This Privacy Notice (“Notice”) sets out how Adventure Tourism Australia, registered in Australia, (ABN 55 722 104 882) and its associated bodies corporate and franchisees worldwide (collectively referred to in this document as “Adventure Tourism Australia”, “we” “our” or “us”) protects the privacy of your personal information.
Adventure Tourism Australia is firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) we will be either the “data processor” or “data controller” for any personal information you provide to us in connection with our relationship. The precise role we will be assuming is dependent on the context of our relationship with you and the purpose of the processing being undertaken.
For the provision of retail travel services by Adventure Tourism Australia, we will be the data controller and this Notice shall apply. Likewise, for the purpose of all our marketing activities (both business travel/event management and retail travel services) we will be the data controller and this Notice shall apply.
By providing personal information to us, you agree that this Notice will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Notice. If you do not agree with any part of this Notice, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Notice, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveller’s full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information. There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Notice. Where this occurs we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.
Depending on the circumstances, in the course of providing a service to you, Adventure Tourism Australia may collect and hold personal information such as:
• your name, date of birth, gender, postal address, telephone number, email address, passport details, medical information and travel insurance details (where applicable);
• details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries; and
• any additional information relating to you that you or a third party has provided to us directly or indirectly through our travellers’ or agents’ phone enquiry lines, websites, online presence, customer surveys or to our in-store or any other representatives.
Information that we collect (such as about your health or religion) may be considered “sensitive information” under the Privacy Act. We collect it to provide you with our services, cater to your needs or act in your interest, and we are only prepared to accept sensitive information on the condition that we have your consent.
If you visit our website or use our mobile applications, we may also collect information that is not personal information to improve the experience for our customers. This information may include the pages you visit, your IP address, browser type and language, and the date and time of your visit. We cannot identify you individually from this information. Some of this information is collected using cookies.
When you are travelling with us, we may take video and images of you that may be used in brochures, in our advertising or on our website. All participants of adventures with Adventure Tourism Australia authorise us to use his/her image (such as a photograph, videotape, film or pictorial representation or recorded voice). If you do not wish for this to happen, please notify us in writing immediately.
What personal information do we collect?
Personal information has the meaning given under your local data protection law, and, where the GDPR applies, the meaning of personal data given under the GDPR. Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf.
We therefore typically process the following types of personal information about you:
- contact information (such as name, residential/mailing address, telephone number, email address);
- payment account information (credit/debit card details, including card type, card number, security number and expiry date);
- passport details;
- loyalty program / frequent flyer details;
- information about your dietary requirements and health issues (if any); and
- other details relevant to your travel arrangements or required by the relevant travel service providers (e.g. airlines and accommodation or tour providers).
When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us. We also collect information that is required for use in the business activities of Adventure Tourism Australia and our related entities, including for example, financial details necessary in order to process various transactions, video surveillance footage used for security purposes, and other relevant personal information you may elect to provide to us.
In some circumstances, we may collect personal information from you which may be regarded as sensitive information under your local data protection laws. Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, criminal record and the alleged commission of an offence, membership of political, professional or trade associations, biometric and genetic information, passwords and financial information and health information, and (in the USA) any personal information relating to a child under the age of 13. We will only collect sensitive information in compliance with your local data protection laws, with your explicit consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorised to do so by law. To the extent permitted or required under your local data protection laws, you consent to us using and disclosing your sensitive information for the purpose for which it was collected, unless we subsequently receive your consent to use it for another purpose. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages, in which case you consent to us using and disclosing that information in connection with facilitating your request. We will not use sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.
How do we collect personal information?
We will only collect personal information in compliance with your local data protection laws. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.
Generally, this collection will occur:
- when you deal with us either in person, by telephone, letter, email;
- when you visit any of our websites; or
- when you connect with us via social media.
- We may collect personal information about you:
- when you purchase or make enquiries about travel arrangements or other products and services;
- when you enter competitions, giveaways or register for promotions;
- when you subscribe to receive marketing from us (e.g. e-newsletters);
- when you request brochures or other information from us; or
- when you provide information, or use our services, on social media.
Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.
In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking.
Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree you have obtained the consent of the other person for Adventure Tourism Australia to collect, use and disclose the other person’s personal information in accordance with this Notice and that you have otherwise made the other person aware of this Notice.
You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.
We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all of your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information relating to you (see section 13 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you, or a person acting on your behalf, provide to us.
How do we use your personal information?
We will only process your information, where:
- you have given your consent to such processing (which you may withdraw at any time, as detailed at section 8 below);
- the processing is necessary to provide our services to you;
- the processing is necessary for compliance with our legal obligations; and/or the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information (as detailed in sections 5 and 6 below).
In detail: Where you contact us in relation to a travel booking or query, the purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Notice (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc.).
