Trafalgar Privacy Policy

Contiki Privacy Policy

Last Updated: October 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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data that you entrust to us.

3. About us
This is the privacy policy of The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation number is (09) 300 1560 and our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

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 data unless at least one of the following requirements is met:

• You have given consent to the processing of your personal data 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 data, 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 data for unrelated purposes, based on our legitimate interest.

•  There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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 data 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 data 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 data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
• We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct 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 data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) 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); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5) who upload, post or send anything to or through our websites or apps, or who receive messages through our websites or apps, using any community functionality.

 
6.2 Examples of who this policy covers
We include in this privacy policy personal data 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 tour 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; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

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

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 collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, recording, storing or holding your personal information, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, 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, tours, 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.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of us appear: contiki.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites.

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

7. What laws we comply with
We process your personal data in accordance with the Privacy Act 1993 Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz

We also comply generally with the laws of New Zealand in relation to the processing of your personal data, and not any other laws.

8. What types of personal information we process
This section summarizes the types of personal data about you that we process:-

8.1 Data 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, and utility bills, 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 (such as to verify you identity, address, and credit status), 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 Business Related Information
If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

8.3 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 data 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.

8.4 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.

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

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

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

8.8 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.

8.9 Technical Information about your computer
We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. 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 data, if this information is in any way linked to you personally.

8.10 Technical Information about your computer
We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. 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 data, if this information is in any way linked to you personally.

8.11 Community Data
Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

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 Automatic capture
By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.

9.2 Data you provide
Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; 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 any data you provide 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 websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

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 to let [Brand Name] and TTC subsidiary 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 Data obtained from third parties
We may obtain personal data concerning you from third parties, including from: 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; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.

9.5 Data generated by us
We and any suppliers or sub-contractors working for us may generate personal data 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 data or data gained from your use of our websites and apps. 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 data:

10.1 Operate our websites, apps and services
to operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, 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 websites, apps, 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
keeping internal records and maintaining reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

10.7 Promotion, management and Improvement of our business
To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, 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 data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. 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 Advertising
to report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

10.10 Anything you have specifically consented to
for any purpose which we have obtained your consent to.

10.11 Maintenance of our website and apps
we may use your personal data to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

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 data 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 expressly consented to this, we may disclose your personal information which is contact data (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, advertisements 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 as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. 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 data
We disclose your personal data to third parties in the following circumstances:

12.1 Credit Checks etc.
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 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, tour operators etc.).

12.3 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, tour 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 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.

12.4 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.

12.5 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.

12.6 Community Functionality
Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data 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, may be disclosed accordingly. Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

12.7 Legal Requirements
we may supply personal data 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 data where otherwise required by or permitted by law.

12.8 Direct Marketing by third parties
we may disclose your personal data 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.

12.9 Customer Representatives
If our customer is a business or organisation, and we are holding your personal data 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 data. 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 data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

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

13. How third parties will handle your personal data
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 collected, used or disclosed 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. Location of your personal information
We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

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 collect, use and disclose 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 collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. Keeping your data 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 collection, use and disclosure 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.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

 

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 data
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.

16. How long do we keep your personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.

17. Your rights
17.1 Access to your personal data 
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. We may charge a fee for handling your request, in an amount prescribed by law. This fee is $10 as at the date of this policy. 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. 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.

17.2 Use causing substantial distress or damage
You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing
You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies
You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

17.5 Compensation
You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

17.6 Complaints to applicable authority
The laws we comply with are regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). 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, who has powers to compel us to comply with applicable laws and fine us for non-compliance. 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 notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email 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 New Zealand, and you must bring any claims against us exclusively in the courts of New Zealand.

20. Contacting us
If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com, (09) 300 1560, or by post to PO Box 68-640, Auckland, 1145. You may also email compliance@ttc.com for all data privacy matters. 

Copyright notice
This document, and all content of our websites is Copyright© The Travel Corporation NZ Limited ALL RIGHTS RESERVED.

Costsaver 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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data that you entrust to us.

3. About Us
This is the privacy policy of The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation number is (09) 300 1560 and our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

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 data unless at least one of the following requirements is met:

• You have given consent to the processing of your personal data 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 data, 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 data for unrelated purposes, based on our legitimate Interest.

• There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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 data 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 data 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 data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
• We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct 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 data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) 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); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5) who upload, post or send anything to or through our websites or apps, or who receive messages through our websites or apps, using any community functionality.

6.2 Examples of who this policy covers
We include in this privacy policy personal data 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 tour 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; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

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

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 collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, 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 data, 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, tours, 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.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of us appear: trafalgar.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites.

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

7. What Laws We Comply With
We process your personal data in accordance with the Privacy Act 1993

Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz

We also comply generally with the laws of New Zealand in relation to the processing of your personal data, and not any other laws.

8. What Types Of Personal Information We Process
This section summarizes the types of personal data about you that we process:-

8.1 Data 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, and utility bills, 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 (such as to verify you identity, address, and credit status), 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 Business Related Information
If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

8.3 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 data 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.

8.4 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.

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

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

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

8.8 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.

8.9 Technical Information about your computer
We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. 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 data, if this information is in any way linked to you personally.

8.10 Technical Information about your computer
We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. 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 data, if this information is in any way linked to you personally.

8.11 Community Data
Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

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 Automatic capture
By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.

9.2 Data you provide
Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; 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 any data you provide 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 websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

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 to let [Brand Name] and TTC subsidiary 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 Data obtained from third parties
We may obtain personal data concerning you from third parties, including from: 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; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.

9. 5 Data generated by us
We and any suppliers or sub-contractors working for us may generate personal data 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 data or data gained from your use of our websites and apps. We may record telephone calls with you.

