Trafalgar Privacy Policy

Last updated: March 2020


1. About This Policy

This document sets out our privacy policy in respect of your personal information, which governs the way we collect, use and protects any personal information that you provide to us. It serves as an expression of our commitment to protecting your personal information, but is not a contract between you and us. Please see Section 18 below for your rights in relation to your personal information.

2. Your Consent

By using our websites, social media channels, posting comments in any forum, providing personal information, making enquires for travel services, creating an online account or booking any travel services with us, you confirm that you agree and consent to the terms of this document and use of your personal information, to the extent that your consent is required by any applicable law.


3. Copyright Notice

This document, all content of our websites - Copyright© 2020 Trafalgar Tours Pty Ltd. ALL RIGHTS RESERVED.


4. About Us

This is the privacy policy of Trafalgar Tours (Australia) Pty Ltd ACN 73 000 717 715 trading as Trafalgar Tours (Australia) Pty Ltd (referred to as "we", "us" or "our").  We are incorporated under the laws of New South Wales. Our registered office is Travel House, Level 2, 35 Grafton Street, Bondi Junction, NSW 2022.

 

5. Contacting Us

If you have any questions about our privacy policy or how we process your personal information, including complaints, either e-mail - privacy@trafalgartours.com.au or by post to Travel House, Level 2, 35 Grafton Street, Bondi Junction, NSW 2022.


6. Our Commitment

We respect your right to privacy, we aim to ensure you have a trustworthy experience with us, when using our websites, shops and booking with or through us. We understand that you care about how your personal information is used, we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information that you entrust to us.


7. Who Our Privacy Policy Covers

7.1         Our customers

Our privacy policy sets out how we process personal information. Relating to individuals who are booking, enquiring about booking, or who are the recipients of any travel services booked with or through us.

7.2         Examples

            In this privacy policy, including personal information we process:

(1) Individuals who are making an enquiry or booking, with us. Individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers, employees of businesses and organisation’s and agents);

(2) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or organisation, individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;

(3) Individuals who visit our website or online sites operated by us or contractors or affiliates;

(4) Individuals who create an online account (if applicable);

(5) Individuals whose personal information from other companies in our group (where you have consented to your personal information being disclosed to other group companies for marketing purposes);

(6) Individuals or businesses from any other arrangement with us.

7.3         When we are an information processor only

This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account.  In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

7.4         Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to “process” or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, charters, it includes both

(1) All products and services which we supply or operate ourselves (including where we sub-contract);

(2) Products and services provided by a third party whom we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, obtaining visas, foreign exchange, providing local representatives and support.

8. What Laws We Comply with

8.1         Privacy Laws

We process your personal information in accordance with the following privacy law(s): the Australian Privacy Principles contained in the Privacy Act, 1988 which regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. Our regulator is the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au/)

8.2         Other Laws

We also comply generally with the laws of Australia, in relation, to the processing of your personal information.

 

9. What Types Of Personal Information We Process

Summarises the types of personal information that we process:-

9.1         Individual Information

Includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proof of identity, address, copy of passport, driving licenses, payment details,  financial information, health information relevant to your planned travel, travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation with member number, and any other information provided to us by or in relation to you..

9.2         Sensitive Information

In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we will assume that when you provide such information to us, you have consented to our collection and use of it In accordance with this policy.

9.3         Business Related Information

If you are an individual associated with a business or other organisation that is our customer,  then your personal information may include the following information that we link to you: business or organisation details (name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (owner, partner, director, shareholder, employee, or agent), and your contact details within that business (work address, work telephone and mobile numbers, work fax number, and work e-mail address).

9.4         Enquiry and Booking

            Information concerning enquiries and bookings made with or through us, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries, searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

9.5         Performance

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

9.6         Survey Information

Information collected or generated out of any surveys we conduct.

9.7         Feedback

Information provided by you in relation to your feedback or experience on a past current or future trip with us.

9.8         Competition

Information collected or generated out of any competitions or promotions we run.

9.9         Account, Registration and Loyalty

Information concerning accounts, registrations, memberships or participation in any loyalty program.

9.10      Correspondence

Our correspondence, communications and any messages between us and third parties, relating to any booking, enquiry or performance of any contract.

9.11      Social Media

Any information you post on our social media channel or any forum which relates to us.

9.12      Website Usage

We may collect information about your visits, browsing, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.

This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); time-zone; browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.

This information may also include: information inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

 

10. How we collect or Generate Your Personal Information

10.1         Visiting our website

By visiting and using our website you or your computer may provide personal information. This includes:  information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. 

10.2         Information you provide

Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; filing in any field or form on a website; posting on our social media channel; posting on any forum referencing us; filling in any printed form we provide you with; e-mail; from documents you provide us with; and updates you provide from time to time.  This includes when you: register or subscribe for any service, account, members, or loyalty program, make an enquiry or booking  for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

10.3         Information - Third parties

We may obtain personal information concerning you from third parties, including: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

10.4         Information generated by us

We and suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

11. What Do We Use Your Personal Information For?

11.1      Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites.  This includes customising your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

11.2      Provide information and respond to enquiries

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

11.3      Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings,  orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

11.4      Payments

Collecting and making payments due and administering our accounts.

11.5      Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

11.6      Record Keeping

To keep internal records, maintain reasonable archives, as to enquiries, bookings, contracts, travel services, and complaints. 

11.7      Manage and Improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, systems and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers.

11.8      Direct marketing

To carry our direct marketing to you. 

11.9      Advertising

Report on aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.

11.10   Legal obligations

We will meet our legal obligations.

11.11   Anything you have specifically consented to

Will be included.

 

12. Use Of Your Personal Information For Direct Marketing

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

12.1      Our Direct marketing

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us. 

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive.

12.2      Direct Marketing - Third Parties

Where you have consented to this, we may disclose your personal information which is contact information (name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us.  They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

 

13. Disclosure Of Your Personal Information

13.1      Bookings and performance contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you.  This may include; applying for visas on your behalf, collecting payments made by you, investigating and responding to complaints, to enforce any booking or other contract with you. Third parties may include any suppliers, sub-contractors, their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

13.2      Suppliers of travel and services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

13.3      Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer.  Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

13.4      Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

13.5      Public forums etc.

Where any facility on our website is clearly designed to make some of your personal information public (e.g. posts you make to any public forum or reviews facility) than any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

13.6      Legal requirements

We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract.  We may disclose your personal information where otherwise required by or permitted by law.  

13.7      Direct Marketing by third parties

We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing.  See the direct marketing section above.

13.8      Customer Representatives

If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information.   If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

13.9      Business acquirers

If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

14. How Third Parties Will Handle Your Personal Information

14.1      Processing on our behalf

In some cases, your personal information may be held and otherwise processed by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and processed by them in accordance with our instructions and this privacy policy.

14.2      Processing on their own account

In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

 

15. Location Of Your Personal Information

15.1      Transfer of personal information overseas

We (any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to:

(1) Our overseas offices;

(2) Information processors (including operators of global travel distribution systems);

(3) Airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

15.2      Counties to which your personal information is transferred

The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

16. Keeping Your Data Secure

16.1      Our security measures

16.1.1      Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

16.1.2      Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

16.1.3      Storage of your personal information

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

16.2       Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about whom you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

17. How Long Do We Keep Your Personal Information For?

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

 

18. Your Rights

Our privacy policy is not intended to create a contract or form part of any contract. You have certain non-contractual rights under the laws noted above, which we summarize below. If you contact us about these rights, we may ask for proof of your identity before we act, and may refuse to act if you do not provide this or your identity is not established by you.

18.1      Access to your personal information

We will, on written request, provide you with access to information we hold about you, including for the purpose of correcting or updating such information, unless there is an exception which applies under the Privacy Act, 1988. Your request for access will be dealt with in a reasonable time and we may recover from your our reasonable expenses incurred.

If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.

18.2      Use for direct marketing

You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or email us at privacy@trafalgartours.com.au. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

18.3      Correction of inaccuracies

We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date.

If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.