When you book or otherwise arrange travel related products and services through us, we usually act as an agent for the relevant travel service providers (e.g. for a hotel). In this case, we process your personal information as necessary so as to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Notice and for the travel service provider for whom we act as agent (e.g. to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.
We act as agent for or on behalf of many thousands of travel service providers around the world, so it is not possible for us to set out in this Notice all of the travel service providers for whom we act or their locations. For more information about the disclosure of personal information to travel service providers located overseas, please refer to section 6 below.
If you have any concerns regarding the transfer of your personal information to a travel service provider, or you wish to contact us for further information, please refer to the “Feedback / Complaints / Contact” section below (section 13).
The purposes for which we collect personal information further include:
- providing you with services and tools you choose to use (for example, saving travel preferences on our websites to a wish list or saving personal information to allow for pre-population of online forms);
- identification of fraud or error;
- regulatory reporting and compliance;
- developing and improving our products and services and those of our related entities;
- servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences;
- involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided;
- to facilitate your participation in loyalty programs;
- for research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and travel destinations and use of our websites;
- internal accounting and administration;
- to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel; and
other purposes as authorised or required by law (e.g. to prevent a threat to life, health or safety, or to enforce our legal rights).
Where permitted by local data protection laws, we may use your personal information to send you targeted marketing activities relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information. These may include, but are not limited to, mail outs, electronic marketing and notifications as described below, and telephone calls). We will only use your personal information to send electronic marketing materials to you (including e-newsletters, email, SMS, MMS and iM) if you have opted-in to receive them. You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of our consultants to do so for you.
Should you no longer wish to receive promotional/marketing material from us, participate in market research or receive other types of communication from us, please refer to the “Feedback / Complaints / Contact” section below (section 13). You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM or other form of electronic marketing. Please also see the “Your rights” section of this Notice to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes (section 8 below).
Is personal information disclosed to third parties?
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Notice and, in particular, as set out below, and in accordance with your local data protection laws. Note that, in this Notice, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise knowingly make available or accessible your personal information to another person or entity.
Your personal information may be disclosed to the following types of third parties:
- our contractors, suppliers and service providers, including without limitation:
- in each of the circumstances set out in section 4 (“How do we use your personal information?”);
- suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting providers we may use);
- publishers, website developers, printers and distributors of marketing material;
- event and expo organisers;
- marketing, market research, research and analysis and communications agencies;
- mailing houses, freight services, courier services; and external business advisers (such as lawyers, accountants, auditors and recruitment consultants);
- our related entities and brands;
- travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
- any third party to whom we assign or novate any of our rights or obligations;
- a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);
- your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;
- a person who can verify to us that they have a relationship with you (e.g. a family member) where you are not contactable, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
- as required or authorised by applicable law, and to comply with our legal obligations;
- customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
- government agencies and public authorities to comply with a valid and authorised request, including a court order or other valid legal process;
- various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including applicable privacy / data protection laws).
On our websites, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with us. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.
Is personal information transferred overseas?
We may disclose your personal information to certain overseas recipients, as set out below. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards as required by your local data protection laws (e.g. GDPR). We will provide you with copies of the relevant safeguard documents on request (see section 13 below).
It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) located in a jurisdiction where you will not be able to seek redress under your local data protection laws and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by your local data protection laws, we will not be liable for how these overseas recipients handle, store and process your personal information.
Our overseas related entities
Your personal information may be disclosed to our overseas related entities in connection with facilitation of your travel booking and/or to enable the performance of administrative, advisory and technical services, including the storage and processing of such information. Security of information
We are committed to safeguarding and protecting personal information and will implement and maintain appropriate technical and organisational measures to ensure a level of security appropriate to protect any personal information provided to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal information transmitted, stored or otherwise processed. Adventure Tourism Australia has implemented various physical, electronic and managerial security procedures in order to protect the personal information it holds from loss and misuse, and from unauthorised access, modification, disclosure and interference. Adventure Tourism Australia consistently reviews security technologies and always strives to protect your personal information as fully as we protect our own confidential information. Adventure Tourism Australia is not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.
We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.
Your rights in relation to the personal information we collect
If you wish to:
access, update, modify, rectify, erase, object to, or obtain a copy of the personal information that we hold on you; or
restrict or stop us from using any of the personal information which we hold on you, including by withdrawing any consent you have previously given to the processing of such information; or
where any personal information has been processed on the basis of your consent or as necessary to perform a contract to which you are a party, request a copy of such personal information in a suitable machine-readable format or have that personal information transmitted by us to another controller
you can request this by emailing us at the address set out in section 13 below. You will receive acknowledgement of your request and we will advise you of the timeframe within which you will receive your information package.
We endeavour to respond to such requests within a month or less, although we reserve the right to extend this period for complex requests.
