1. INTRODUCTION 1.1 Holiday Concepts Group of Companies Holiday Concepts and its subsidiaries operate a range of businesses including the operation of call centres, resorts, customer/travel service companies, administration and sales business(s). Through these operations, Holidays Concepts from time to time gathers information from Customers and other parties with whom we deal for a variety of reasons. Holiday Concepts understands individuals' concerns regarding confidentiality and takes seriously its obligations in respect of all information it gathers. To safeguard that information, Holiday Concepts has implemented a program to ensure compliance with the Privacy Act 1988 (Cth) and the National Privacy Principles ("NPPs"). This Privacy Policy outlines how Holiday Concepts deals with Personal Information. Back to Top 2. WHY HOLIDAY CONCEPTS COLLECTS PERSONAL INFORMATION 2.1 Nature of Information The information Holiday Concepts collects in most cases relates to Customers but can relate to suppliers and other parties we deal with (for the purpose of this Privacy Policy all such people are described as "Customers"). Information is gathered for a range of purposes, including the provision of ongoing Customer support and the compiling of Customer databases to enable us to more accurately market our goods and services. The type of information we collect includes such things as contact details, buying habits, opinions, product preferences and transactional details. Holiday Concepts treats all such information which is collected and identifiable as relating to an individual as Personal Information. It is this Information which is described as "Personal Information" for the purposes of this Privacy Policy. 2.2 Collection of Information In accordance with the NPPs, where practical, Customers of Holiday Concepts may deal with Holiday Concepts on an anonymous basis. However, as a provider of a wide range of services, Holiday Concepts frequently finds that it is necessary to collect Personal Information during the course of transactions. Personal Information may be collected about Customers via the following means: a) competition entry forms; b) application forms; c) email; d) websites; e) online transactions; f) networking functions (eg: business cards); g) over the phone; h) credit card details via credit card purchases; i) information collected from third parties; and j) Customer surveys. 2.3 'sensitive information' a) the Customer provides their consent; b) the collection of that information is specifically authorised by law; c) the collection is necessary to lessen a serious or imminent threat to the health or safety of a person; or d) the collection of the information is necessary for the establishment, exercise or defence of a legal claim. 2.4 Customer consent Wherever practical, Holiday Concepts will obtain the express consent of Customers to the collection of Personal Information. In some situations, Holiday Concepts will interpret a Customer's actions as indicating that a Customer consents to the collection of Personal Information. This may occur where the Customer has provided Personal Information for a particular purpose and that purpose cannot be achieved without Holiday Concepts making use of the Customer's Personal Information. Back to Top 3. MAINTENANCE AND MANAGEMENT OF PERSONAL INFORMATION 3.1 Who may view Personal Information In general, only officers, employees, contractors or common equity partners of Holiday Concepts may view Personal Information. Holiday Concepts will only grant access to parties other than Holiday Concepts officers, employees and contractors to view Personal Information where Holiday Concepts believes that access is necessary to achieve the purpose for which the Personal Information was collected. Holiday Concepts will only disclose Personal Information to parties other than Holiday Concepts officers, employees and contractors if: a) that disclosure is required to give effect to ongoing Customer support or marketing services which Holiday Concepts may be of Benefit to the Customer; b) the Customer has consent to that disclosure; c) Holiday Concepts believes that the disclosure may lessen a risk of harm to the health or safety of any person; d) Holiday Concepts believes an unlawful activity is being undertaken and the Personal Information is disclosed as part of Holiday Concepts investigation into this activity; e) Holiday Concepts is required by law to disclose the Personal Information; or f) The disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue. 3.2 Identification Holiday Concepts does not use any prohibited identifiers (such as a tax file number) to identify its Customers. 3.3 Storage and Security Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is wherever practical, kept under locked security. Personal Information stored on computer is wherever practical, password locked. Where possible and practical, Holiday Concepts will endeavour to comply with recognised Australian and international standards relating to information security. Holiday Concepts regularly deletes and de-identifies Personal information if the information is no longer needed by Holiday Concepts. 3.4 Updating Personal Information Holiday Concepts regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis. Customers can update their Personal Information at any time by contacting the Holiday Concepts Privacy Officer. Back to Top 4. MINORS Holiday Concepts has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed. Where Holiday Concepts is aware that it is gathering information from a minor, Holiday Concepts will obtain consent from a legal guardian for the collection of the information. Where this is not possible, Holiday Concepts staff will make a determination as to the minor's understanding of why the Personal Information is being collected, before deciding to collect that information. Back to Top 5. COMPETITIONS Personal Information gathered during competitions run by Holiday Concepts will be governed by the principles set out in this Privacy Policy unless an express statement is made in relation to privacy in the conditions of entry for the competition. Back to Top 6. DIRECT MARKETING Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Customer as provided for in this Privacy Policy. In circumstances where Holiday Concepts cannot practically obtain the consent of a Customer, then Holiday Concepts may still engage in direct marketing to that Customer, but will if requested: a) allow the Customer to be taken off the mailing list at any time; and b) display its contact details clearly in each direct marketing publication. Customers may be taken off any mailing list be contacting Holiday Concepts Privacy Officer. Back to Top 7. ACCESS TO PERSONAL INFORMATION Customers may access their Personal Information by contacting Holiday Concepts Privacy Officer. Access is generally granted within 30 days of that request. Holiday Concepts may impose a reasonable charge for access. Back to Top 8. WHEN HOLIDAY CONCEPTS MAY WITHHOLD ACCESS TO PERSONAL INFORMATION 8.1 When access can be withheld Access to Personal Information may be withheld in a number of circumstances. These include where: a) providing access would pose a serious and imminent threat to the life or health of a person; b) providing access would have an unreasonable impact on the privacy of others; c) the information is subject to confidentiality where the person who provided the information to Holiday Concepts did so expressly on the condition that it remains confidential; d) the request is vexatious or frivolous; e) the information relates to current or anticipated legal proceedings between Holiday Concepts and the person and the information would not be required to be discovered to a court; f) Holiday Concepts is in commercial negotiations with the person and the information would reveal Holiday Concepts intentions; g) Providing access would be unlawful or Holiday Concepts is required by a law to withhold access; or h) Providing access could prejudice the investigation or detection by Holiday Concepts or by a government body of an unlawful activity or some serious or improper misconduct. Where Holiday Concepts does withhold Personal Information, Holiday Concepts may instead choose to give the Customer a summary of that information. 8.2 Written reasons If Holiday Concepts does withhold Personal Information, Holiday Concepts will provide written reasons. 8.3 Third party intermediary If Holiday Concepts withholds access to Personal Information, Holiday Concepts will consider whether the provision of access to an independent third party will meet Holiday Concepts and the relevant Customer's needs. Back to Top 9. CONTRACTORS Holiday Concepts may from time to time employ subcontractors to provide services to it. In these situations, Personal Information may be collected about those subcontractors. This Privacy policy applies equally to those subcontractors. Back to Top 10. WHO TO CONTACT If you have any queries with respect to this Privacy Policy please contact our Privacy Officer at Holiday Concepts, 571 Bridge Road, Richmond VIC 3121. Back to Top 11. MODIFICATIONS TO THIS DOCUMENT Holiday Concepts may modify this Privacy Policy and the way it handles Personal Information at any time at its sole discretion. Back to Top 12. FURTHER INFORMATION Further information on privacy can be obtained from the Privacy Commissioner at www.privacy.gov.au. Back to Top