18.4      Complaints to applicable authority

The laws we comply with are regulated by the Australian Information Commissioner.  In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator.  However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

For more information on privacy, you can contact the Australian Information Commissioner’s hotline on 1300 363 992 or if outside of Australia + 61 2 9284 9749, or visit the Office of the Australian Information Commissioner website at http://www.oaic.gov.au/.

 

19. Changes to this Privacy Policy

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes.  You should check the top of the document to see the latest version in force.  Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

20. Applicable Law and Disputes
This policy is subject to the law of Australia. You may obtain further information regarding privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.oaic.gov.au/.

 

21. Linked Websites

Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.

Contiki Privacy Policy

(PRIVACY POLICY – Aus)

Last updated: October 2019

 

1. ABOUT THIS POLICY

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your information.

This privacy notice supplements other notices and is not intended to override them.

 

2. OUR COMMITMENT

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

 

3. ABOUT US

This is the privacy policy of BRAND trading as Contiki Holidays (referred to as "we", "us" or "our"). We are incorporated under the laws of New South Wales. Our registered office Travel House, Level 3, 35 Grafton St, Bondi Junction NSW 2022. We are a member of ATAS and IATA

 

4. YOUR CONSENT

By using our websites, using our social media channels, posting comments about us in any forum, providing any personal information to us, making enquiries with us for travel services, creating an online account or booking any travel services with us, you confirm that you agree to and consent to the terms of this document and our collection and use of your personal information, to the extent that your consent is required by any applicable law.

 

5. WHO OUR PRIVACY POLICY COVERS

• Our customersOur privacy policy sets out how we process personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.
• Examples of who this policy coversWe include in this privacy policy personal information we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and travel group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online sites operated by us or our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.
• When we are an information processor only This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

5.4 Terms used in this policy When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to “process” or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, trips, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

 

6. WHAT LAWS WE COMPLY WITH

6.1     Privacy Laws We process your personal information in accordance with the following privacy law(s): the Australian Privacy Principles contained in the Privacy Act, 1988 which regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. Our regulator is the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au/)

6.2 Other laws We also comply generally with the laws of Australia in relation to the processing of your personal information, and the GDPR in situations where we process personal information involving EU data subjects.

 

7. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarises the types of personal information about you that we process:-

7.1 Information concerning you as an individual This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

7.2 Sensitive Information In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we assume that when you provide such information to us, you have consented to our collection and use of it in accordance with this policy.

7.3 Business Related Information If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

7.4 Enquiry and Booking Information Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. travel operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

7.5 Performance Information Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

7.6 Survey Information Information collected or generated out of any surveys we conduct.

7.7 Feedback and user generated content (UGC) Information or content provided by you in relation to your feedback or experience on a past current or future trip with us.

7.8 Competition Information Information collected or generated out of any competitions or promotions we run.

7.9 Account, Registration and Loyalty Information Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

7.10 Correspondence Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

7.11 Social Media Any information (including your social media user details, feedback, comments and photos) you post on our social media channel or any forum which relates to us.

7.12 Website Usage Information We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.

This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally. This information may also include: information inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this privacy policy.

 

8. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION

This section sets out the ways in which we may collect or generate personal information concerning you.

8.1 Visiting our website By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

Cookies - Cookies collect information that includes the server your computer is logged onto, your browser type and how you gained entry to our website. Therefore, when you visit our website anonymously, details are recorded about your visit, such as, in addition to the matters described in the previous paragraph, time and date, pages accessed and time spent. This information is used in an anonymous form for statistical purposes and as such, cannot be used to identify you individually. A cookie cannot retrieve any other information from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable information. You should note that accepting cookies is required if you want to view our websites, because they are essential for our site administration and security. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimize your visit to our site and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.

8.2 Information you provide Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

8.3 User Generated Content (UGC)

We may process, information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. These could include any marketing activities such as: 

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives

Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

8.4 Information obtained from third parties We may obtain personal information concerning you from third parties, including from: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us

8.5 Information generated by us We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

 

9. WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

This section sets out the uses which we make of your personal information:

9.1 Operate our website To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customising your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

9.2 Provide information and respond to enquiries To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

9.3 Bookings and other contracts To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

9.4 Payments To collect and make payments due and administer our accounts.

9.5 Communication with customers To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

9.6 Record keeping To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

9.7 Manage and Improve our business To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

9.8 Direct marketing To carry out direct marketing to you. See next section below for further information.

9.9 Use of Reviews: By submitting content to our website by electronic mail, postings on our website or otherwise, including any reviews, questions, comments, suggestions, ideas, photos or the like contained in any submissions (collectively, “Submissions”), you grant Contiki Holidays and its affiliates a nonexclusive, royalty-free, perpetual, transferable, irrevocable and fully sub-licensable right to (a) use, reproduce, modify, adapt, translate, distribute, publish, create derivative works from and publicly display and perform such Submissions throughout the world in any media, now known or hereafter devised; and (b) use the name that you submit in connection with such Submission.

9.10 Use of User Generated Content (UGC)

By submitting content to our social media channels or websites you grant us a non-exclusive licence to use the content you add to our websites.  For example, we may use this information in any of our brochures or for our campaigning purposes or marketing materials.

9.11 Advertising To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.

9.12 Anything you have specifically consented to For any purpose which we have obtained your consent to.

9.13 Consequences of not providing your Information You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Sometimes, providing your information to authorities when you travel is a legal obligation for us.

 

10. USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

10.1 Direct marketing by us Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

10.2 Direct marketing by third parties Where you have consented to this, we may disclose your personal information which is contact information (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

 

11. DISCLOSURE OF YOUR PERSONAL INFORMATION

We transfer your personal information to third parties in the following circumstances:-

11.1 Bookings and performance of contracts We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, travel operators etc.).

11.2 Suppliers of travel and other services We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, trip or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a travel operator. Details of any third party travel operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any trip or other brochure provided by us.

11.3 Insurance If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

11.4 Business Function Outsourcing Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

11.5 Public Forums etc. Where any facility on our website is clearly designed to make some of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

11.6 Legal Requirements We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

11.7 Direct Marketing by third parties We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

11.8 Customer Representatives If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.9 Business acquirers If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

 

12. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION

Where we provide your personal information to a third party one of the following two circumstances will apply:-

12.1 Processing on our behalf In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

12.2 Processing on their own account In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

 

13. LOCATION OF YOUR PERSONAL INFORMATION

13.1 Transfer of personal information overseas We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

13.2 Counties to which your personal information is transferred
The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

 

14. KEEPING YOUR INFORMATION SECURE

14.1 Our security measures

14.1.1 Our general commitment We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

14.1.2 Transmissions between your web browser and our servers We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

14.1.3 Storage of your personal information The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

14.2 Your security measures For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

 

15. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

 

16. YOUR RIGHTS

16.1 Access to your personal data Our privacy policy is not intended to create a contract or form part of a contract. You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure.  More information about your rights and our obligations can be found on https://www.oaic.gov.au/privacy-law/privacy-act/ which we summarize below. If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.

You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

To exercise any of your rights below, please contact us as per the contact details provided. You can also exercise some of these rights directly through our online form at https://ttc.com/personal-data-request/

16.2 Use for direct marketing You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us by phone on 1300 266 845 or email us at marketing@contiki.com.au. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

16.3 Correction of inaccuracies We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date.

If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.

16.4 Complaints to applicable authority The laws we comply with are regulated by the Australian Information Commissioner. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

 

17. CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website.  You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes.  You should check the top of the document to see the latest version in force.  Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

 

18. APPLICABLE LAW AND DISPUTES

This policy is subject to the law of Australia. You may obtain further information regarding privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.oaic.gov.au/.

19. LINKED WEBSITES

Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.

 

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal information, including any complaints, please contact us either by e-mail to marketing@contiki.com.au, telephone on 1300 266 845, or by post to Travel House, Level 3, 35 Grafton St, Bondi Junction NSW 2022. You may also email compliance@ttc.com for all data protection and privacy matters.