10. What Do We Use Your Personal Information
This section sets out the uses which we make of your personal data:

10.1 Operate our websites, apps and services
to operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, 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 websites, apps, 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
keeping internal records and maintaining reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

10.7 Promotion, management and Improvement of our business
To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, 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 data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. 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 Advertising
to report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

10.10 Anything you have specifically consented to
for any purpose which we have obtained your consent to.

10.11 Maintenance of our website and apps
we may use your personal data to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

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 data 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 expressly consented to this, we may disclose your personal information which is contact data (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, advertisements 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 as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. 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 Data
We disclose your personal data to third parties in the following circumstances:-

12.1 Credit Checks etc.
We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 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, tour operators etc.).

12.3 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, tour 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 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.

12.4 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.

12.5 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.

12.6 Community Functionality
Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data 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, may be disclosed accordingly. Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

12.7 Legal Requirements
we may supply personal data 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 data where otherwise required by or permitted by law.

12.8 Direct Marketing by third parties
we may disclose your personal data 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.

12.9 Customer Representatives
If our customer is a business or organisation, and we are holding your personal data 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 data. 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 data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

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

13. How Third Parties Will Handle Your Personal Data
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 collected, used or disclosed 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. Location Of Your Personal Information
We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

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 collect, use and disclose 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 collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. Keeping Your Data 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 collection, use and disclosure 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.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

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 data
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.

16. How Long Do We Keep Your Personal Data For
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.

17. Your Rights
17.1 Access to your personal data
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. We may charge a fee for handling your request, in an amount prescribed by law. This fee is $10 as at the date of this policy. 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. 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.

17.2 Use causing substantial distress or damage
You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing
You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies
You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

17.5 Compensation
You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

17.6 Complaints to applicable authority
The laws we comply with are regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). 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, who has powers to compel us to comply with applicable laws and fine us for non-compliance. 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 notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email 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 New Zealand, and you must bring any claims against us exclusively in the courts of New Zealand.

20. Contacting Us
If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com or by post to PO Box 68-640, Auckland, 1145. You may also email compliance@ttc.com for all data privacy matters.

Luxury Gold Privacy Policy

Last updated: September 2019.

1. ABOUT THIS DOCUMENT

TThis 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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data that you entrust to us.

3. ABOUT US

This is the privacy policy of The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

 

4. OUR LEGAL BASES FOR PROCESSIN

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

1. You have given consent to the processing of your personal data 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);
2. 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);
3. Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
4. 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);
5. 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 data, 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 data for unrelated purposes, based on our legitimate Interest.

1. There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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.
2. For circumstances where we may have other secondary purposes, for processing already existing data 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.
3. We will adopt an aggregate data model that allows us derive aggregated data from your personal information. Aggregated data is not considered personal data 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.
4. However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
5. We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct 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 data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) 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); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5) who upload, post or send anything to or through our websites or apps, or who receive messages through our websites or apps, using any community functionality.

6.2 Examples of who this policy covers

We include in this privacy policy personal data 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 tour 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; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

6.3 When we are a data processor only

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

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 collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, 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 data, 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, tours, 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.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of us appear: insightvacations.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites.

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

 

7. WHAT LAWS WE COMPLY WITH

We process your personal data in accordance with the Privacy Act 1993 Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz We also comply generally with the laws of New Zealand in relation to the processing of your personal data, and not any other laws.

 

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal data about you that we process:

8.1 Data 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, and utility bills, 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 (such as to verify you identity, address, and credit status), 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 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

8.3 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 data 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.

8.4 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.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

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

8.7 Account, Registration and Loyalty Information

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

8.8 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.

8.9 Technical Information about your computer

We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. 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 data, if this information is in any way linked to you personally.

8.10 Technical Information about your computer

We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. 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 data, if this information is in any way linked to you personally.

8.11 Community Data

Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

 

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 Automatic capture

By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.

9.2 Data you provide

Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; 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 any data you provide 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 websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

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 to let Luxury Gold and TTC subsidiary 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 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from: 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; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.

9.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data 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 data or data gained from your use of our websites and apps. 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 data:

10.1 Operate our websites, apps and services

to operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, 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 websites, apps, 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

keeping internal records and maintaining reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

10.7 Promotion, management and Improvement of our business

To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, 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 data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. 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 Advertising

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

10.10 Anything you have specifically consented to

for any purpose which we have obtained your consent to.

10.11 Maintenance of our website and apps

we may use your personal data to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

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 data 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 expressly consented to this, we may disclose your personal information which is contact data (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, advertisements 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 as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. 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 DATA

We disclose your personal data to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 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, tour operators etc.).

12.3 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, tour 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 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.

12.4 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.

12.5 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.

12.6 Community Functionality

Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data 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, may be disclosed accordingly. Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

12.7 Legal Requirements

we may supply personal data 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 data where otherwise required by or permitted by law.

12.8 Direct Marketing by third parties

we may disclose your personal data 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.

12.9 Customer Representatives

If our customer is a business or organisation, and we are holding your personal data 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 data. 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 data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.10 Business Acquirers

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

13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

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 collected, used or disclosed 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. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

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 collect, use and disclose 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 collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. KEEPING YOUR DATA 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 collection, use and disclosure 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.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

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 data

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.

16. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.

 

17. YOUR RIGHTS

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.

17.1 Access to your personal data

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. We may charge a fee for handling your request, in an amount prescribed by law. This fee is $10 as at the date of this policy. 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. 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.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

17.5 Compensation

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

17.6 Complaints to applicable authority

The laws we comply with are regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). 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, who has powers to compel us to comply with applicable laws and fine us for non-compliance. 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 notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email 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 New Zealand, and you must bring any claims against us exclusively in the courts of New Zealand.

