PRIVACY POLICY
Makoma Expeditions Ltd
Version 1.0 | Last updated 14/07/2026
Who we are. Makoma Expeditions Ltd (we, us, our) is a UK tour operator that arranges private guided safari packages in Tanzania. We are the controller of the personal data described in this policy. This policy explains what personal data we collect, how and why we use it, who we share it with, how long we keep it, and the rights you have under the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
1. Our Details
Controller
Makoma Expeditions Ltd
Company number
16976519 (registered in England and Wales)
Registered office
c/o BCG Financial, 111 South Road, Waterloo, Liverpool, L22 0LT
Contact for data matters
Jake Ansell, Director
Telephone
+44 (0) 7397 120320
We are not required to appoint a statutory Data Protection Officer, but the Director named above is responsible for data protection and is your point of contact for any question or request about your personal data.
2. The Personal Data We Collect
Depending on your relationship with us, we may collect the following categories of personal data:
Enquiry and contact data: your name, email address, telephone number, and the content of your enquiry, including travel dates, party composition, and preferences.
Booking and traveller data: the full names (as shown on passports), dates of birth, nationality, passport numbers and expiry dates, home address, and emergency contact details of every member of your party.
Special category data: health, dietary, mobility, or medical information that you choose to share so that we can arrange suitable services or respond to an emergency. We collect this only where you provide it and only to the extent needed.
Financial data: payment records and confirmations. Card payments are processed by our payment provider and by Protected Trust Services; we do not store full card numbers.
Insurance data: the policy details you provide to evidence that this condition of booking has been met.
Correspondence: records of our communications with you, including emails, messages, and call notes.
Technical data: if you use our website, limited technical data such as your IP address and pages visited, collected through our website platform and any cookies described in section 9.
Where you provide personal data about other members of your party, you confirm that you have their authority to do so and that you have made them aware of this policy.
3. How We Process Your Data and Our Lawful Bases for doing so
Under the UK GDPR, we must have a lawful basis for processing your personal data. We rely on the following:
Purpose
Lawful basis
Responding to your enquiry and preparing a quotation or itinerary
Steps taken at your request before entering a contract; our legitimate interest in responding to enquiries
Taking and administering your booking, arranging your travel services, and providing support before, during, and after your trip
Performance of our contract with you
Sharing necessary traveller data with the Ground Operator and accommodation providers in Tanzania
Performance of our contract with you
Processing payments and meeting our trust-account and financial-protection obligations
Performance of our contract; compliance with a legal obligation
Using health, dietary, or medical information to arrange suitable services or respond to an emergency
Compliance with a legal obligation; your explicit consent, or protection of vital interests in an emergency
Keeping accounting and tax records and meeting regulatory duties under the Package Travel Regulations
Compliance with a legal obligation
Handling complaints, disputes, and insurance or legal claims
Compliance with a legal obligation
Sending you occasional updates about Makoma, where you have asked to receive them
Your consent, which you may withdraw at any time
Where we rely on legitimate interests, we have balanced those interests against your rights and are satisfied that our use of your data is proportionate and does not override your interests. You may object to processing based on legitimate interests as described in section 7.
Special category data. Health, medical, mobility, dietary and other sensitive information is special category data and attracts additional protection. We process it only where one or more of the following conditions is met: you have given your explicit consent; the processing is necessary to protect your or another person's vital interests where you are physically or legally incapable of giving consent (for example, in a medical emergency on safari); or the processing is necessary for the establishment, exercise, or defence of a legal claim. We collect the minimum data needed, share it only with those who need it to keep you safe and deliver your trip, and delete it promptly after your trip unless it is needed for an ongoing claim. You may withdraw your consent at any time, although this may affect our ability to arrange or adjust certain services for you. The withdrawal of your consent does not affect our entitlement to process personal data for which another legal basis exists.
4. Who We Share Your Data With
We share your personal data only where necessary, with:
Serengeti Wilderness Calls (or any alternative ground handler we may use), our Ground Operator in Arusha, Tanzania, and the accommodation providers, camps, and transfer services that deliver your safari, so that they can perform the travel services in your package.