 

COPYRIGHT NOTICE

This document, and all content of our websites is Copyright© 2019 Contiki Holidays. ALL RIGHTS RESERVED.

Insight Vacations Privacy Policy

Last updated: December 2019

 

1. ABOUT THIS DOCUMENT

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your information.

This privacy notice supplements other notices and is not intended to override them.

 

2. OUR COMMITMENT

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

 

3. ABOUT US

This is the privacy policy of Insight Vacations (referred to as "we", "us" or "our"). We are incorporated under the laws of applicable jurisdiction. Our registered office 35 Grafton Street, Bondi Junction NSW 2022. [We are a member of ABTA (Y181X) and licensed by the Civil Aviation Authority (10148).]

 

4. YOUR CONSENT

By using our websites, using our social media channels, posting comments about us in any forum, providing any personal information to us, making enquiries with us for travel services, creating an online account or booking any travel services with us, you confirm that you agree to and consent to the terms of this document and our collection and use of your personal information, to the extent that your consent is required by any applicable law.

 

5. CONTACTING US

5.1 Our customersOur privacy policy sets out how we process personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

5.2 Examples of who this policy covers We include in this privacy policy personal information we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and travel group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online sites operated by us or our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.

5.3 When we are an information processor only This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

5.4 Terms used in this policy When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to “process” or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, trips, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

 

6. WHAT LAWS WE COMPLY WITH

6.1 Privacy Laws We process your personal information in accordance with the following privacy law(s): the Australian Privacy Principles contained in the Privacy Act, 1988 which regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. Our regulator is the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au/)

6.2 Other laws We also comply generally with the laws of Australia in relation to the processing of your personal information, and the GDPR in situations where we process personal information involving EU data subjects.

 

7. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarises the types of personal information about you that we process:-

7.1 Information concerning you as an individual This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

7.2 Sensitive Information In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we assume that when you provide such information to us, you have consented to our collection and use of it in accordance with this policy.

7.3 Business Related Information If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

7.4 Enquiry and Booking Information Information Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. travel operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

7.5 Performance Information Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

7.6 Survey Information Information collected or generated out of any surveys we conduct.

7.7 Feedback and user generated content (UGC) Information or content provided by you in relation to your feedback or experience on a past current or future trip with us.

7.8 Competition Information collected or generated out of any competitions or promotions we run.

7.9 Account, Registration and Loyalty Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

7.10 Correspondence Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

7.11 Social Media Any information (including your social media user details, feedback, comments and photos) you post on our social media channel or any forum which relates to us.

7.12 Website Usage Information We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.

This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally. This information may also include: information inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this privacy policy.

 

8. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION

This section sets out the ways in which we may collect or generate personal information concerning you.

8.1 Visiting our website By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

Cookies - Cookies collect information that includes the server your computer is logged onto, your browser type and how you gained entry to our website. Therefore, when you visit our website anonymously, details are recorded about your visit, such as, in addition to the matters described in the previous paragraph, time and date, pages accessed and time spent. This information is used in an anonymous form for statistical purposes and as such, cannot be used to identify you individually. A cookie cannot retrieve any other information from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable information. You should note that accepting cookies is required if you want to view our websites, because they are essential for our site administration and security. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimize your visit to our site and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.

8.2 Information you provide Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures. If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

8.3 User Generated Content (UGC) We may process, information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. These could include any marketing activities such as:

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives.

 

Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

8.4 Information obtained from third parties We may obtain personal information concerning you from third parties, including from: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

8.5 Information generated by us We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

 

9.WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

This section sets out the uses which we make of your personal information:-

9.1 Operate our website To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customising your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

9.2 Provide information and respond to enquiries To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

9.3 Bookings and other contracts To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

9.4 Payments To collect and make payments due and administer our accounts.

9.5 Communication with customers To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

9.6 Record keeping To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

9.7 Manage and Improve our business To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

9.8 Direct marketing To carry out direct marketing to you. See next section below for further information.

9.9 Use of Reviews: By submitting content to our website by electronic mail, postings on our website or otherwise, including any reviews, questions, comments, suggestions, ideas, photos or the like contained in any submissions (collectively, “Submissions”), you grant Insight Vacations and its affiliates a nonexclusive, royalty-free, perpetual, transferable, irrevocable and fully sub-licensable right to (a) use, reproduce, modify, adapt, translate, distribute, publish, create derivative works from and publicly display and perform such Submissions throughout the world in any media, now known or hereafter devised; and (b) use the name that you submit in connection with such Submission.

9.10 Use of User Generated Content (UGC) By submitting content to our social media channels or websites you grant us a non-exclusive licence to use the content you add to our websites. For example, we may use this information in any of our brochures or for our campaigning purposes or marketing materials.

9.11 Advertising To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.

9.12 Anything you have specifically consented to For any purpose which we have obtained your consent to.

9.13 Consequences of not providing your Information You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Sometimes, providing your information to authorities when you travel is a legal obligation for us.

 

10. USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

10.1 Direct marketing by us Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

10.2 Direct marketing by third parties Where you have consented to this, we may disclose your personal information which is contact information (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

 

11. DISCLOSURE OF YOUR PERSONAL INFORMATION

We transfer your personal information to third parties in the following circumstances:

11.1 Bookings and performance of contracts We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, travel operators etc.).

11.2 Suppliers of travel and other services We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, trip or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a travel operator. Details of any third party travel operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any trip or other brochure provided by us.

11.3 Insurance If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

11.4 Business Function Outsourcing Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

11.5 Public Forums etc. Where any facility on our website is clearly designed to make some of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

11.6 Legal Requirements We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

11.7 Direct Marketing by third parties we may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

11.8 Customer Representatives If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.9 Business acquirers If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

 

12. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION

Where we provide your personal information to a third party one of the following two circumstances will apply:

12.1 Processing on our behalf In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

12.2 Processing on their own account In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

 

13. LOCATION OF YOUR PERSONAL INFORMATION

We transfer your personal information to third parties in the following circumstances:-

13.1 Transfer of personal information overseas We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

13.2 Counties to which your personal information is transferred The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

 

14. KEEPING YOUR INFORMATION SECURE

14.1 Our security measures

14.1.1 Our general commitment We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

14.1.2 Transmissions between your web browser and our servers We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

14.1.3 Storage of your personal information The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

14.2 Your security measures For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about whom you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

 

15. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

 

16. YOUR RIGHTS

16.1 Access to your personal data Our privacy policy is not intended to create a contract or form part of a contract. You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on https://www.oaic.gov.au/privacy-law/privacy-act/ which we summarize below. If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.

You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

To exercise any of your rights below, please contact us as per the contact details provided. You can also exercise some of these rights directly through our online form at https://ttc.com/personal-data-request/

16.2 Use for direct marketing You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us by phone on brand phone number or email us at marketing@insightvacations.com.au. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

16.3 Correction of inaccuracies We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date. If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.

16.4 Complaints to applicable authority The laws we comply with are regulated by the Australian Information Commissioner. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

 

17. CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes. You should check the top of the document to see the latest version in force. Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

 

18. APPLICABLE LAW AND DISPUTES

This policy is subject to the law of Australia. You may obtain further information regarding privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.oaic.gov.au/.

 

19. LINKED WEBSITES

Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.

 

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal information, including any complaints, please contact us either by e-mail to marketing@insightvacations.com.au, telephone on 1800 001 778 or by post to 35 Grafton Street, Bondi Junction NSW 2022. You may also email compliance@ttc.com for all data protection and privacy matters.

 

21. COPYRIGHT NOTICE

This document, and all content of our websites is Copyright© brand legal name. ALL RIGHTS RESERVED.

Uniworld Privacy Policy

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Luxury Gold Privacy Policy

 

1. ABOUT THIS DOCUMENT

This document (our “privacy policy”) sets out information into how we use personal information relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your information.

This privacy notice supplements other notices and is not intended to override them.