 

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com, contact us here, or by post to PO Box 68-640, Auckland, 1145. You may also email compliance@ttc.com for all data privacy matters.

Insight Vacations Privacy Policy

Last updated: September 2020.

 

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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data that you entrust to us.

3. ABOUT US

This is the privacy policy of The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

 

4. OUR LEGAL BASES FOR PROCESSIN

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

1. You have given consent to the processing of your personal data 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);
2. 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);
3. Processing is necessary for compliance with a legal obligation to which we are subject (for instance, for visa applications);
4. 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);
5. 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 data, 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 data for unrelated purposes, based on our legitimate Interest.

1. There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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.
2. For circumstances where we may have other secondary purposes, for processing already existing data 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.
3. We will adopt an aggregate data model that allows us derive aggregated data from your personal information. Aggregated data is not considered personal data 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.
4. However, if we combine or connect aggregated data with your personal data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
5. We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct 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 data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) 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); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5) who upload, post or send anything to or through our websites or apps, or who receive messages through our websites or apps, using any community functionality.

6.2 Examples of who this policy covers

We include in this privacy policy personal data 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 tour 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; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

6.3 When we are a data processor only

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

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 collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, 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 data, 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, tours, 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.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of us appear: insightvacations.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites.

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

 

7. WHAT LAWS WE COMPLY WITH

We process your personal data in accordance with the Privacy Act 1993 Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz We also comply generally with the laws of New Zealand in relation to the processing of your personal data, and not any other laws.

 

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal data about you that we process:

8.1 Data 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, and utility bills, 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 (such as to verify you identity, address, and credit status), 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 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

8.3 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 data 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.

8.4 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.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

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

8.7 Account, Registration and Loyalty Information

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

8.8 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.

8.9 Technical Information about your computer

We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. 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 data, if this information is in any way linked to you personally.

8.10 Technical Information about your computer

We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. 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 data, if this information is in any way linked to you personally.

8.11 Community Data

Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

 

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 Automatic capture

By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.

9.2 Data you provide

Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; 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 any data you provide 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 websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

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 to let The Travel Corporation NZ and TTC subsidiary 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 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from: 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; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.

9.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data 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 data or data gained from your use of our websites and apps. 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 data:

10.1 Operate our websites, apps and services

to operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, 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 websites, apps, 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

keeping internal records and maintaining reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

10.7 Promotion, management and Improvement of our business

To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, 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 data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. 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 Advertising

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

10.10 Anything you have specifically consented to

for any purpose which we have obtained your consent to.

10.11 Maintenance of our website and apps

we may use your personal data to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

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 data 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 expressly consented to this, we may disclose your personal information which is contact data (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, advertisements 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 as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. 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 DATA

We disclose your personal data to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 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, tour operators etc.).

12.3 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, tour 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 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.

12.4 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.

12.5 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.

12.6 Community Functionality

Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data 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, may be disclosed accordingly. Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

12.7 Legal Requirements

we may supply personal data 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 data where otherwise required by or permitted by law.

12.8 Direct Marketing by third parties

we may disclose your personal data 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.

12.9 Customer Representatives

If our customer is a business or organisation, and we are holding your personal data 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 data. 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 data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.10 Business Acquirers

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

13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

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 collected, used or disclosed 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. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

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 collect, use and disclose 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 collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. KEEPING YOUR DATA 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 collection, use and disclosure 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.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

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 data

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.

16. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.

 

17. YOUR RIGHTS

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.

17.1 Access to your personal data

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. We may charge a fee for handling your request, in an amount prescribed by law. This fee is $10 as at the date of this policy. 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. 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.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

17.5 Compensation

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

17.6 Complaints to applicable authority

The laws we comply with are regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). 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, who has powers to compel us to comply with applicable laws and fine us for non-compliance. 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 notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email 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 New Zealand, and you must bring any claims against us exclusively in the courts of New Zealand.

 

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com, Contact Us Here, or by post to PO Box 68-640, Auckland, 1145. You may also email for all data privacy matters.

Uniworld Privacy Policy

Last updated: 7 October 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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data that you entrust to us.

3. ABOUT US

This is the privacy policy of The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation number is (09) 300 1560 and our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

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 data unless at least one of the following requirements is met:

• You have given consent to the processing of your personal data 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 data, 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 data for unrelated purposes, based on our legitimate Interest.

• There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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 data 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 to derive aggregated data from your personal information. Aggregated data is not considered personal data 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 data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
• We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct 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 data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) 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); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5) who upload, post or send anything to or through our websites or apps, or who receive messages through our websites or apps, using any community functionality.

6.2 Examples of who this policy covers

We include in this privacy policy personal data 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 tour 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; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

6.3 When we are a data processor only

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

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 collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, 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 data, 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, tours, 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.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of us appear: uniworld.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

7. WHAT LAWS WE COMPLY WITH

We process your personal data in accordance with the Privacy Act 1993.

Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz.

We also comply generally with the laws of New Zealand in relation to the processing of your personal data, and not any other laws.

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal data about you that we process:

8.1 Data 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, and utility bills, 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 (such as to verify your identity, address, and credit status), 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 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

8.3 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 data 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.

8.4 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.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

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

8.7 Account, Registration and Loyalty Information

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

8.8 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.

8.9 Technical Information about your computer

We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. 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 data, if this information is in any way linked to you personally.

8.10 Technical Information about your computer

We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. 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 data, if this information is in any way linked to you personally.

8.11 Community Data

Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

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 Automatic capture

By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.

9.2 Data you provide

Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; 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 any data you provide 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 websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

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 to let [Brand Name] and TTC subsidiary 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 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from: 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; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.