We reserve the right to deny you access for any reason permitted under applicable laws. Such exemptions may include but not limited to national security, corporate finance and confidential references. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by local data protection laws, will note your request and the denial of same in our records.
You have the right to lodge a complaint with a relevant supervisory authority.
Further correspondence regarding your request should only be made in writing to the Data Protection Officer at the address set out in section 13 below.
Please note that, if you request that we restrict or stop using personal information we hold on you, or withdraw any consent you have given to the processing of such information, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveller’s full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.
You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it is not correct.
You can at any time tell us not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated below (section 13).
In any of the situations listed above, we may request that you prove your identity by providing us with a copy of a valid means of identification in order for us to comply with our security obligations and to prevent unauthorised disclosure of personal information.
We reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal information, and for any additional copies of the personal information you request from us.
Social Media Integrations
Our websites and mobile applications use social media features and widgets (such as “Like” and “Share” buttons/widgets) (“SM Features”). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.
If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them. Similarly, your interactions with the SM Features may be recorded by the third party. In addition, the third party company may send us information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to you via the third party social media platform. You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third party social media platform.
When you access our website, use any of our mobile applications or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet.
We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (e.g. to better tailor our marketing and advertising materials, provided you have opted in to receive electronic marketing).
Tracking Technologies / Cookies
We may use third-party web analytics services on our websites and mobile apps, such as those listed in our Cookies Policy. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.
What are cookies?
Cookies are unique to the web browser you’re using – so if you’re using a desktop computer as well as a mobile, different data will be collected for each. You can find more information on the About Cookies website www.aboutcookies.org/
Cookies can be set by the owner of the website you’re on. These are known as 1st Party Cookies. There are also 3rd Party Cookies that can be set by partner websites. Only the owner of the cookie can see the anonymous information it collects.
You can choose to accept all cookies, reject 3rd Party Cookies or reject all cookies by changing your internet browser settings. If you don’t accept cookies, some features of our website won’t work. For example, you won’t be able to make a booking.
By using our websites, you agree to us using cookies as set out in this statement.
How the cookies are used
• Storing what’s in your shopping basket: This allows you to book trips with us.
• Collecting information: This means we can learn more about how you use our website so we can improve our products and online experience.
• Tailoring your experience: Cookies allow us to provide you with information, products and services that we think you’ll find interesting.
• Making our marketing relevant: We can show you relevant offers and promotions on our own websites and through our advertising networks.
• Make it possible for you to use our website
• Show you information and offers that are relevant to you
• Find out more about how our customers use the site
Buying our products online
Your recent searches and shortlisted holidays are recorded using cookies. If you’ve made a shortlist but you haven’t saved it by entering your email address, we’ll store your shortlisted holidays using a cookie, so you’ll be able to see it when you visit us again using the same computer or device.
Improving your experience
We can find out how you move around our website, so we can look into any errors stopping you from being able to do what you want. The data we collect from cookies is really important for us to improve your experience.
Making your experience personal
We can find out how you move around our website, so we can look into any errors stopping you from being able to do what you want. The data we collect from cookies is really important for us to improve your experience.
Advertisements on other websites
Types of cookies we use
You may choose to opt-out of Google Analytics using the Google Analytics Opt-out Browser Add-on which you may access at https://tools.google.com/dlpage/gaoptout/
Refusing cookies after you’ve accepted
You can change your browser settings to accept or refuse all cookies, choose which cookies you want or don’t want, or ask to be notified when a cookie is set. Use the help feature in your browser to see how.
Changing your mind after you’ve accepted our cookies
Feedback / Complaints / Contact
If you wish to make a Subject Access Request to inform us of a change or correction to your personal information, request a copy of the information we collect on you, request deletion of your information or would like to restrict the further processing of your data, please apply using the following link: www.adventuretourismaustralia.com/promotions
We will respond to these requests within a month of receipt.
If you have any enquiries, comments or complaints about this Notice or our handling of your personal information, please contact your consultant or the Data Protection Officer using the details set out below and we will responds as soon as practicable.
You can contact our Privacy Officer by:
• calling us on +61456698701
• emailing us at firstname.lastname@example.org
• by post to Privacy Officer
Our Privacy Officer will contact you within a reasonable time after receipt of your complaint to discuss your concerns and outline options regarding how they may be resolved. We will aim to ensure that your query or complaint is resolved in a timely and appropriate manner.
Changes to our Notice
We will amend this Notice from time to time. When we make a change to the Notice, the revised version will be posted on our website. We will post a prominent notice on our website to notify you of any significant changes to our Notice and indicate at the end of the Notice when it was most recently updated. It is your responsibility, and we are telling you to check the website from time to time in order to determine whether there have been any changes. If we update our Notice, in certain circumstances, we may seek your consent.
This Privacy Notice was last updated on 27th May 2019