 

2. OUR COMMITMENT

We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

 

3. ABOUT US

This is the privacy policy of Luxury Gold trading as Insight Vacations PTY LTD (referred to as "we", "us" or "our").We are incorporated under the laws of applicable jurisdiction. Our registered office 35 Grafton Street, Bondi Junction NSW 2022. [We are a member of ABTA (Y181X) and licensed by the Civil Aviation Authority (10148).]

 

4. YOUR CONSENT

By using our websites, using our social media channels, posting comments about us in any forum, providing any personal information to us, making enquiries with us for travel services, creating an online account or booking any travel services with us, you confirm that you agree to and consent to the terms of this document and our collection and use of your personal information, to the extent that your consent is required by any applicable law.

 

5. CONTACTING US

5.1 Our customersOur privacy policy sets out how we process personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

5.2 Examples of who this policy covers We include in this privacy policy personal information we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and travel group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online sites operated by us or our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.

5.3 When we are an information processor only This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

5.4 Terms used in this policy When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to “process” or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, trips, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

 

6. WHAT LAWS WE COMPLY WITH

6.1 Privacy Laws We process your personal information in accordance with the following privacy law(s): the Australian Privacy Principles contained in the Privacy Act, 1988 which regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. Our regulator is the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au/)

6.2 Other laws We also comply generally with the laws of Australia in relation to the processing of your personal information, and the GDPR in situations where we process personal information involving EU data subjects.

 

7. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarises the types of personal information about you that we process:-

7.1 Information concerning you as an individual This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

7.2 Sensitive Information In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we assume that when you provide such information to us, you have consented to our collection and use of it in accordance with this policy.

7.3 Business Related Information If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

7.4 Enquiry and Booking Information Information Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. travel operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

7.5 Performance Information Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

7.6 Survey Information Information collected or generated out of any surveys we conduct.

7.7 Feedback and user generated content (UGC) Information or content provided by you in relation to your feedback or experience on a past current or future trip with us.

7.8 Competition Information collected or generated out of any competitions or promotions we run.

7.9 Account, Registration and Loyalty Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

7.10 Correspondence Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

7.11 Social Media Any information (including your social media user details, feedback, comments and photos) you post on our social media channel or any forum which relates to us.

7.12 Website Usage Information We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.

This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally. This information may also include: information inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this privacy policy.

 

8. HOW WE COLLECT OR GENERATE YOUR PERSONAL INFORMATION

This section sets out the ways in which we may collect or generate personal information concerning you.

8.1 Visiting our website By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website.

Cookies - Cookies collect information that includes the server your computer is logged onto, your browser type and how you gained entry to our website. Therefore, when you visit our website anonymously, details are recorded about your visit, such as, in addition to the matters described in the previous paragraph, time and date, pages accessed and time spent. This information is used in an anonymous form for statistical purposes and as such, cannot be used to identify you individually. A cookie cannot retrieve any other information from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable information. You should note that accepting cookies is required if you want to view our websites, because they are essential for our site administration and security. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimize your visit to our site and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.

8.2 Information you provide Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you with; by e-mail; from documents you provide use with; and from updates to any information to provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures. If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

8.3 User Generated Content (UGC) We may process, information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. These could include any marketing activities such as:

Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives.

Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

8.4 Information obtained from third parties We may obtain personal information concerning you from third parties, including from: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

8.5 Information generated by us We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

 

9.WHAT DO WE USE YOUR PERSONAL INFORMATION FOR?

This section sets out the uses which we make of your personal information:-

9.1 Operate our website To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customising your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

9.2 Provide information and respond to enquiries To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

9.3 Bookings and other contracts To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

9.4 Payments To collect and make payments due and administer our accounts.

9.5 Communication with customers To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

9.6 Record keeping To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

9.7 Manage and Improve our business To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

9.8 Direct marketing To carry out direct marketing to you. See next section below for further information.

9.9 Use of Reviews: By submitting content to our website by electronic mail, postings on our website or otherwise, including any reviews, questions, comments, suggestions, ideas, photos or the like contained in any submissions (collectively, “Submissions”), you grant Luxury Gold and its affiliates a nonexclusive, royalty-free, perpetual, transferable, irrevocable and fully sub-licensable right to (a) use, reproduce, modify, adapt, translate, distribute, publish, create derivative works from and publicly display and perform such Submissions throughout the world in any media, now known or hereafter devised; and (b) use the name that you submit in connection with such Submission.

9.10 Use of User Generated Content (UGC) By submitting content to our social media channels or websites you grant us a non-exclusive licence to use the content you add to our websites. For example, we may use this information in any of our brochures or for our campaigning purposes or marketing materials.

9.11 Advertising To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.

9.12 Anything you have specifically consented to For any purpose which we have obtained your consent to.

9.13 Consequences of not providing your Information You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Sometimes, providing your information to authorities when you travel is a legal obligation for us.

 

10. USE OF YOUR PERSONAL INFORMATION FOR DIRECT MARKETING

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

10.1 Direct marketing by us Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

10.2 Direct marketing by third parties Where you have consented to this, we may disclose your personal information which is contact information (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

 

11. DISCLOSURE OF YOUR PERSONAL INFORMATION

We transfer your personal information to third parties in the following circumstances:

11.1 Bookings and performance of contracts We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; applying for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, travel operators etc.).

11.2 Suppliers of travel and other services We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, trip or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a travel operator. Details of any third party travel operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any trip or other brochure provided by us.

11.3 Insurance If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

11.4 Business Function Outsourcing Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

11.5 Public Forums etc. Where any facility on our website is clearly designed to make some of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

11.6 Legal Requirements We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

11.7 Direct Marketing by third parties we may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

11.8 Customer Representatives If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.9 Business acquirers If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

 

12. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL INFORMATION

Where we provide your personal information to a third party one of the following two circumstances will apply:

12.1 Processing on our behalf In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

12.2 Processing on their own account In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

 

13. LOCATION OF YOUR PERSONAL INFORMATION

We transfer your personal information to third parties in the following circumstances:-

13.1 Transfer of personal information overseas We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

13.2 Counties to which your personal information is transferred The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

 

14. KEEPING YOUR INFORMATION SECURE

14.1 Our security measures

14.1.1 Our general commitment We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

14.1.2 Transmissions between your web browser and our servers We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

14.1.3 Storage of your personal information The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

14.2 Your security measures For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about whom you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

 

15. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

 

16. YOUR RIGHTS

16.1 Access to your personal data Our privacy policy is not intended to create a contract or form part of a contract. You have certain rights under data protection laws, which we summarise below. If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on https://www.oaic.gov.au/privacy-law/privacy-act/ which we summarize below. If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.

You may request us to tell you whether we are processing personal data about you, to tell you what personal data we are processing and for what purposes, and to provide you with a copy of your personal data that we hold. The law does allow us, in certain cases to refuse your request, and we will advise you at the time if this is the case.

To exercise any of your rights below, please contact us as per the contact details provided. You can also exercise some of these rights directly through our online form at https://ttc.com/personal-data-request/

16.2 Use for direct marketing You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us by phone on brand phone number or email us at marketing@insightvacations.com.au. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

16.3 Correction of inaccuracies We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date. If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.

16.4 Complaints to applicable authority The laws we comply with are regulated by the Australian Information Commissioner. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

 

17. CHANGES TO THIS PRIVACY POLICY

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes. You should check the top of the document to see the latest version in force. Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.

 

18. APPLICABLE LAW AND DISPUTES

This policy is subject to the law of Australia. You may obtain further information regarding privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.oaic.gov.au/.

 

19. LINKED WEBSITES

Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.

 

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal information, including any complaints, please contact us either by e-mail to marketing@insightvacations.com.au, telephone on 1800 621 387, or by post to 35 Grafton Street, Bondi Junction NSW 2022. You may also email compliance@ttc.com for all data protection and privacy matters.

 

21. COPYRIGHT NOTICE

This document, and all content of our websites is Copyright© Luxury Gold. ALL RIGHTS RESERVED.

Costsaver Privacy Policy

Last updated: March 2020


1. About This Policy

This document sets out our privacy policy in respect of your personal information, which governs the way we collect use and protects any personal information that you provide to us. It serves as an expression of our commitment to protecting your personal information, but is not a contract between you and us. Please see Section 18 below for your rights in relation to your personal information.