9.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data 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 data or data gained from your use of our websites and apps. 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 data:

10.1 Operate our websites, apps and services

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, 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 websites, apps, 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

Keeping internal records and maintaining reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

10.7 Promotion, management and Improvement of our business

To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, 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 data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. 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 Advertising

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

10.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to.

10.11 Maintenance of our website and apps

We may use your personal data to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

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 data 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 expressly consented to this, we may disclose your personal information which is contact data (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, advertisements 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 as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. 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 DATA

We disclose your personal data to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 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, tour operators etc.).

12.3 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, tour 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 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.

12.4 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.

12.5 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.

12.6 Community Functionality

Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data 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, may be disclosed accordingly. Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

12.7 Legal Requirements

We may supply personal data 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 data where otherwise required by or permitted by law.

12.8 Direct Marketing by third parties

We may disclose your personal data 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.

12.9 Customer Representatives

If our customer is a business or organisation, and we are holding your personal data 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 data. 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 data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.10 Business AcquirersIf our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.

13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

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 collected, used or disclosed 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. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

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 collect, use and disclose 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 collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. KEEPING YOUR DATA 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 collection, use and disclosure 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.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

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 data

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.

16. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.

17. YOUR RIGHTS

17.1 Access to your personal data

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. We may charge a fee for handling your request, in an amount prescribed by law. This fee is $10 as at the date of this policy. 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. 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.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

17.5 Compensation

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

17.6 Complaints to applicable authority

The laws we comply with are regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). 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, who has powers to compel us to comply with applicable laws and fine us for non-compliance. 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 notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email 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 New Zealand, and you must bring any claims against us exclusively in the courts of New Zealand.

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com, (09) 300 1560, or by post to PO Box 68-640, Auckland, 1145. You may also email compliance@ttc.com for all data privacy matters.

AAT Kings Privacy Policy

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 The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation number is (09) 300 1560 and our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

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 data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com, (09) 300 1560, or by post to PO Box 68-640, Auckland, 1145. You may also email compliance@ttc.com for all data privacy matters.

SEIT Privacy Policy

Seit Outback Australia is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This Statement of Privacy applies to the Seit Outback Australia Web site and governs data collection and usage. By using the Seit Outback Australia website, you consent to the data practices described in this statement.

• Collection of your Personal Information
  • Seit Outback Australia collects personally identifiable information, such as your e-mail address, name, home or work address or telephone number. Seit Outback Australia also collects anonymous demographic information, which is not unique to you, such as your ZIP code, age, gender, preferences, interests, and favourites.
  • There is also information about your computer hardware and software that is automatically collected by Seit Outback Australia. This information can include your IP address, browser type, domain names, access times and referring Web site addresses. This information is used by Seit Outback Australia for the operation of the service, to maintain the quality of the service, and to provide general statistics regarding use of the Seit Outback Australia Web site.
  • Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through Seit Outback Australia public message boards, this information may be collected and used by others. Note: Seit Outback Australia does not read any of your private online communications.
  • Seit Outback Australia encourages you to review the privacy statements of Web sites you choose to link to from Seit Outback Australia so that you can understand how those Web sites collect, use and share your information. Seit Outback Australia is not responsible for the privacy statements or other content on Web sites outside of the Seit Outback Australia and Seit Outback Australia family of Web sites.
• Use of your Personal Information
  • Seit Outback Australia collects and uses your personal information to operate the Seit Outback Australia Web site and deliver the services you have requested. Seit Outback Australia also uses your personally identifiable information to inform you of other products or services available from Seit Outback Australia and its affiliates. Seit Outback Australia may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.
  • Seit Outback Australia does not sell, rent or lease its customer lists to third parties. Seit Outback Australia may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (e-mail, name, address, telephone number) is not transferred to the third party. In addition, Seit Outback Australia may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to Seit Outback Australia, and they are required to maintain the confidentiality of your information.
  • Seit Outback Australia does not use or disclose sensitive personal information, such as race, religion, or political affiliations, without your explicit consent.
  • Seit Outback Australia keeps track of the Web sites and pages our customers visit within Seit Outback Australia, in order to determine what Seit Outback Australia services are the most popular. This data is used to deliver customized content and advertising within Seit Outback Australia to customers whose behavior indicates that they are interested in a particular subject area.
  • Seit Outback Australia Web sites will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on Seit Outback Australia or the site; (b) protect and defend the rights or property of Seit Outback Australia; and, (c) act under exigent circumstances to protect the personal safety of users of Seit Outback Australia, or the public.
• Use of Cookies
  • The Seit Outback Australia Web site use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a Web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
  • One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize Seit Outback Australia pages, or register with Seit Outback Australia site or services, a cookie helps Seit Outback Australia to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same Seit Outback Australia Web site, the information you previously provided can be retrieved, so you can easily use the Seit Outback Australia features that you customized.
  • You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Seit Outback Australia services or Web sites you visit.
• Security of your Personal Information
  • Seit Outback Australia secures your personal information from unauthorized access, use or disclosure. Seit Outback Australia secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. When personal information (such as a credit card number) is transmitted to other Web sites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
• Changes to this Statement
  • Seit Outback Australia will occasionally update this Statement of Privacy to reflect company and customer feedback. Seit Outback Australia encourages you to periodically review this Statement to be informed of how Seit Outback Australia is protecting your information.
• Contact Information
  • Seit Outback Australia welcomes your comments regarding this Statement of Privacy. If you believe that Seit Outback Australia has not adhered to this Statement, please contact Seit Outback Australia at manager@seitoutbackaustralia.com.au. We will use commercially reasonable efforts to promptly determine and remedy the problem.

