PRIVACY POLICY

Travlect Pty Ltd (ACN 670 335 118) (Travlect) and each of its Related Bodies Corporate (also referred to as “We, us, our” in this Privacy Policy) respects your privacy and is committed to protecting your personal information. Our privacy policy outlines our approach to privacy and how we collect, use and protect your personal information and sets out your rights in relation to accessing the personal information we hold about you.

Capitalised terms not defined in this Policy are defined in our Service Terms, available at https://travlect.com/terms.

1. PERSONAL INFORMATION

1.1. Personal information is defined in the Privacy Act 1988 (Cth) (Privacy Act) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.

1.2. As applicable, we will comply with the Australian Privacy Principles contained in the Privacy Act

2. HOW WE COLLECT PERSONAL INFORMATION

2.1. We only collect personal information you give us directly, or which is collected automatically as part of your activities with us (including usage data or cookies on our website (Site)). For example, when you:

• 2.1.1. give information to our agents or representatives;
• 2.1.2. complete electronic and paper forms;
• 2.1.3. call us;
• 2.1.4. use our Site;
• 2.1.5. send us information via the ‘Contact Us’ page on our Site;
• 2.1.6. view electronic communication that you receive from us, including where you open emails, the links you view from the email and what webpages you view from the email and the number of pages viewed.

2.2. When we collect information, we will ensure the individual has given verifiable consent or there is some other lawful basis for collection and processing. We will generally explain to the individual why we are collecting it, who we give it to and how we will use or disclose it.

3. WHAT PERSONAL INFORMATION WE COLLECT

3.1. The personal information we collect consist of the details necessary to facilitate your travel arrangements, bookings, and organize travel-related services and products for you. This includes:

• 3.1.1. identifying information, including your name, passport details and contact details including your email, home address, billing address;
• 3.1.2. transactional information, including information you provide as part of a transaction with us or that is generated as a result of that transaction;
• 3.1.3. financial information, including payment details, credit card numbers or bank details;
• 3.1.4. information we are required or authorised to collect and process under law to identify you or verify information you have provided;
• 3.1.5. usage information, including data about your interaction with our website through devices you use; and
• 3.1.6. Computer and connection information such as page views, traffic, uniform resource locators (urls), internet protocol (ip) address and web log information.

3.2. When you visit our Site, we may place cookies on your browser to enhance and manage our website and improve our business and the services we provide to you. We and/or google may use this information to optimise and place advertisements, including advertisements of third party vendors, on our own and third party websites. Google’s ability to use and share information collected by google analytics is restricted by the google analytics terms of use and privacy policy. Cookies can be managed by accessing the individual settings in your browser.

3.3. Our site does support “do not track” requests.

3.4. We may collect personal information from people who are not customers or suppliers of our business but whose personal information is given to us by those individuals via our site or in the course of a transaction or recruitment. For example, details of people accompanying you on a holiday. If you give us information you must only do so with that individual’s authorisation and you should inform them of this privacy policy.

3.5. Our services are not intended for children and we do not knowingly collect personal information from individuals who are children.

3.6. We may use social media (including x, meta, instagram, linkedin and facebook) to communicate with you or the public. We may collect personal information that you provide us via social media for the purposes of engaging and consulting with you. Any personal information we collect via social media will be handled appropriately in accordance with this privacy policy. Social media platforms may also collect your personal information for their own purpose and when you agree to their terms of service and privacy policy. To protect your privacy and the privacy of others, you should refrain from posting any personal information (including phone numbers and email addresses) in your comments, tweets or replies.

4. WHY WE COLLECT PERSONAL INFORMATION

4.1. The purpose for which we collect personal information is to enable the effective provision of our services to you and our other customers, including to:

• 4.1.1. execute your requests for our services;
• 4.1.2. place and manage Bookings on your behalf;
• 4.1.3. improve and optimise our services, business and our users’ experience;
• 4.1.4. send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
• 4.1.5. send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting. You may opt out of receiving these direct marketing communications at any time. Our electronic marketing activities will comply with the requirements of the Spam Act 2003 (Cth);
• 4.1.6. administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• 4.1.7. comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties; and

5. WHEN WE WILL USE, PROCESS OR DISCLOSE PERSONAL INFORMATION

5.1. We will only use, process or disclose your personal information for the primary purpose for which it was collected or otherwise as relevant national laws allow.

5.2. We may otherwise use and disclose your personal information to detect, prevent and investigate fraudulent behaviour, if you have given us consent for the use or disclosure or it is required or authorised by law.

5.3. You consent to us disclosing your personal information to Suppliers for the purposes of making and managing your Bookings, and for us to provide you with our Services.

5.4. To the extent we provide personal information to any third party, including Suppliers of Travel Products, we will take appropriate and reasonable steps to ensure any personal information is protected.

