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 indonesia.travlr.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 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.
We may also collect information how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
Tracking Cookies Data
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
- Session Cookies. We use Session Cookies to operate our Service.
- Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
- Security Cookies. We use Security Cookies for security purposes.
Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
TRAVLR Pty Ltd may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it's not overridden by your rights
- For payment processing purposes
- To comply with the law
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; and
- 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.
Transfer Of Data
Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
Disclosure Of Data
Disclosure for Law Enforcement
Under certain circumstances, TRAVLR Pty Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
TRAVLR Pty Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:
- To comply with a legal obligation
- To protect and defend the rights or property of TRAVLR Pty Ltd
- To prevent or investigate possible wrongdoing in connection with the Service
- To protect the personal safety of users of the Service or the public
- To protect against legal liability
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
"Do Not Track" Signals
We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
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.
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; and/or
- provide any other services that you or your organisation have contracted us to provide.
Your Data Protection Rights Under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. TRAVLR Pty Ltd aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where TRAVLR Pty Ltd relied on your consent to process your personal information.
We may employ third party companies and individuals to facilitate our Service ("Service Providers"), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on - https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Facebook remarketing service is provided by Facebook Inc. You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook's interest-based ads follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the
USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors).
The payment processors we work with are:
Commonwealth Bank of Australia
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:
May 26, 2018