At TRAVLR, we recognise the importance of your privacy and understand your concerns about the security of the Personal Information you provide to us, whether via the TRAVLR Platform or otherwise.
We are bound by the Australian Privacy Principles (APP) contained in the Privacy Act (subject to exemptions that are applicable to us under that Act), our general law obligations of confidentiality to you and all other applicable guidelines and codes in Australia.
We may, from time to time, review and update this Policy, including taking account of new or amended laws, new technology and/or changes to our operations and practices. All Personal Information held by us will be governed by the most recently updated Policy. Accordingly, please also regularly check our Policy so that you are aware of these updates and changes. If you have any questions, please contact us at us at TRAVLR Pty Ltd, www.travlr.com/contact-us or via email firstname.lastname@example.org.
For the above reasons, we recommend that you please read the following details carefully.
"Health Information" is information or an opinion about an individual's health or disability, the health services provided or to be provided to them, their expressed wishes for the provision of future health services, personal information collected to provide a health service, personal Information collected in connection with organ and body-part donation, and predictive genetic information.
"Personal information" is information or an opinion about an identified individual, or about an individual who is reasonably identifiable, whether or not the opinion is true or not and whether or not the information is stored in material form or not.
“Privacy Act” means Privacy Act 1988 (Cth).
"Sensitive Information" is a special category of Personal Information. It is information or an opinion about an individual's racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices, criminal record, Health Information about an individual or genetic information about an individual that is not otherwise health information.
"TRAVLR", "we", "us" or “our” means any member of the TRAVLR Group.
TRAVLR Group means TRAVLR Pty Ltd ACN 613 747 845 and each of its subsidiaries.
"TRAVLR Platform" means, collectively, the website, mobile application and any other related applications, which are owned or operated by TRAVLR and includes the websites located at www.travlr.com and www.thebalibible.com.
What kinds of information will we collect and hold?
The kinds of Personal Information that we commonly collect and hold from you or about you include: your name, gender, address, phone, fax and mobile numbers, email address, date of birth and interests. We may also collect other types of Personal Information such as your travel experience, objectives, preferences, plans, photos and style and any other information in connection with your travel plan and/or experience.
When you browse the TRAVLR Platform or contact us electronically, we may record geographical tagging, cookies, statistical data and your IP (internet protocol) address to help customise your user experience and to administer the TRAVLR Platform.
To make a travel reservation or booking (such as flights, accommodations, tours etc) via the TRAVLR Platform, you may be requested to provide details of a payment mechanism, such as bank and credit card details, authentication code and billing address. We will securely transmit this information to the supplier of the travel reservation or booking to complete the transaction. Please note that we do not generally bank details, although we may store your credit card details until you request us to delete such details.
We do not generally collect sensitive information from you or about you unless there is a legal requirement to do so, or unless we are otherwise permitted by law. In all other situations, we will specifically seek your consent.
How do we collect that information?
We collect Personal Information from you or about you in a number of ways, including:
- when you visit and interact with the TRAVLR Platform and related software;
- when you sign up an account with us or sign up for our newsletter;
- submit correspondences to or otherwise communicates with us or via the TRAVLR Platform, whether in writing or by email, facsimile or post;
- when making a travel reservation or booking via the TRAVLR Platform;
- when you share your travel experience via the TRAVLR Platform or otherwise provide reviews, opinions and feedback about your travel experience or destination;
- when you browse the TRAVLR Platform and/or other linked or associated social media platforms;
- when you provide any other material to us or to any other persons connected to your travel plan;
- through information about you that is available on the internet or that is otherwise published.
We may also collect Personal Information from third parties such as law enforcement agencies and other government entities and any third party service provider who is contracted to provide payment processing services.
Where you have provided us with the Personal Information of another person (e.g. your travel companion or partners), you confirm that every person whose Personal Information has been provided to us by you has been notified of this and has agreed to the collection, process, disclosure and use of their personal information as set out in this Policy and any of our terms and conditions. You also confirm that you will inform such persons that they may have rights of access to, and correction of, their personal information.
In addition, in connection with your use of the TRAVLR Platform, we may also collect cookies and IP address from your computer, which enables us to tell when you use the TRAVLR Platform and also to help customise your user experience.
You can be anonymous or use a pseudonym when dealing with us, unless:
- the use of your true identity is a legal requirement; or
- it is impracticable for us to deal with you on such basis.
How do we hold that information?
Your Personal Information is held and stored on paper, by electronic means or both. We have physical, electronic and procedural safeguards in place for Personal Information and take reasonable steps to ensure that your Personal Information is protected from misuse, interference, loss and unauthorised access, modification and disclosure.
The purpose for which we collect, hold, use and disclose Personal Information
Generally, we collect, hold, use and disclose your Personal Information to assist you, your travel partners and/or other users in planning your trips, to provide services we offer and to provide you with travel related information.