Down Under Tours Privacy Policy

Last updated: 7 September 2020

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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data.

 

3. 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 data unless at least one of the following requirements are met:

– You have given consent to the processing of your personal data 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).

 

4. 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 data, 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 data for unrelated purposes, based on our legitimate Interest.

– There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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 data 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 data 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 data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
– We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct legitimate Interest assessments and data protection impact assessments DPIA, prior to carrying out the proposed processing activity.

 

5. Who our Privacy Policy Covers

5.1 Our customers

Our privacy policy sets out how we process personal data relating to individuals who are:

– booking or enquiring about booking travel services with or through us; or
– 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
– customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

5.2 Examples of who this policy covers

We include in this privacy policy personal data 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, tour group members, 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 whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

5.3 When we are data processor only

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

5.4 Terms used in this policy

When we refer to “you” and “your” in this privacy policy, we refer to you, and any such individual whose personal data we process from time to time.
When we refer to “processing” of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, 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, tours, 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 types of Personal Data we may process

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

6.1 Data concerning you as an individual

We may collect the following:

– name,
– age,
– photograph,
– gender,
– address,
– telephone,
– mobile,
– fax,
– e-mail,
– Social networking contact details, your social posts about any of our trips and travel experiences.
– proofs of identity and address, copies of passports, driving licences, and utility bills,
– 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 (such as to verify your identity, address, and credit status),
– your preferences,
– Frequent flyer or travel partner programme affiliation and member number.

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. In any e-mail you send we would ask you to insert “unsubscribe” as the subject heading.

6.2 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

6.3 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 data 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, or other requirements relevant to the service you are enquiring about or your contract with us.

6.4 Survey Information

Information collected or generated out of any surveys we conduct.

6.5 Competition Information

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

6.6 Account, Registration and Loyalty Information

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

6.7 Correspondence

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

6.8 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 data 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 (as per our cookie policy);
– 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 data, if this information is in any way linked to you personally.
This information may also include:

– data inputted into forms and fields;
– 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 data and processed according to this privacy policy.

 

7. How we collect or generate your personal data

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

7.1 Visiting our website

By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information recorded 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. This is more detailed in our cookie policy.

7.2 Data you provide

Your personal data will include data 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 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 to us 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.

7.3 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 to let Down Under Tours and TTC subsidiary 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.

7.4 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from:

– 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;
– Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

7.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data 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 data; or
– data gained from your use of our website according to our cookie policy.

We may record telephone calls with you for training and quality purposes.

 

8. What do we use your personal data for?

This section sets out the uses which we make of your personal data and the legal basis on which we rely to do this.

8.1 Operate our website

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

8.2 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. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.3 Bookings and other contracts

To enable you to make bookings, and to fulfil, 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. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.4 Payments

To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us.

8.5 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. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

8.6 Record Keeping

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

8.7 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 data 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. This is done on the basis of our legitimate interests in ensuring our business to run efficiently.

8.8 Direct marketing

To carry out direct marketing to you, see section 10.1 for further information.

8.9 Advertising

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

8.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.

8.11 Consequences of Not Providing your Data

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.

 

9. Period for retaining your data

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

If you would like to know more about our data retention policy, please ask us.

 

10. Use of your personal data for Direct Marketing

We do not use or disclose your personal data for direct marketing purposes unless:

– we have obtained your consent to do so, such as through an opt-in box on any form or website of ours; and/or
– you have made a booking with us and there is our legitimate business interest to do so for similar products or services.

If you do not want to receive direct marketing activities anymore, you can manage your communications preferences on your online account or unsubscribe by following the link at the end of every of our electronic communications.
In addition to data protection law if we use your personal information for direct marketing purposes we may also be subject to additional rules that regulate direct marketing, such as the EU Privacy and Electronic Communications Directive 2009/136/EC. The term “direct marketing” essentially means direct marketing material or advertising at a particular individual.

10.1 Direct marketing by us

We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:

(1) offered by us;
(2) which can be booked with third parties through us;
(3) which can be booked with other companies within our group (i.e. the Travel Corporation Group); and
(4) offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent.

Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or sms).

10.2 Direct Marketing by Third Parties

From time to time we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:

other companies within our The Travel Corporation, which are bound by the same requirements set in this privacy policy; and
other companies which offer services that may enhance your travel experience or be able to help you to finalise your travel arrangements (“third parties”). Such third parties may then contact you directly with marketing information about services and products offered by them. Such third parties are not part of The Travel Corporation and are not bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g. email, text) when providing your consent.

10.3 Withdrawing from Direct Marketing

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”
When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.
You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

 

11. Disclosure of your personal data to third parties

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

11.1 Credit Checks etc.

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

11.2 Bookings and performance of contracts

We disclose your personal data 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, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.

11.3 Suppliers of travel and other services

We may disclose your personal data 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, tour or other products or services we have agreed to provide to you in order to perform our contract with you.
We may disclose your personal data 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.

11.4 Insurance

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data 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.

11.5 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 we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.

11.6 Public forums etc.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data 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 and to the terms of this privacy policy.

11.7 Legal requirements

We may supply personal data to a government authority or regulator where required to:

– comply with a legal requirement,
– for the administration of justice or when required by a public enforcement body, or
– for the purposes of customs, visas and immigration.

We may disclose your personal data where otherwise required by or permitted by law.

11.8 Direct Marketing by third parties

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

11.9 Business Customers who are businesses (not individuals)

If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.
If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

11.10 Business acquirers

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.

 

12. How third parties will handle your personal data

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

12.1 Processing on our behalf

In some cases, your personal data may be held and otherwise processed by others on our behalf. We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy. The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.