2. Your Consent

By using our websites, social media channels, posting comments in any forum, providing personal information, making enquires for travel services, creating an online account or booking any travel services with us, you confirm that you agree and consent to the terms of this document and use of your personal information, to the extent that your consent is required by any applicable law.


3. Copyright Notice

This document, all content of our websites - Copyright© 2020 Trafalgar Tours Pty Ltd. ALL RIGHTS RESERVED.


4. About Us

This is the privacy policy of CostSaver trading as Trafalgar Tours (Australia) Pty Ltd ACN 73 000 717 715(referred to as "we", "us" or "our").  We are incorporated under the laws of New South Wales. Our registered office is Travel House, Level 2, 35 Grafton Street, Bondi Junction, NSW 2022.

 

5. Contacting Us

If you have any questions about our privacy policy or how we process your personal information, including complaints, either e-mail - privacy@trafalgartours.com.au or by post to Travel House, Level 2, 35 Grafton Street, Bondi Junction, NSW 2022.


6. Our Commitment

We respect your right to privacy, we aim to ensure you have a trustworthy experience with us, when using our websites, shops and booking with or through us. We understand that you care about how your personal information is used, we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information that you entrust to us.


7. Who Our Privacy Policy Covers

7.1         Our customers

Our privacy policy sets out how we process personal information. Relating to individuals who are booking, enquiring about booking, or who are the recipients of any travel services booked with or through us.

7.2         Examples

            In this privacy policy, including personal information we process:

(1) Individuals who are making an enquiry or booking, with us. Individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers, employees of businesses and organisation’s and agents);

(2) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or organisation, individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;

(3) Individuals who visit our website or online sites operated by us or contractors or affiliates;

(4) Individuals who create an online account (if applicable);

(5) Individuals whose personal information from other companies in our group (where you have consented to your personal information being disclosed to other group companies for marketing purposes);

(6) Individuals or businesses from any other arrangement with us.

7.3         When we are an information processor only

This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account.  In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

7.4         Terms used in this policy

When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

When we refer to “process” or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, charters, it includes both

(1) All products and services which we supply or operate ourselves (including where we sub-contract);

(2) Products and services provided by a third party whom we book for you (acting as agent for you or that third party). Travel services also include any services we or a third party provide in association with travel, obtaining visas, foreign exchange, providing local representatives and support.

8. What Laws We Comply with

8.1         Privacy Laws

We process your personal information in accordance with the following privacy law(s): the Australian Privacy Principles contained in the Privacy Act, 1988 which regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. Our regulator is the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au/)

8.2         Other Laws

We also comply generally with the laws of Australia, in relation, to the processing of your personal information.

 

9. What Types Of Personal Information We Process

Summarises the types of personal information that we process:-

9.1         Individual Information

Includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proof of identity, address, copy of passport, driving licenses, payment details,  financial information, health information relevant to your planned travel, travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation with member number, and any other information provided to us by or in relation to you..

9.2         Sensitive Information

In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we will assume that when you provide such information to us, you have consented to our collection and use of it In accordance with this policy.

9.3         Business Related Information

If you are an individual associated with a business or other organisation that is our customer,  then your personal information may include the following information that we link to you: business or organisation details (name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (owner, partner, director, shareholder, employee, or agent), and your contact details within that business (work address, work telephone and mobile numbers, work fax number, and work e-mail address).

9.4         Enquiry and Booking

            Information concerning enquiries and bookings made with or through us, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries, searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. tour operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

9.5         Performance

Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

9.6         Survey Information

Information collected or generated out of any surveys we conduct.

9.7         Feedback

Information provided by you in relation to your feedback or experience on a past current or future trip with us.

9.8         Competition

Information collected or generated out of any competitions or promotions we run.

9.9         Account, Registration and Loyalty

Information concerning accounts, registrations, memberships or participation in any loyalty program.

9.10      Correspondence

Our correspondence, communications and any messages between us and third parties, relating to any booking, enquiry or performance of any contract.

9.11      Social Media

Any information you post on our social media channel or any forum which relates to us.

9.12      Website Usage

We may collect information about your visits, browsing, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website.

This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); time-zone; browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally.

This information may also include: information inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website.

 

10. How we collect or Generate Your Personal Information

10.1         Visiting our website

By visiting and using our website you or your computer may provide personal information. This includes:  information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. 

10.2         Information you provide

Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; filing in any field or form on a website; posting on our social media channel; posting on any forum referencing us; filling in any printed form we provide you with; e-mail; from documents you provide us with; and updates you provide from time to time.  This includes when you: register or subscribe for any service, account, members, or loyalty program, make an enquiry or booking  for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures.

If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

10.3         Information - Third parties

We may obtain personal information concerning you from third parties, including: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

10.4         Information generated by us

We and suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

11. What Do We Use Your Personal Information For?

11.1      Operate our website

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites.  This includes customising your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

11.2      Provide information and respond to enquiries

To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

11.3      Bookings and other contracts

To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings,  orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

11.4      Payments

Collecting and making payments due and administering our accounts.

11.5      Communication with customers

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

11.6      Record Keeping

To keep internal records, maintain reasonable archives, as to enquiries, bookings, contracts, travel services, and complaints. 

11.7      Manage and Improve our business

To analyse, audit, provide, operate, administer, maintain and improve our business, systems and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers.

11.8      Direct marketing

To carry our direct marketing to you. 

11.9      Advertising

Report on aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.

11.10   Legal obligations

We will meet our legal obligations.

11.11   Anything you have specifically consented to

Will be included.

 

12. Use Of Your Personal Information For Direct Marketing

We do not use or disclose your personal information for direct marketing purposes unless we have obtained your consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

12.1      Our Direct marketing

Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us. 

Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive.

12.2      Direct Marketing - Third Parties

Where you have consented to this, we may disclose your personal information which is contact information (name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us.  They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

 

13. Disclosure Of Your Personal Information

13.1      Bookings and performance contracts

We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you.  This may include; applying for visas on your behalf, collecting payments made by you, investigating and responding to complaints, to enforce any booking or other contract with you. Third parties may include any suppliers, sub-contractors, their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.).

13.2      Suppliers of travel and services

We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator.  Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

13.3      Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer.  Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

13.4      Business Function Outsourcing

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

13.5      Public forums etc.

Where any facility on our website is clearly designed to make some of your personal information public (e.g. posts you make to any public forum or reviews facility) than any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

13.6      Legal requirements

We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract.  We may disclose your personal information where otherwise required by or permitted by law.  

13.7      Direct Marketing by third parties

We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing.  See the direct marketing section above.

13.8      Customer Representatives

If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information.   If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

13.9      Business acquirers

If our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

14. How Third Parties Will Handle Your Personal Information

14.1      Processing on our behalf

In some cases, your personal information may be held and otherwise processed by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and processed by them in accordance with our instructions and this privacy policy.

14.2      Processing on their own account

In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account.  In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

 

15. Location Of Your Personal Information

15.1      Transfer of personal information overseas

We (any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to:

(1) Our overseas offices;

(2) Information processors (including operators of global travel distribution systems);

(3) Airlines, hotels and other travel service products; and information technology and business service providers.

In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

15.2      Counties to which your personal information is transferred

The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

16. Keeping Your Data Secure

16.1      Our security measures

16.1.1    Our general commitment

We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

16.1.2    Transmissions between your web browser and our servers

We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

16.1.3    Storage of your personal information

The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

16.2       Your security measures

For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

We also encourage you to be careful about whom you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made.  Please let us know if you someone purports to contact you in our name.

17. How Long Do We Keep Your Personal Information For?

We keep your personal information for so long a is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

 

18. Your Rights

Our privacy policy is not intended to create a contract or form part of any contract. You have certain non-contractual rights under the laws noted above, which we summarize below. If you contact us about these rights, we may ask for proof of your identity before we act, and may refuse to act if you do not provide this or your identity is not established by you.