5.5. We may disclose personal information for the purposes described above to:

• 5.5.1. Suppliers of Travel Products and their agents or representatives;
• 5.5.2. our employees, agents and related bodies corporate;
• 5.5.3. data processors, including third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing our products and services to you);
• 5.5.4. professional advisers, dealers and agents;
• 5.5.5. payment systems operators (e.g. merchants receiving card payments);
• 5.5.6. our existing or potential agents, business partners or partners;
• 5.5.7. our sponsors or promoters of any competition that we conduct via our Services;
• 5.5.8. anyone to whom our assets or businesses (or any part of them) are transferred;
• 5.5.9. specific third parties authorised by you to receive information held by us; and/or
• 5.5.10. other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

5.6. If you choose to make a Booking by phone and opt for credit card payment, you consent to us processing any credit card payment in your capacity as purchaser of the Travel Product regardless of whether the credit card details you provide belong to you. If, at your direction, we process a credit card payment using the credit card details of any third party who is not the purchaser of the product (the Third Party Payment), you indemnify us for all liability including all claims, demands or actions the third party may take against us with respect to the processing of the Third Party Payment.

6. DIRECT MARKETING

6.1. You agree to Travlect using and/or disclosing any personal information collected from you for the purpose of direct marketing, whether obtained via telephone, our Site, or any other means, in accordance with this Privacy Policy and applicable Laws (including the Spam Act (Cth)).

7. MAINTAINING ACCURACY OF INFORMATION

7.1. We will take reasonable steps to ensure that all personal information we collect, use or disclose is accurate, complete and up to date.

7.2. To ensure the accuracy of our information, we recommend that you:

• 7.2.1. notify us of any errors in your Personal Information; and
• 7.2.2. keep us up to date with recent changes to your Personal Information such as your name or address. You may change your personal details by using the relevant facility on our Website or by contacting the Data Protection Officer.

8. SECURITY AND RETENTION OF PERSONAL INFORMATION

8.1. Travlect takes reasonable steps to protect the personal information we hold against loss, unauthorised access, use, modification or disclosure and against other misuse. For example, we use secure hard copy document storage, implement security measures for access to our security systems, use two factor authentication and ensure data is transferred using encrypted hypertext transfer protocol secure]. However, we cannot guarantee the security of your personal information.

We will only use, process or store personal information and sensitive information for as long as required by the purpose it has been collected, including where such purpose relates to our legitimate interest, and for a longer period where you have given consent to such processing, as long as such consent is not withdrawn. We may be obliged to retain personal information for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority

9. ACESSING, CORRECTING OR MANAGING YOUR INFORMATION

9.1. You have certain rights in relation to the personal information we collect and hold about you. We will allow an individual to:

• 9.1.1. You have certain rights in relation to the personal information we collect and hold about you. We will allow an individual to:
• 9.1.2. request us to correct or update information we hold about you.

9.2. Notwithstanding the above, we may refuse to provide you with access to your Personal Information if required or permitted by Law.

9.3. We will take reasonable steps to correct our records containing your Personal Information as soon as practically possible in accordance with the Privacy Act.

10. MAINTAINING YOUR ANONYMITY

10.1. We will not compel visitors to its website to provide Personal Information unless necessary to respond to an inquiry or deliver a service.

10.2. We will permit its members to transact with it anonymously or by using a pseudonym wherever that is reasonable and practicable.

11. WHERE YOUR PERSONAL INFORMATION BE HELD AND PROCESSED

11.1. We will process your personal information in our servers in Australia.

11.2. We will provide your information to third parties that provide services to us solely for the purpose of providing those services, including third parties that provide our payment gateway, marketing and technology support services. This may include providing your information to third parties that are located outside of Australia.

11.3. We also need to provide your personal information to Suppliers in order for us to make and manage your Bookings, many of which are not located in Australia.

11.4. Information that is disclosed to Suppliers will be collected, processed and disclosed in accordance with their respective privacy policies, which form part of the Supplier Conditions you agree to when making a Booking.

11.5. Where your personal information is transferred outside Australia (including to Suppliers), we will take steps to ensure that overseas recipients will deal with that information in a way that is consistent with the Privacy Act or applicable national laws.

12. REVIEW AND CONTACT

12.1. This privacy policy will be reviewed annually at a minimum, following an information security incident or significant changes to our systems; and following changes to the relevant privacy legislation, including the Privacy Act.

12.2. Travlect has appointed a Privacy Officer who can be contacted by email: Attention: Privacy Officer, at support@travlect.com.au

12.3. To make a complaint about how we handle your personal information, you may contact our Privacy Officer. We will respond to your complaint within a reasonable time after it is received. If you are not satisfied by our response, you may acquire further information regarding privacy from the Office of the Australian Information Commissioner.