Introduction
The Walshe Group, a subsidiary of Southern Travel Holdings (STH) understands that privacy is important to our customers and business contacts. At STH we are committed to protecting and maintaining your privacy. STH is bound by the Australian Privacy Principles, which are contained in the Privacy Act 1988 (Australia) and by the New Zealand Privacy Principles, contained in the Privacy Act 1993 (NZ). As part of our business operations we may collect your personal information. This Privacy Policy describes the type of personal information we may collect and how we use, store and disclose this personal information. If you have any questions regarding this privacy policy, please contact our Privacy Officer using the contact details below.
Kind of information that we collect and hold
In the course of operating our business, STH may collect personal information about you. Personal information is basically information or an opinion that can identify you. In general, the type of personal information STH collects and holds could include (but is not limited to) your name, address (postal and email), mobile or day time telephone number, geographic location (including your suburb or post code), gender, transaction details relating to your use of STH services and any preferences you tell us about.
How we collect information
The types of personal information that STH collects about you will depend on the nature of your dealings with us. We may collect your personal information over the internet, over the phone, when you write to us, when you attend an event run by us or when you participate in a survey, questionnaire, competition or other marketing campaign run by us or our partners. We only collect personal information that we need for our business activities, or which is volunteered to us. STH collects personal information from:
Individuals
This includes (but is not limited to) information about people who contact STH via our websites and ask to receive any communications (including but not limited to signing up online to receive regular newsletters and other marketing communication). STH may also collect your personal information when STH conducts competitions or promotions.
Business Contacts
STH may collect contact information from people with whom we do business (such as contact people in regulatory bodies, or in our external service providers). If you are a business contact of STH, we may collect contact information about you including your name, your position and the organisation you work for, your business telephone and mobile number and your email address.
Our Employees and Contractors
STH needs personal information about our employees and people who work for us as contractors. The handling of personal information about our employees and contractors is addressed in STH Company Policies which is available from the Human Resource Department.
How we hold personal information
STH may hold your personal information in electronic or hard copy format or a combination of both. We have taken a number of physical, electronic and procedural steps to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure.
STH protects the personal information it collects in secure databases. STH employs firewalls, intrusion detection systems and virus scanning tools to protect against unauthorised persons and viruses from entering our systems.
STH employees are required, as a condition of their employment, to treat personal information held by STH as confidential, and to maintain the confidentiality of that personal information. They are also required to use a login and password when accessing STH systems.
How use personal information
Generally, we only use personal information for the primary purpose for which we have collected it, or for another closely related purpose. The uses include the following:
- Conducting competitions or promotions on behalf of STH or selected third parties;
- So that we can promote our products and services to you and the products and services of third parties that we deal with;
- Verifying your identify;
- Investigating any complaints about you or made by you;
- Using personal information as otherwise required or permitted by any law (including the applicable Privacy Act).
STH may state a more specific purpose at the point we collect your personal information.
Disclosure
Except as described in this Privacy Policy, STH will not disclose your personal information outside of STH and its subsidiaries without your consent.
STH may disclose personal information it collects about you to third parties for a variety of purposes in connection with STH providing its services to you (including to our agents and contractors). Personal information may be disclosed to third parties by STH in the following circumstances:
(a) Recruitment
For information about how STH handles personal information where you have provided that information to STH in relation to a position of employment, please contact the Human Resources department using the contact details set out below.
(b) Service Providers personal information collected by STH may be disclosed to third parties to whom STH contracts out specialised functions. If STH does need to disclose personal information to third party contractors under outsourcing or contracting arrangements, STH policy is to take reasonable steps to ensure that those third parties:
(i) comply with Australian and NZ Privacy Principles when they handle your personal information; and
(ii) preserve the confidentiality of the personal information; and
(iii) are authorised only to use personal information in order to provide the services or to perform the functions required by STH.
(c) Clients/Partners of STH Personal information collected by STH from an individual may be disclosed to a specified third party client or partner of STH if the individual has consented to such disclosure.
(d) Disclosures required by law or STH policies
We may access or disclose information about you, including the content of your communications, in order to: (a) comply with the law or respond to lawful requests or legal process; (b) protect the rights or property of STH or our customers, including the enforcement of our agreements or policies governing your use of the products or services; or (c) act on a good faith belief that such access or disclosure is necessary to protect the personal safety of STH employees, customers or the public.
We may also disclose personal information as part of a corporate transaction such as a merger or sale of shares or assets.