18.1      Access to your personal information

We will, on written request, provide you with access to information we hold about you, including for the purpose of correcting or updating such information, unless there is an exception which applies under the Privacy Act, 1988. Your request for access will be dealt with in a reasonable time and we may recover from your our reasonable expenses incurred.

If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.

18.2      Use for direct marketing

You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or email us at privacy@trafalgartours.com.au. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

18.3      Correction of inaccuracies

We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date.

If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.

18.4      Complaints to applicable authority

The laws we comply with are regulated by the Australian Information Commissioner.  In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator.  However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

For more information on privacy, you can contact the Australian Information Commissioner’s hotline on 1300 363 992 or if outside of Australia + 61 2 9284 9749, or visit the Office of the Australian Information Commissioner website at http://www.oaic.gov.au/.

 

19. Changes to this Privacy Policy

We may change this privacy policy at any time and from time to time without notice to you, including by publishing a new version on our website. You should check this privacy policy for updates each time you visit our website to be sure that you are aware of any changes.  You should check the top of the document to see the latest version in force.  Any change will be prospective only, and we will not make any changes that have retroactive effect unless legally required to do so.


20. Applicable Law and Disputes

This policy is subject to the law of Australia. You may obtain further information regarding privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.oaic.gov.au/.

 

21. Linked Websites

Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.

Inspiring Journeys Privacy Policy

Last updated 1 June 2020.

 

1. About This Policy

   This document (our “privacy policy”) sets out information into how we use personal information (also referred to as personal data) relating to people we interact with including, for example, customers and website users. It serves as an expression of our commitment to protecting your personal information. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal information collection and processing, so you are fully aware of how and why we are using your data. This privacy notice supplements other notices and is not intended to override them.

2. Our Commitment

   We respect your right to privacy and we aim to ensure you have a trustworthy experience with us, including when using our websites or shops and booking with or through us. We understand that you care about how your personal information is used by us, and we want to share with you the policies and practices we’ve adopted. This way you can feel confident about how we handle your personal information.

3. About Us

   This is the privacy policy of Inspiring Journeys trading as AAT KINGS TOURS LIMITED (referred to as "we", "us" or "our"). We are incorporated under the laws of Australia. Our registered office 82-86 Bourke Road Alexandria, NSW, 2015 AUSTRALIA. We are a member of ATAS (10527).

4. Our Legal Bases for Processing

   We will process your personal data in accordance with all applicable laws and applicable contractual obligations. More specifically, we will not process personal information unless at least one of the following requirements are met:

   You have given consent to the processing of your personal information for one or more specific purposes (for instance, for tailored offers to your interests, for sharing of your photos/videos of experiences of our trips on social media and sharing emails of co passengers, that have agreed to stay in touch);

   The processing is necessary for the performance of a contract to which you are party (for instance, for booking you have made) or in order to take steps at your request prior to entering into a contract (for instance, when you request a quote from us);

   Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);

   Processing is necessary in order to protect your vital interests or of any other individual (for instance, if you have any issue during a trip);

   Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party (for instance, protecting our customers, our employees and other individuals and maintaining their safety, health and welfare; promoting, marketing and advertising our products and services; understanding our customers’ behaviour, activities, preferences, and needs; improving existing products and services and developing new products and services; preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies; handling customer contacts, queries, complaints or disputes; managing insurance claims by customers; protecting us, our employees and customers, by taking appropriate legal action against parties who have committed criminal acts or are in breach of legal obligations to us; effectively handling any legal claims or regulatory enforcement actions taken against us; fulfilling our duties to our customers, colleagues, shareholders and other stakeholders).

5. Change of Purpose

   We will only use your personal information for the purpose for which we obtained it. If we reasonably need to re-purpose your personal information, we will ensure it is for a reason that is compatible with the original purpose. If you require an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. We may process your personal information for unrelated purposes, based on our Legitimate Interest.

   
   
   • There are some circumstances in which personal information may be processed for purposes that go beyond the original purpose for which the personal information was collected. When this is susceptible to be the case, we will make our best efforts to tell you in advance and request your consent when appropriate.
   • For circumstances where we may have other secondary purposes, for processing already existing information which you have provided as part of a contract for example, booking information. The objective of further processing may include conducting marketing insights and data analysis to have a better understanding of our customers.
   • We will adopt an aggregate data model that allows us derive aggregated data from your personal information. Aggregated data is not considered personal information by law, as you will not be directly or indirectly identified. For example we may make use of aggregated data to see performance statistics of our travel consortia/consultants and to gain insights into customer demographics for improving marketing and customer service.
   • However, if we combine or connect aggregated data with your personal information so that it directly or indirectly identifies you, we shall treat the combined data as personal information which will be processed with strict guidelines of the GDPR or relevant privacy laws of the Country you reside.
   • We will not repurpose sensitive information without explicit consent and where we rely on Legitimate Interest; will ensure we conduct (as required by law) Legitimate Interest assessments and data protection impact assessments (DPIA), prior to carrying out the proposed processing activity.

6. Who Our Privacy Policy Covers

   6.1 Our customers

   Our privacy policy sets out how we process personal information relating to individuals who are booking or enquiring about booking travel services with or through us or who are the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you), or who are customers or potential customers or recipients of travel services that can be booked with or through us.

   6.2 Examples of who this policy covers

   We include in this privacy policy personal information we process relating to: (1) individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, and travel group members, and officers and employees of businesses and organisations booking with or through us); (2) individuals in respect of whom any enquiry or booking is made with us by an agent; (3) where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors; (4) individuals who visit our website or other online sites operated by us or our contractors or affiliates; (5) individuals who create an online account (if applicable); (6) individuals whose personal information from other companies in our group (such as where you have consented to your personal information being disclosed to other group companies for marketing purposes); and (7) individuals or businesses from any other arrangement with us.

   6.3 When we are an information processor only

   This privacy policy does not apply where we are processing personal information strictly as a sub-contractor or information processor on behalf of a third party, and not on our own account. In this case, you should look to that third party, who will be answerable for how we process that personal information and its privacy policy.

   6.4 Terms used in this policy

   When we refer to "you" and "your" in this privacy policy, we refer to you, any such individual whose personal information we process from time to time.

   When we refer to “process” or "processing" of your personal information, this includes collecting, recording, storing or holding your personal information, and anything we do with it, such as organizing, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other information, and blocking, erasing or destroying it.

   When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, trips, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both (1) all such products and services which we supply or operate ourselves (including where we sub-contract); and (2) any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

7. What Laws We Comply With

   7.1 Privacy laws

   We process your personal information in accordance with the privacy law(s) in the Country you reside. For example:
   In Australia, the Australian Privacy Principles contained in the Privacy Act, 1988 which regulates the handling of personal information about individuals. This includes the collection, use, storage and disclosure of personal information. The Australian regulator is the Office of the Australian Information Commissioner (OAIC) (http://www.oaic.gov.au/)
   In Europe, the GDPR contained in the Data Protection Act 2018.

   7.2 Other laws

   We also comply generally with the laws of the Country you reside in relation to the processing of your personal information.

8. What Types Of Personal Information We Process

   This section summarises the types of personal information about you that we process:-

   8.1 Information concerning you as an individual

   This includes name, age, photograph, gender, address, telephone, mobile, fax, e-mail, social networking contact details, proofs of identity and address, copies of passports, driving licences, card and other payment details, and financial information, health information relevant to your planned travel, and travel insurances held, results of searches carried out against you, your preferences, frequent flyer or travel partner program affiliation and member number, and any other information provided to us by or in relation to you which concern you as an individual.

   8.2 Sensitive Information

   In some instances it may be necessary to collect “sensitive information”, such as your religion and details of medical, dietary, mobility or factors relevant to your booking. As we are required by law to obtain your consent to the collection of “sensitive information”, we will assume that when you provide such information to us, you have consented to our collection and use of it in accordance with this policy.