We collect, hold, use and disclose Personal Information from you or about you primarily for the following purposes (where applicable):
- to establish, maintain and administer your account;
- to provide our services to you, including assisting you in your travel plan and in making reservations or bookings in connection with your future trips;
- to answer your queries and communication with you in general;
- to assist and facilitate payments for any travel bookings or reservations made by you via the TRAVLR Platform;
- for our administrative and accounting functions, fraud checks, marketing and promotions, newsletter communications, website traffic analysis;
- to allow you to share your review, experience, feedback, opinions, photos and/or other content to all or some of the other users of the TRAVLR Platform;
- to measure interest in a particular destination;
- to send you news, promotional or other information about tours, accommodations, flights and/or other products or services offered by us and/or our partners, unless you opt out;
- for reporting, research and analysis purposes in order to help develop tourism;
- to help us customize the content, experience, and advertisements provided to you on the TRAVLR Platform;
- for any other purposes disclosed at the time of collection.
Where we use your Personal Information for marketing and promotional communications, you can opt out at any time by notifying us.
We will also disclose your information to third party contractors or providers that we retain or use to assist us providing services to or for you, including database design contractors, our internet service provider and our professional advisers (such as our accountants or lawyers).
We may also share certain information about you or your travel plan or experience with the following entities:
- suppliers, including but not limited to hotel, airline, cruise, car rental, or activity providers, or vacation rental managers or owners in order to facilitate your travel reservations and/or bookings or to assist you in planning your future tours or trips;
- business partners with whom we may offer products or services in conjunction.
- members within the TRAVLR Group to allow us to provide you with information about products and services, both travel-related and other, which might be of interest to you.
- other users of the TRAVLR Platform if you choose to create a profile on the TRAVLR Platform or share your travel experience, feedback or reviews with other users or the public via the TRAVLR Platform; however, we do not generally share your email address with any other members nor display it any public manner.
Other than as set out above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.
We also may share aggregate or anonymous information with third parties, including business partners, advertisers and/or government stakeholders for the purposes set out above and/or of reporting, research and analysis purposes. Please note that this information does not contain any personal information about you unless you have consented to the disclosure or use of your personal information.
We will not disclose Personal Information about you for any other purposes, except that we may disclose or use your Personal Information where:
- we are under a legal duty to do so, including circumstances where we are under a lawful duty of care to disclose information; or
- such disclosure is authorised or permitted by the APP, law or you.
What is the main consequence for you if you do not provide your information to us?
You can choose not to provide your Personal Information to us. However, if you do not provide your Personal Information to us, you may be unable to:
- use or navigate the TRAVLR Platform or any engage in certain TRAVLR Platform related activities;
- receive any relevant travel related offerings from TRAVLR and its partners and suppliers;
- participate in discussion forums;
- share your travel experience, feedback, reviews, photos and suggestions to other users of the TRAVLR Platform;
- make travel reservations and bookings for your future trips;
- find out travel related information about your future travel plans; and/or
- communicate with us regarding your queries.
Additionally, if you do not provide your Personal Information to us, we may be unable to
- assist you in your travel plan and making any related bookings or reservations such as tours, flights, accommodations, dining etc;
- provide you with information about your proposed travel destination or relevant to your travel plans;
- answer your enquiry;
- provide any other services that you or your organisation have contracted us to provide.
Destruction and De-identification
We will retain your Personal Information whilst it is required for any of our business functions, or for any other lawful purpose.
We use secure methods to destroy or to permanently de-identify your Personal Information when it is no longer needed.
Paper records are commonly sent for secure destruction.
Electronic records are deleted from all locations, to the best of our ability, or encrypted and/or placed beyond use.
The TRAVLR Platform is affiliated with or utilises the services of other businesses located both in Australia and overseas. It is noted some of the third-party companies, agents, and contractors that we engage to perform services on our behalf may need to transfer or disclose your personal information internationally in order to provide their services. We may also transfer or disclose your Personal Information between members within the TRAVLR Group, located globally.
Accordingly, your Personal Information may be disclosed to, stored, and processed by organisations in Australia and any other counties. It is noted that some territories organisations may not have data protection laws as comprehensive as those set out in this Policy and the APP.
While we have implemented measures to safeguard your personal information in accordance with this Policy at all times, we may not have control over the use, collection, disclosure and retention of your Personal Information by the organisation to which we disclose your Personal Information. We may not require organisations to which we disclose Personal Information in those countries to comply with similar privacy laws. Accordingly your personal information may not receive the same protections that it would in Australia, and you may not be able to seek redress in the overseas jurisdiction.
By using and accessing the TRAVLR Platform and providing your Personal Information to us, you expressly consent to our disclosure of your Personal Information to those third parties with whom we share it as described in this Policy.
How do we keep Personal Information accurate and up to date?
We rely on the Personal Information we hold about you in providing you with our services or otherwise conducting our business. Therefore, it is important that the information we hold about you is accurate, complete and up-to-date. This means that from time to time we may ask you to tell us if there are any changes to your Personal Information. To assist us to keep our records up-to-date, please advise us immediately when your personal details change.
How are you able to access to your Personal Information
We have procedures in place for dealing with and responding to requests for access to the Personal Information held about you.
In most cases, we expect that we will be able to comply with your request. However, if we do not agree to provide you access to information as requested, we will give you written reasons why. For further information, please contact us at TRAVLR Pty Ltd, www.travlr.com/contact-us or via email email@example.com.
Enquiries & complaints
We have procedures in place for dealing with complaints and concerns about our practices in relation to the Privacy Act and the APPs. We will respond to your complaint in accordance with the relevant provisions of the APPs. For further information, please contact our Privacy Officer at firstname.lastname@example.org.
You can contact us as follows:
30 November 2017