12.2 Processing on their own account

In other cases, your personal data 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 your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party and they will provide their privacy policy to you.

 

13. Location of your personal data

We (and any affiliate, subcontractor or other person processing your personal data on our behalf) may transfer, store and otherwise process your personal data anywhere within Australia.
We will only send your personal data outside the Australia to companies either within our group or to parties with whom we have a contract. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. This means within our group and for those other organisations with whom we have contracts we ensure that we have in place adequate safeguards in respect of such transfers outside Australia. You can find out about what adequate safeguards these are by contacting us using the details provided in Section 16 of this privacy notice.

 

14. Keeping your data secure

14.1 Our security measures

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

– only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
– using secured servers to store your information;
– verifying the identity of any individual who requests access to information prior to granting them access to the information
– using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.

Unfortunately transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.
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 data. Please do not include sensitive personal data 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 data to. We never contact you to ask you for your payment card information, or sensitive personal data 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. Your Rights

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 the Australian Information Commissioner’s website at http://www.oaic.gov.au/
To exercise any of your rights below, please contact us as per the contact details provided in Section 16. You can also exercise some of these rights directly through our online form https://ttc.com/personal-data-request/
You may request, we tell you whether we are processing personal data about you, to tell you what personal data we are processing, for what purposes, from which sources we have collected it, who we disclose it to and to provide you with a copy of your personal data that we hold. We will act within one month after receiving a valid request (i.e. when we will have been able to identify you as the data subject). If your request is complex, or if we have a high volume of requests, we may extend this period for two additional months. We will advise you if this is the case.
The law does allow us, in certain cases, to refuse to act upon your request or to charge a reasonable administration fee, if we estimate that the request is manifestly unfounded or excessive We will advise you at the time if this is the case along with your possibility of lodging a complaint with a supervisory authority and seeking a judicial remedy.

15.1 Rectification

You have the right to have your personal data amended if it is inaccurate or incomplete.

15.2 Right to object

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

15.3 Erasure

You have the right to have your personal information deleted or removed in the following circumstances:

– The data is no longer necessary for the purpose for which it was originally collected or otherwise processed;
– Where you withdraw your consent, where consent was used as the legal basis for processing;
– Personal data has been unlawfully processed;
– When you object to the processing and we have no overriding legitimate interest for continuing the processing;
– Erasure is required for compliance with a legal requirement; or
– Data has been collected in relation to the offering of online services to a child.

When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.

We have the right to refuse to act on a request of erasure if the data is necessary for:

– Exercising the right of freedom of expression and information;
– Compliance with a legal obligation;
– The establishment, exercise or defence of legal claims;

15.4 Portability

You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:

– the processing is based on consent or on a contract; and
– the processing is carried out by automated means.

15.5 Restrict Processing

You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:

– You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
– The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
– We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise or defence of legal claims;
– You have objected to processing pending the verification whether our legitimate grounds override yours.

Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so.
We will inform you before the restriction of processing is lifted.

15.6 Right to withdraw your consent

You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10 for details as to how to object to our direct marketing communications.

15.7 Complaints to the Data Protection 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 a concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have. You can contact us using the details provided in Section 16 of our privacy notice.

Changes to this privacy policy

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

Applicable Law and Disputes

Our privacy policy is subject to the law of Australia and disputes can be determined by the courts of Australia.

 

16. Contacting Us

If you have any questions about our privacy policy or about how we process your personal data, including any requests or complaints, please contact us either by e-mail to privacy@downundertours.com, telephone on +617 4047 9066, or by post to Down Under Tours, P.O. BOX 5670, Cairns QLD 4870 Australia.

 

17. About Us

This is the privacy policy of Down Under tours (Australia) Pty Ltd (referred to as “we”, “us” or “our”). We are incorporated under the laws of Queensland, Australia. Our incorporation number is A.B.N. 19 011 012 945 and our incorporation address or registered office is C/O The Travel Corporation, 35 Grafton Street, Bondi Junction NSW 2022 Australia.

 

18. Privacy Shield Statement

The Travel Corporation Inc. (TTC) including all its entities and Subsidiaries in the US complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States.

The Travel Corporation (TTC), has certified to the Department of Commerce that it adheres to the Privacy Shield Principles, namely Notice, Data Integrity and Purpose Limitation, Choice, Security, Access, Recourse, Enforcement and Liability and Accountability for Onward Transfer Principles.  If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/ and https://ttc.com/privacy-shield-statement/. Under Privacy Shield Frameworks, we are subject to the authority of the U.S. Federal Trade Commission.

If you have any questions or concerns relating to our use and disclosure of your personal information in accordance to the Privacy Shield Principles, contact compliance@ttc.com. We will respond to a complaint or inquiry within 45 days of receipt.

We commit to cooperate with the EU data protection authorities or the Swiss Federal Data Protection and Information Commissioner (‘DPAs’), as applicable, and comply with their advice with regards to personal information transfers from the EU or Switzerland. If you believe that your questions or concerns were not addressed by us to your satisfaction, you may also contact the DPA of your place of residence. The dispute resolution by DPAs will be provided at no cost to you.

In certain circumstances, you may also have the right to pursue binding arbitration through the Privacy Shield Framework, as described in Annex I to the Privacy Shield Principles.

If we have received your personal information under the Privacy Shield and subsequently transfer it to a third-party service provider for processing as described in this Privacy Policy, we will remain responsible if they process your personal information inconsistently with the Privacy Shield Principles, except where we can establish that we are not responsible for the violation.

 

19. Copyright Notice

This document, and all content of our websites is Copyright© Down Under Tours (Australia) Pty Ltd 2020. ALL RIGHTS RESERVED.