   8.3 Business Related Information

   If you are an individual associated with a business or other organisation that is our customer, then your personal information may include the following information that we link to you: business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.), your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

   8.4 Enquiry and Booking Information

   Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include: records of enquiries and searches for holiday and travel products made by or on your behalf, details of your personal interests, needs and other information relevant to your enquiry; details of results, quotes, proposals, estimates and other information given in response to enquiries; details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about; details of the passengers / holidaymakers travelling; details of the provider of the travel services (e.g. travel operator); dates and times of travel; price; payment details (including card details); passport information and visa information; foreign exchange requirements and arrangements; and sensitive information such as health, medical, dietary, mobility, disability, religious or other special conditions or requirements.

   8.5 Performance Information

   Information generated concerning the performance of any booking or other contract made with or through us, including information relating to anything arising during any holiday or other travel services, and information relating to payments to be made.

   8.6 Survey Information

   Information collected or generated out of any surveys we conduct.

   8.7 Feedback and user generated content (UGC)

   Information or content provided by you in relation to your feedback or experience on a past current or future trip with us.

   8.8 Competition Information

   Information collected or generated out of any competitions or promotions we run.

   8.9 Account, Registration and Loyalty Information

   Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

   8.10 Correspondence

   Correspondence, communications and messages, including between you and us, and between us and third parties, including relating to any booking or booking enquiry, or performance of any contract.

   8.11 Social Media

   Any information (including your social media user details, feedback, comments and photos) you post on our social media channel or any forum which relates to us.

   8.12 Website Usage Information

   We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of information we collect will depend on how you interact with our website. This information may include: your IP address (a unique identifier allocated to your computer for your connection to the internet); your computer device details (PC, tablet, smartphone, watch etc.); the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc); your time-zone; your browser plug-ins; any web-page you came from, identified as the referrer web page address by your web browser; cookies; page response times; download error; pages and parts of pages you visit; usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.; services and products you viewed; length of visit to website and pages; page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs). This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal information, if this information is in any way linked to you personally. This information may also include: information inputted into forms and field; registrations for any accounts, forum, feedback mechanism, social functionality, newsletters or other features of our site; usernames and passwords, log-in / out history, and settings; actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review or other social functionality on our website. Such information will be treated as personal information and processed according to this privacy policy.

9. How We Collect Or Generate Your Personal Information

   This section sets out the ways in which we may collect or generate personal information concerning you.

   9.1 Visiting our website

   By visiting and using our website you or your computer may provide personal information. This includes: information which is automatically provided by your browser to our servers; information record on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. Cookies - Cookies collect information that includes the server your computer is logged onto, your browser type and how you gained entry to our website. Therefore, when you visit our website anonymously, details are recorded about your visit, such as, in addition to the matters described in the previous paragraph, time and date, pages accessed and time spent. This information is used in an anonymous form for statistical purposes and as such, cannot be used to identify you individually. A cookie cannot retrieve any other information from your hard drive, pass on computer viruses or capture your email address or any other personally identifiable information. You should note that accepting cookies is required if you want to view our websites, because they are essential for our site administration and security. You may disable cookies or set your browser to alert you when cookies are being sent. If you do disable cookies, we may be unable to optimize your visit to our site and you may experience some errors. Refer to your browser instructions or help screens to learn about these functions. If you reject all cookies, you may not be able to use our web sites.

   9.2 Information you provide

   Your personal information will include information you provide (or later amend), whether: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website; by posting on our social media channel; by posting on any forum referencing us; by filling in any printed form we provide you with; by e-mail; from documents you provide us with; and from updates to any information you provide from time to time. This includes when you: register or subscribe for any service, account, members, or loyalty program, or make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; and request sales and advertising information, including brochures. If you do not provide us with your personal information we will be unable to provide you with information or book travel services for or on your behalf.

   9.3 User Generated Content (UGC)

   We may process, information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent (including by submitting or making the submission) to let AAT Kings or the Travel Corporation Pty Ltd related companies to process this information in various initiatives. These could include any marketing activities such as: Print materials on our website; email activities; social posts; images on our trips; provide images to our trade partners to use on their websites, email marketing and other marketing initiatives Make available in our content feeds. We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods; any other information provided to us by or in relation to you which concerns you as an individual.

   9.4 Information obtained from third parties

   We may obtain personal information concerning you from third parties, including from: people making enquiries or bookings on your behalf, providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries; credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations; from any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

   9. 5 Information generated by us

   We and any suppliers or sub-contractors working for us may generate personal information relating to you, including in connection with responding to and dealing with any enquiry, booking or complaint; or in performing any booking or other contract with you; or through the analysis of your personal information or information gained from your use of our website. We may record telephone calls with you.

10. What Do We Use Your Personal Information For?

    This section sets out the uses which we make of your personal information:

    10.1 Operate our website

    To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites. This includes customising your online experience by providing you with more relevant online offers and updates, managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

    10.2 Provide information and respond to enquiries

    To provide information to you about our website, systems and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally.

    10.3 Bookings and other contracts

    To enable you to make bookings, and to fulfill, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you.

    10.4 Payments

    To collect and make payments due and administer our accounts.

    10.5 Communication with customers

    To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you.

    10.6 Record keeping

    To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints.

    10.7 Manage and Improve our business

    To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services; to carry out surveys and analyse the results; to run promotions and competitions; undertake product or customer research/development; to assist us in and help us to improve our sales, editorial, advertising and marketing processes; to carry out other business development and improvement activities; and to provide training to our staff, sub-contractors and suppliers. For example, we may use your personal information to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings.

    10.8 Direct marketing

    To carry out direct marketing to you. See next section below for further information.

    10.9 Use of Reviews:

    By submitting content to our website by electronic mail, postings on our website or otherwise, including any reviews, questions, comments, suggestions, ideas, photos or the like contained in any submissions (collectively, “Submissions”), you grant AAT Kings and its affiliates a nonexclusive, royalty-free, perpetual, transferable, irrevocable and fully sub-licensable right to (a) use, reproduce, modify, adapt, translate, distribute, publish, create derivative works from and publicly display and perform such Submissions throughout the world in any media, now known or hereafter devised; and (b) use the name that you submit in connection with such Submission.

    10.10 Advertising

    To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical information about browsing actions and patterns, and do not identify any individual.

    10.11 Anything you have specifically consented to

    For any purpose which we have obtained your consent to.

    10.12 Consequences of not providing your Information

    You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products; we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.

11. Use Of Your Personal Information For Direct Marketing

    We do not use or disclose your personal information for direct marketing purposes unless we have obtained your express consent to this, such as through an opt-in or opt-out tick box on any form or website of ours.

    11.1 Direct marketing by us

    Where you have consented to this, we may use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services we provide or which can be booked with third parties through us.

    Where you have consented to this, we may also use your personal information to carry out direct marketing and send you marketing messages, materials, adverts and promotions relating to travel services which are offered by or which can be booked through any other company in the same group of companies as us (i.e. within the Travel Corporation group) or third parties selected by us.

    You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive or by clicking the ‘unsubscribe’ button at the bottom of any of our emails. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

    11.2 Direct marketing by third parties

    Where you have consented to this, we may disclose your personal information which is contact information (such as name, e-mail, postal address, telephone, mobile or fax number) to any other company in the same group of companies as us (e.g. within the Travel Corporation group), or to third parties selected by us. They will use this to carry out direct marketing in their own right and will use it to send you marketing materials, adverts and promotions relating to products and services they offer or which can be booked through them. You will be free to withdraw your consent to our disclosure of your personal information for this purpose at any time, by contacting us as detailed above. If you withdraw your consent, this will not affect any disclosures we have already made (i.e. we will not be able to remove your personal information from anyone we have disclosed it to), but we will tell you who they are on request, and you should contact them directly concerning this.

     

12. Disclosure Of Your Personal Information

    We transfer your personal information to third parties in the following circumstances:-

    12.1 Bookings and performance of contracts

    We disclose your personal information to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include; to apply for visas on your behalf, to collect payments to be made by you, to investigate and respond to complaints, and to enforce any booking or other contract with you. Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, travel operators etc.).

