The Travel Corporation
Last updated: 3 June 2015
Please click on a link below to jump to a
1. About This Document
2. Your Consent
3. Copyright Notice
4. About Us
5. Contacting Us
6. Our Commitment
8. What Laws We Comply With
9. What Types Of Personal Information We
10. How We Collect Or Generate Your Personal
11. What Do We Use Your Personal Information
12. Use Of Your Personal Information For
13. Disclosure Of Your Personal Information
14. How Third Parties Will Handle Your
15. Location Of Your Personal Information
16. Keeping Your Information Secure
17. How Long Do We Keep Your Personal Information
18. Your Rights
20. Applicable Law And Disputes
21. Linked Websites
About This Document
This document sets out our privacy
policy in respect of your personal information, which governs the way we collect,
use and protect any personal information that you provide to us. It serves as
an expression of our commitment to protecting your personal information, but is
not a contract between you and us. Please see Section
for your rights in relation to your personal information.
using our websites, using our social media channels, posting comments about us
in any forum, providing any personal information to us, making enquires with us
for travel services, creating an online account or booking any travel services
with us, you confirm that you agree to and consent to the terms of this
document and our collection and use of your personal information, to the extent
that your consent is required by any applicable law.
This document, and all content of
our websites is Copyright© The Travel Corporation Australia 2015. ALL RIGHTS
(referred to as "we",
"us" or "our").We are incorporated under the laws of New
South Wales. Our registered office is
35 Grafton Street, Bondi Junction, New South Wales 2022
If you have any questions about our
complaints, please contact us either by e-mail to email@example.com,
telephone on 02 9028 2277, or by post to TTC Privacy Officer,
35 Grafton Street, Bondi Junction, New South
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 that you entrust to us.
process personal information relating to individuals who are booking or
enquiring about booking travel services with or through us or who are the
recipients of any travel services booked with or through us (e.g. you are the
passenger for a booking or booking enquiry made by someone else for you), or
who are customers or potential customers or recipients of travel services that
can be booked with or through us.
Examples of who this policy
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 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;
(4) individuals who visit our website or other online sites operated by us or
our contractors or affiliates; (5) individuals who create an online account (if
applicable); (6) individuals whose personal information from other companies in
our group (such as where you have consented to your personal information being
disclosed to other group companies for marketing purposes); and (7) individuals
or businesses from any other arrangement with us.
When we are an information
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
Terms used in this policy
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, 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
What Laws We Comply With
We process your personal information in accordance with the
following privacy law(s): the Australian Privacy Principles contained in the
Privacy Act, 1988 which regulates the handling of personal information about
individuals. This includes the collection, use, storage and disclosure of
personal information. Our regulator is the Office of the Australian Information
Commissioner (OAIC) (http://www.oaic.gov.au/)
We also comply generally with the laws of Australia in relation to
the processing of your personal information, and not any other laws.
What Types Of Personal Information
This section summarises the types of
personal information about you that we process:-
Information concerning you as
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.
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.
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).
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. 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
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.
Information collected or generated
out of any surveys we conduct.
Feedback and user generated content
Information or content provided
by you in relation to your feedback or experience on a past current or future
trip with us.
Information collected or generated
out of any competitions or promotions we run.
Account, registration and loyalty
Information concerning any accounts,
registrations, or memberships with us, or participation in any loyalty program.
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
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.
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
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.
How We Collect Or Generate Your Personal
This section sets out the ways in
which we may collect or generate personal information concerning you.
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.
Information you provide
Your personal information will
include information you provide (or later amend), whether: from correspondence
with you; verbally to us over the phone or in person; by filing in any field or
form on a website; by posting on our social media channel; by posting on any
forum referencing us; by filling in any printed form we provide you with; by
e-mail; from documents you provide use with; and from updates to any
information to provide from time to time.
This includes when you: register or subscribe for any service, account,
members, or loyalty program, or make an enquiry or bookingfor 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.
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.
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.
What Do We Use Your Personal Information For?
This section sets out the uses which
we make of your personal information:
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.
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.
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.
collect and make payments due and administer our accounts.
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.
To keep internal records and
maintain reasonable archives, including concerning as to enquiries, bookings,
contracts, travel services, and complaints.
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.
To carry out direct marketing to
you. See next section below for further
User Generated Content (UGC)
Use of Reviews:
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 The Travel Corporation 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.
Use of User Generated Content (UGC)
submitting content to our social media channels or websites you grant us a
non-exclusive license to use the content you add to our websites. For example,
we may use this information in any of our brochures or for our campaigning
purposes or marketing materials.
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.
To meet our legal obligations.
Anything you have specifically consented to
Any purpose for which we have
obtained your consent.
Use Of Your Personal Information For Direct Marketing
We do not use or disclose your personal information for direct
marketing purposes unless we have obtained your consent to this, such as
through an opt-in or opt-out tick box on any form or website of ours.
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.
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.
Disclosure Of Your Personal Information
We transfer your personal information
to third parties in the following circumstances:-
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.).
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.
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.
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.
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.
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.
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.
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.
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.
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:-
Processing on our behalf
In some cases, your personal information
may be held and otherwise processed by them on our behalf, in which case we
will remain responsible for what they do with your personal information, and
your personal information will only be held and processed by them in accordance
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
with it following disclosure.
Location Of Your Personal
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.
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.
Keeping Your Information Secure
Our security measures
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.
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”.
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.
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.
How Long Do We Keep Your Personal Information For?
We keep your personal information
for so long a is reasonably necessary for the purposes for which we use it, and
if longer, for any duration required by law, and for statutory claims limitation
periods where your personal information may be relevant to any possible
liability we may have to you.
to create a contract or form part of any contract. You have certain
non-contractual rights under the laws noted above, which we summarize below. If
you contact us about these rights, we may ask for proof of your identity before
we act, and may refuse to act if you do not provide this or your identity is
not established by you.
Access to your personal information
We will, on written request, provide
you with access to information we hold about you, including for the purpose of
correcting or updating such information, unless there is an exception which
applies under the Privacy Act, 1988.
Your request for access will be dealt with in a reasonable time and we may
recover from your our reasonable expenses incurred.
If we refuse to provide you with
access to information we hold about you, we will provide reasons for such
refusal and inform you of any exceptions relied upon under the Privacy Act, 1988.
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 email
firstname.lastname@example.org, or telephone on 02 9028 2277. In any e-mail
you send we would ask you to insert "unsubscribe" as the subject
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.
Complaints to applicable authority
The laws we comply with are regulated
by the Australian Information Commissioner.
In addition to your rights above, it is open to you, if you have a
complaint or concern, to seek assistance from such government regulator.However, before you do so, we would hope that
you will contact us first to discuss any complaint or concerns you have.
For more information on privacy, you
can contact the Australian Information Commissioner’s hotline on 1300 363 992
or if outside of Australia + 61 2 9284 9749, or visit the Office of the
Australian Information Commissioner website at http://www.oaic.gov.au/.
any time and from time to time without notice to you, including by publishing a
each time you visit our website to be sure that you are aware of any
changes. You should check the top of the
document to see the latest version in force.
Any change will be prospective only, and we will not make any changes
that have retroactive effect unless legally required to do so.
Applicable Law And Disputes
This policy is subject to the law of Australia. You may obtain
further information regarding privacy issues in Australia by visiting the Australian
Information Commissioner’s website at
Our websites contain 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.
End of Document