U by Uniworld Privacy Policy

Last updated: 7 October 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 data. It is important that you read this privacy policy together with any other privacy notices we may provide you on all occasions of personal data 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 data 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 data that you entrust to us.

3. ABOUT US

This is the privacy policy of The Travel Corporation NZ Limited (referred to as "we", "us" or "our"). We are incorporated under the laws of New Zealand. Our incorporation number is (09) 300 1560 and our incorporation address or registered office is 131 New North Road., Auckland, New Zealand. We are an allied member of TAANZ (member no.3487).

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 data unless at least one of the following requirements is met:

• You have given consent to the processing of your personal data 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 data, 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 data for unrelated purposes, based on our legitimate Interest.

• There are some circumstances in which personal data may be processed for purposes that go beyond the original purpose for which the personal data 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 data 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 to derive aggregated data from your personal information. Aggregated data is not considered personal data 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 data so that it directly or indirectly identifies you, we shall treat the combined data as personal data which will be processed with strict guidelines of the GDPR.
• We will not repurpose sensitive data without explicit consent and where we rely on Legitimate Interest; will ensure we conduct 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 data (including information) relating to individuals who: (1) are booking or enquiring about booking travel services with or through us; (2) 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); (3) who are customers or potential customers or recipients of travel services that can be booked with or through us; (4) who register an account with us, including through any website or app of ours; or (5) who upload, post or send anything to or through our websites or apps, or who receive messages through our websites or apps, using any community functionality.

6.2 Examples of who this policy covers

We include in this privacy policy personal data 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 tour 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; and (4) individuals whose personal data from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

6.3 When we are a data processor only

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

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 collect, use and disclose from time to time.

When we refer to "processing" of your personal information, this includes obtaining, 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 data, 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, tours, 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.

When we refer to our "websites", we mean all our present or future websites, including those at the following addresses, and any other website on which these terms of us appear: uniworld.com/nz. References to our websites include: (a) our websites you visit through a web-browser or through an app; and (b) any community functionality and other functionality and services provided by us remotely which you access on or through our websites

When we refer to our "apps" we mean all of our present and future apps, including any apps which this policy is presented with, and references to our apps include (1) any native software application and any software that runs in a web browser, (2) any software that we provide for installation or use on a PC or on a mobile computer such as a tablet or phone, and (3) include any community functionality and other functionality and services provided by us in or through the app, including remotely.

When we refer to "community functionality" this means any service or functionality we provide on or through our websites or apps, which enables you to upload, post or send any content or messages, or receive any content or messages, including any comment or review system, forum, feedback system, survey system, review system, blogging system, picture or video gallery functionality, messaging system, system for posting into other social media platforms such as Facebook or Twitter, and other interactive, social or community functionality.

When we refer to a "device" this includes a personal computer, computer server, tablet, phone, watch, or other computing device, used to access our websites or on which any of our apps is installed and run.

7. WHAT LAWS WE COMPLY WITH

We process your personal data in accordance with the Privacy Act 1993.

Our regulator is the New Zealand Privacy Commissioner: www.privacy.org.nz.

We also comply generally with the laws of New Zealand in relation to the processing of your personal data, and not any other laws.

8. WHAT TYPES OF PERSONAL INFORMATION WE PROCESS

This section summarizes the types of personal data about you that we process:

8.1 Data 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, and utility bills, 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 (such as to verify your identity, address, and credit status), 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 Business Related Information

If you are an individual associated with a business or other organisation that is our customer, then your personal data 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).

8.3 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 data 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.

8.4 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.

8.5 Survey Information

Information collected or generated out of any surveys we conduct.

8.6 Competition Information

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

8.7 Account, Registration and Loyalty Information

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

8.8 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.

8.9 Technical Information about your computer

We may collect technical information and data about or from the device accessing our websites or on which our apps are to be installed and run, including: (1) your IP address (a unique identifier allocated to your device for your connection to the internet); (2) your device's location; (3) your device details, including type of device (PC, tablet, smartphone, watch etc.), the make and model of device, and the features and functionality of your device; (4) the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using; (5) your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc.); (6) your time-zone and language; (7) your browser plug-ins; and (8) cookies previously set and information previously stored by us on your device.. 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 data, if this information is in any way linked to you personally.

8.10 Technical Information about your computer

We may collect information about your usage of your usage of our websites and apps, including: (1) any web-page you came from, identified as the referrer web page address by your web browser; (2) pages you visit; (3) features, services and functionality of our websites and apps you use; (4) website and app performance information, and errors encountered; (5) enquiries and searches undertaken; (6) services and products you viewed; (7) length of visit to websites and pages; (8) page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs); (9) data inputted into forms and fields; and (10) log-in / out information. 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 data, if this information is in any way linked to you personally.

8.11 Community Data

Any content (including text, pictures and video), messages, and other data which you upload, post or send using any community functionality, and any content or messages sent to you personally from anyone else using any private messaging part of the community functionality.

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 Automatic capture

By visiting and using our websites and apps, your device may provide personal data or your device may enable us to capture personal data, or store information and retrieve information previously stored. This includes: information which is automatically provided by your browser or device to our servers; information recorded on our servers about your interaction with and use of our websites and apps, including pages viewed and functionality used; information we capture or place on your computer or generate using cookies or other technologies on our websites or in our apps; and information you input into forms and fields on our websites or in our apps.

9.2 Data you provide

Your personal data will include data you provide (or later amend), including: from correspondence with you; verbally to us over the phone or in person; by filing in any field or form on a website or in an app; 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 any data you provide 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 websites or otherwise; send us your comments or suggestions; subscribe to any newsletter or other publication; request sales and advertising information, including brochures; or upload, post or send anything using any community functionality.