    12.2 Suppliers of travel and other services

    We may disclose your personal information to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, trip or other products or services we have agreed to provide to you. We may disclose your personal information to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a travel operator. Details of any third party travel operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any trip or other brochure provided by us.

    12.3 Insurance

    If any application is made through us for any travel or other insurance to cover you, we will pass your personal information on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

    12.4 Business Function Outsourcing

    Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis, and providing customer services), then then we may provide your personal information to them as required for use for or processing as part of those purposes.

    12.5 Public Forums etc.

    Where any facility on our website is clearly designed to make some of your personal information public (e.g. posts you make to any public forum or reviews facility) then any personal information you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us.

    12.6 Legal Requirements

    We may supply personal information to a government authority or regulator where required to comply with a legal requirement, for the administration of justice, for the purposes of customs, visas and immigration, or where reasonably required to protect your vital interests or enforce any booking or other contract. We may disclose your personal information where otherwise required by or permitted by law.

    12.7 Direct Marketing by third parties

    We may disclose your personal information to third parties to carry out direct marketing to you, where you have given your prior consent, to third parties to carry out direct marketing. See the direct marketing section above.

    12.8 Customer Representatives

    If our customer is a business or organisation, and we are holding your personal information in your capacity as an associate of that business or organisation (including as agent, representative, contact, employee, officer, owner, partner, or director), then we may disclose to them that personal information. If our customer is making a booking or booking enquiry on your behalf, with your authority, then we may disclose to our customer your personal information as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

    12.9 Business acquirers

    if our business is ever transferred to a third party, then your personal information will be transferred to the acquirer to enable them to continue our business.

13. How Third Parties Will Handle Your Personal Information

    Where we provide your personal information to a third party one of the following two circumstances will apply:-

    13.1 Processing on our behalf

    In some cases, your personal information may be held and otherwise collected and used by them on our behalf, in which case we will remain responsible for what they do with your personal information, and your personal information will only be held and collected and used by them in accordance with our instructions and this privacy policy.

    13.2 Processing on their own account

    In other cases, your personal information may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for that personal information, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure.

14. Keeping Your Personal Information Secure

    15.1 Our security measures

    15.1.1 Our general commitment

    We are committed to doing what we reasonably can to keep your personal information secure, and we are obliged by law to put in place appropriate technical and organisational measures against unauthorised or unlawful processing of your personal information and against accidental loss or destruction of, or damage to, your personal information. We have accordingly implemented security policies, rules and technical measures with a view to achieving this.

    15.1.2 Transmissions between your web browser and our servers

    We use Secured Socket Layer (“SSL”) software in order to encrypt the personal information that you provide to us whilst it is in transit over the internet. This will work if your browser is SSL enabled (which most are). You can verify that this is working by looking for the symbol of a closed lock or solid key on the bottom bar of your browser window, and checking that the prefix for the web address in the browser address bar has changed from “http” to “https”.

    15.1.3 Storage of your personal information

    The personal information we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures.

    15.2 Your security measures

    For your own privacy protection, we encourage you to maintain anti-virus and other malware protection software on your computers and other devices, and to maintain your own measures to protect your personal information. Please do not include sensitive personal information in any e-mails you may send to us, including payment card information.

    We also encourage you to be careful about who you give personal information to. We never contact you to ask you for sensitive personal information, such as payment card information, or sensitive personal information such as passport numbers or log-in details, and we will only ask you for such information in person or through our website, or by telephone in connection with a booking you are making or have made. Please let us know if you someone purports to contact you in our name.

15. Location Of Your Personal Information

    15.1 Transfer of personal information overseas

    We (and any affiliate, subcontractor or other person processing your personal information on our behalf) may transfer, store and otherwise process your personal information anywhere in the world to fulfill the purposes set out in this policy, for example to: (1) our overseas offices; (2) information processors (including operators of global travel distribution systems); (3) airlines, hotels and other travel service products; and information technology and business service providers.

    In many cases the transfer is necessary to initiate or complete a booking or other transaction on your behalf in response to a request by you or for the purpose of entering a contract with a third party on your behalf.

    Where we disclose your personal information to third parties, that disclosure may also involve a transfer of your personal information anywhere in the world, and those third parties may themselves transfer, store or otherwise process that information anywhere in the world.

    In each case, we will comply with any legal requirements concerning the transfer of your personal information by us to any third party outside the country where we are established, and where your personal information is still controlled by us or is being stored or otherwise processed on our behalf, our security measures (as detailed below) will also apply.

    15.2 Counties to which your personal information is transferred

    The countries which we transfer your personal information depends on your booking. Generally such countries include those in Asia Pacific, Africa, North and South America and Europe.

16. How Long Do We Keep Your Personal Information For?

    We keep your personal information for so long as is reasonably necessary for the purposes for which we use it, and if longer, for any duration required by law, and for statutory claims limitation periods where your personal information may be relevant to any possible liability we may have to you.

17. Your Rights

    17.1 Access to your personal information

    Our privacy policy is not intended to create a contract or form part of your contract. You may have certain rights under data protection laws in the Country you reside to access your personal information. You may request us to tell you whether we are processing personal information about you, to tell you what personal information we are processing and what purposes, and to provide you with a copy of your personal information that we hold.

    If you contact us about these rights, we may ask for proof of your identity before we act on any request, and we may refuse to act if you do not provide this or your identity is not established by you. This is to ensure that your data is protected and kept secure. More information about your rights and our obligations can be found on the governing body administering privacy laws in the Country you reside. For example, in Australia this can be found at https://www.oaic.gov.au/privacy-law/privacy-act/. If we refuse to provide you with access to information we hold about you, we will provide reasons for such refusal and inform you of any exceptions relied upon under the relevant law.

    16.2 Right to Amend Information

    You have the right to have your personal information amended if it is inaccurate or incomplete. To exercise any of your rights, please contact us as per the contact details provided. You can also exercise some of these rights directly through our online form at https://ttc.com/personal-data-request/

    17.2 Use for direct marketing

    You have the right to ask us to stop using your personal information to carry out direct marketing to you. To opt-out of receiving direct marketing from us please follow the instructions detailed at the bottom of all our email marketing communications or contact us by phone on 1300 228 546 or email us at marketing@aatkings.com.au. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

    17.3 Correction of inaccuracies

    We take reasonable steps to ensure that the personal information we hold about you is, whenever we collect or use it, is accurate, complete and up-to-date. If the information we hold is inaccurate, incomplete or out-of-date please update your details on our website (if possible) or contact us and we will take reasonable steps to either correct it, or if necessary, discuss alternative action with you.

    17.4 Complaints to applicable authority

    The laws we comply with are regulated by the relevant authority in the Country you reside, for example in Australia the Australian Information Commissioner. In addition to your rights above, it is open to you, if you have a complaint or concern, to seek assistance from such government regulator. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have.

18. Changes To This Privacy Policy

    We keep our privacy policy under review to make sure it is up to date and accurate. When we make any change, we will notify you by updating our privacy policy online or emailing you of such change. You can check the top of the document to see the latest version in force.

19. Applicable Law And Disputes

    This policy is subject to the law of the Country in which you reside and the information is collected. For example, if you reside in Australia you may obtain further information regarding privacy issues in Australia by visiting the Australian Information Commissioner’s website at http://www.oaic.gov.au/. If you reside elsewhere, you may enquire of the governing body administering privacy laws in that Country of residence.

20. Linked Websites

    Our website contains links to other websites. We are not responsible for the privacy practice or content on those websites. You should read the privacy statements and policies of any linked sites as their privacy policies may differ from ours.

21. Contacting Us

    If you have any questions about our privacy policy or about how we process your personal information, including any complaints, please contact us either by e-mail to marketing@aatkings.com.au, telephone on 1300 228 546, or by post to 82-86 Bourke Road Alexandria, NSW, 2015 AUSTRALIA. You may also email compliance@ttc.com for all data protection and privacy matters.

    COPYRIGHT NOTICE
    This document, and all content of our websites is Copyright© 2020 AAT Kings. ALL RIGHTS RESERVED.

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