and medical providers in an emergency
- The agent or school that made the booking, where they are a party to it
- Government authorities where required, including immigration and visa processing
- Service providers: [LIST: e.g. Typeform, Heyzine, Google Workspace, your host, your booking tools]
We do not sell personal information, and we do not share it for advertising.
6. International transfers
Running programs in Australia, Brazil and Japan means participant information is transferred to those countries, whose data protection laws differ from those where you live. Where we transfer information out of the UK or European Economic Area, we use appropriate safeguards such as Standard Contractual Clauses. [CONFIRM WITH YOUR ATTORNEY WHICH MECHANISM YOU RELY ON.]
7. How long we keep it
| Information | Retention |
|---|---|
| Enquiries that do not become bookings | [e.g. 24 months] |
| Passport and travel details | Deleted within [e.g. 90 days] of program end |
| Medical and dietary information | Deleted within [e.g. 90 days] of program end |
| Booking, financial and tax records | [e.g. 7 years], as required by law |
| Incident and safeguarding records | [TAKE ADVICE — often longer] |
| Photographs used with consent | Until consent is withdrawn |
8. How we protect it
- Participant and medical data is collected through encrypted forms and stored in access-controlled accounts.
- Only the staff who need a participant’s information can see it.
- We do not send passport or medical information by unencrypted email.
- Camp staff carry only the information required for supervision and emergency response.
9. Your rights
Depending on where you live, you may have the right to access a copy of your information, correct it, delete it, restrict or object to how we use it, receive it in a portable format, and withdraw consent. Residents of California and certain other US states may also have the right to know what we collect and to opt out of sale or sharing — we do neither.
To exercise any of these, email privacy@townrcamps.com. We respond within [30 DAYS]. A parent or guardian may exercise these rights for a child.
If you are in the UK or EEA and are unhappy with our response, you may complain to your national data protection authority.
10. Changes
If we change this policy we will update the date above, and we will tell anyone with a live booking directly if the change is significant.
11. Contact
TOWNR LLC · [REGISTERED ADDRESS]
privacy@townrcamps.com