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 to let [Brand Name] and TTC subsidiary 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 Data obtained from third parties

We may obtain personal data concerning you from third parties, including from: 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; and posts and messages sent to you or addressed to you by other customers of ours using any community functionality.

9.5 Data generated by us

We and any suppliers or sub-contractors working for us may generate personal data 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 data or data gained from your use of our websites and apps. 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 data:

10.1 Operate our websites, apps and services

To operate and provide the search, booking, accounts, review, forums and other services, facilities and functions of our websites, including all community functionality. This includes managing any accounts or registrations you have with our websites, apps, community functionality and services, 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 websites, apps, 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

Keeping internal records and maintaining reasonable archives, including concerning enquiries, bookings, contracts, travel services, and complaints. and including for the purposes of disputes, legal proceedings and investigations.

10.7 Promotion, management and Improvement of our business

To promote, develop, analyse, audit, provide, operate, administer, maintain and improve our business, websites, apps, 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 data to help us profile how our customers generally are using our websites and apps and booking travel services with (or through) us, and we may use any Tweets you send using our community functionality to promote our business and services. 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 Advertising

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

10.10 Anything you have specifically consented to

For any purpose which we have obtained your consent to.

10.11 Maintenance of our website and apps

We may use your personal data to maintain and update our websites and apps. For instance, we may use technical information and data concerning your device to facilitate software maintenance and updates and product support.

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 data 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 expressly consented to this, we may disclose your personal information which is contact data (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, advertisements 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 as well as by unsubscribing from their email directly by clicking the ‘unsubscribe’ button at the bottom of any of their emails. 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 DATA

We disclose your personal data to third parties in the following circumstances:

12.1 Credit Checks etc.

We may disclose your personal information to third parties (including intermediaries) as necessary to carry out any checks concerning you or enforce any booking or contract with you (including credit, security, fraud and identity checks). This may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

12.2 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, tour operators etc.).

12.3 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, tour 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 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.

12.4 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.

12.5 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.

12.6 Community Functionality

Where any community functionality or facility on our websites and apps is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), or to have certain of your personal data communicated or made available to others (such as other customers of ours), then any personal data 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, may be disclosed accordingly. Where you have agreed that certain of your personal data is non-confidential, then we may also disclose it for business promotion, management and improvement purposes.

12.7 Legal Requirements

We may supply personal data 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 data where otherwise required by or permitted by law.

12.8 Direct Marketing by third parties

We may disclose your personal data 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.

12.9 Customer Representatives

If our customer is a business or organisation, and we are holding your personal data 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 data. 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 data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

12.10 Business AcquirersIf our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business.

13. HOW THIRD PARTIES WILL HANDLE YOUR PERSONAL DATA

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 collected, used or disclosed 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. LOCATION OF YOUR PERSONAL INFORMATION

We (and any affiliate, subcontractor or other person collecting, using and disclosing your personal information on our behalf) may transfer, store and otherwise collect, use and disclose your personal information anywhere in the world.

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 collect, use and disclose 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 collected, used or disclosed on our behalf, our security measures (as detailed below) will also apply.

Based on the foregoing, some or all of the personal information we collect may be stored or processed on servers located outside your jurisdiction or residence, whose information protection laws may differ from the jurisdiction in which you live. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. Subject to applicable laws in other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require the data processor in that country to maintain protections on the personal information that are equivalent to those that apply in the country in which you live.

15. KEEPING YOUR DATA 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 collection, use and disclosure 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.

We maintain administrative, technical and physical safeguards (appropriate to the sensitivity of such information) designed to protect against unauthorized use, disclosure or access of the personal information we collect on this website. Unfortunately, no data transmission over the internet can be guaranteed to be 100% secure. As a result, while we are committed to protecting your personal information, we cannot ensure or warrant the security of any information you provide to us. All third parties that obtain personal information from us (e.g. service providers or sub-contractors that perform functions on our behalf) are contractually required to protect your confidentiality and personal information in a manner consistent with this policy, and/or as required by law.

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 data

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.

16. HOW LONG DO WE KEEP YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. If you would like to know more about our data retention policy, please ask us.

17. YOUR RIGHTS

17.1 Access to your personal data

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. We may charge a fee for handling your request, in an amount prescribed by law. This fee is $10 as at the date of this policy. 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. 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.

17.2 Use causing substantial distress or damage

You have the right to ask us to stop using your personal information for any purpose in any manner that is causing you or is likely to cause you unwarranted and substantial damage or distress, subject to exceptions.

17.3 Use for direct marketing

You have the right to ask us to stop using your personal information to carry out direct marketing to you as well as to engage in electronic communications with you.

17.4 Correction of inaccuracies

You have the right to ask a court to order us to rectify, block, erase or destroy any inaccurate personal information we hold about you.

17.5 Compensation

You have the right to claim compensation for damage and (in certain cases) distress you suffer if we do not comply with the laws referred to above.

17.6 Complaints to applicable authority

The laws we comply with are regulated by the Privacy Commissioner in New Zealand (www.privacy.org.nz). 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, who has powers to compel us to comply with applicable laws and fine us for non-compliance. 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 notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email 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 New Zealand, and you must bring any claims against us exclusively in the courts of New Zealand.

20. CONTACTING US

If you have any questions about our privacy policy or about how we process your personal data, including any complaints, please contact us either by e-mail, marketingnz@ttc.com, (09) 300 1560, or by post to PO Box 68-640, Auckland, 1145. You may also email compliance@ttc.com for all data privacy matters.

 

COPYRIGHT NOTICE

This document, and all content of our websites is Copyright© The Travel Corporation NZ Limited ALL RIGHTS RESERVED.