Protected Trust Services (PTS), which administers the trust account that holds and protects your money and provides our insolvency protection. We share with PTS the booking and payment information needed to operate the trust account and, in the event of a claim, to arrange a refund or repatriation.
Our payment provider, which processes card and bank payments securely.
Our professional advisers, including our accountants (BCG Financial), insurance brokers (James Hallam), and, where needed, legal advisers.
Authorities and regulators, where we are required by law to disclose information.
We do not sell your personal data, and we do not share it with third parties for their own marketing.
Personal data about other members of your party. Where the lead traveller gives us personal data about other people in the party, we obtain that data from the lead traveller rather than directly from each person. We are entitled to assume that the lead traveller has the authority of the party members to provide their personal data to us. The lead traveller is asked to provide confirmation that they have this authority. If you are a member of a party whose booking was made by someone else and you would like to know how we use your data or exercise your rights, please contact us using the details in section 1.
Automated decision-making. We do not make decisions about you based solely on automated processing, and we do not carry out profiling that produces legal or similarly significant effects.
5. International Transfers
To deliver your safari, we transfer necessary traveller data to our Ground Operator and accommodation providers in Tanzania. Tanzania is outside the UK and is not currently the subject of UK adequacy regulations. Where we make such a transfer we put in place an appropriate safeguard, normally the UK International Data Transfer Agreement or the International Data Transfer Addendum to the European Commission's standard contractual clauses, or we rely on a relevant exception in the UK GDPR, in particular that the transfer is necessary for the performance of our contract with you. You may ask us for a copy of the safeguard we use.
Where the data transferred to Tanzania includes special category data, for example a dietary or medical requirement that a lodge or your guide needs to know about, we transfer only the minimum necessary for your safety and care, under the same safeguard, and on the basis of your explicit consent or the protection of your vital interests. We will tell you if a particular requirement cannot be accommodated without sharing such information.
6. How Long We Keep Your Data
We keep your personal data only for as long as necessary for the purposes set out in this policy:
Enquiries that do not lead to a booking: normally up to 24 months, then deleted.
Booking and financial records: for the duration of your trip and then for 6 years after the end of the relevant tax year, to meet accounting, tax, and limitation-period requirements.
Special category (health and other sensitive) data: deleted promptly after your trip is completed, unless needed for an ongoing claim.
Marketing consents: until you withdraw consent, after which we retain a minimal record of your withdrawal so that we can honour it.
7. Your Rights
Under the UK GDPR, you have the right to:
be informed about how we use your data (this policy);
request access to a copy of the personal data we hold about you;
ask us to correct inaccurate or incomplete data;
ask us to erase your data where there is no good reason for us to keep it;
ask us to restrict processing in certain circumstances;
object to processing based on our legitimate interests, and to object to direct marketing at any time;
request the transfer of certain data to you or another controller (data portability); and
withdraw consent at any time where we rely on consent, without affecting processing already carried out.
To exercise any of these rights, contact us using the details in section 1. We will respond within one month. There is normally no charge, although we may charge a reasonable fee or refuse a request that is manifestly unfounded or excessive. We may need to verify your identity before acting.
8. Your Right to Complain
If you are unhappy with how we have handled your personal data, please tell us first so that we can try to put it right. You also have the right to complain to the Information Commissioner's Office (ICO), the UK supervisory authority, at www.ico.org.uk, by telephone on 0303 123 1113, or by post to Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
9. Cookies and Our Website
Our website is hosted on the Squarespace platform. It uses a limited number of cookies that are necessary for the site to function and, where you agree, cookies that help us understand how the site is used. You can control non-essential cookies through the cookie banner on the site and through your browser settings. Disabling some cookies may affect how the website works.
10. Changes to This Policy
We may update this policy from time to time. The current version is always available on our website, and the date at the top shows when it was last revised. Where changes are significant we will take reasonable steps to bring them to your attention.
Makoma Expeditions Ltd | Company No. 16976519 | Registered in England and Wales | Registered office: c/o BCG Financial, 111 South Road, Waterloo, Liverpool, L22 0LT | jake@makomaexpeditions.com | +44 (0) 7397 120320 | www.makomaexpeditions.com