Otherwise, STH will only disclose personal information if you consent, or if it is otherwise permitted under the applicable Privacy Act.
As at the date of this Privacy Policy, STH does not disclose personal information to overseas recipients.
Opting in and Unsubscribing
Opting In
At the point STH collects information from you, you may be asked to “opt in” to consent to us using or disclosing your personal information other than in accordance with this Privacy Policy or the applicable Privacy Act. For example, you may be asked to opt-in to receive further information or communications from our advertisers and partners which do not fall into one of the categories described above.
Opting Out / Unsubscribing
You will be given the opportunity to “opt out” from receiving communications from us or from third parties that send communications to you in accordance with this Privacy Policy. For example, you will be given the option to unsubscribe from newsletters, emails and other marketing or promotional material sent by us. You may “opt out” from receiving these communications by clicking on an unsubscribe link at the end of an email.
If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact the STH Privacy Officer (contact details set out below).
Cookies
Should you choose to create a profile on our website we may store a cookie on your computer. The information stored in the cookie allows us to personalize your visit and can help you obtain information you have requested. If you wish you can disable cookies from being stored on your computer by changing your browser settings, however this may result in a limited experience of our functionality and services. STH does not use cookies to record any personal information.
Linked Sites
Our website contains links to other sites for which STH is not responsible for the privacy practices or the content of such web sites or companies. Please read the privacy statements of any linked sites as their Privacy Policy maybe different to ours.
Access and Correction
Access
Under the Australian Privacy Act and NZ Privacy Act, you have the right to request access to the personal information which STH holds about you. There are some limitations to this right set out in the applicable Privacy Act, which mean that we can refuse to provide you access to that information in limited circumstances, including where granting you access might have an unreasonable impact on the privacy of other individuals, if the request is frivolous or vexatious; or if the information relates to anticipated legal proceedings.
If you wish to exercise your right under the applicable Privacy Act to seek access to the personal information that STH holds about you, we ask that you contact STH using the contact details for the Privacy Officer set out below. We will assume (unless you tell us otherwise) that your request relates to our current records about you. These current records may include personal information about you which is included in our databases and in paper files (and which we may use on a day to day basis), or in tapes of programs which we have broadcast.
Generally, STH will endeavour to acknowledge your request for access within 7 days, and to provide you with access within 30 days of the date of receipt of your request. We will notify you if we consider it will take longer than 30 days to provide you with access.
For legal and administrative reasons, STH may also store records containing personal information in its archives. Please be aware that if the relevant personal information was collected in Australia before 21 December 2001, STH will only provide you with access in accordance with section 16C of the Privacy Act 1988. Section 16C states that access must only be provided to personal information collected before 21 December 2001 if we use and disclose that information after that date, and that providing access would not cause an unreasonable administrative burden or unreasonable expense.
Therefore, if you seek access to records held by STH which are not current records, our Privacy Officer will need to contact you to discuss your request. If your access request to archived records is granted, please be aware that it may take a longer period of time to locate these records and that we may charge you for the cost of providing access.
Correction
STH endeavours to ensure that personal information it holds is accurate, complete and up-to-date.
You have the right to ask us to correct information about you which is inaccurate, incomplete, out of date, not relevant or misleading. STH is required to take such steps (if any) as are reasonable in the circumstances to correct the information. You are able to seek correction of your personal information that we hold about you, by notifying our Privacy Officer. STH policy is to respond to your request for correction within 30 days of receipt.
How to contact us
STH may, from time to time, review and update this Privacy Policy to take account of new laws and technology and changes to STH operations. The STH Privacy Policy is available on request from the STH website at http://www.southerntravelholdings.com.
If you have any questions about this Privacy Policy or if you wish to make a complaint about how STH has handled personal information about you or would like to make an access request, please contact STH by writing to the Privacy Officer, by letter: Southern Travel Holdings, PO Box Q1348, QVB Post Office, Sydney, NSW 1230; or by email: privacy@southerntravelholdings.com.
All complaints received will be assessed by the Privacy Officer and all reasonable steps (if any) will be taken to remedy the complaint. STH will endeavour to respond to your complaint within 30 days of receipt of the complaint by STH.
For further information about privacy, visit the Australian Federal Privacy Commissioner's website at: http://www.oaic.gov.au/ or the Parliamentary Counsel site of New Zealand at http://www.legislation.govt.nz/
This Privacy Policy was last updated on 28 August 2014.
*Southern Travel Holdings subsidiary and joint venture companies
The Walshe Group Limited, Walshes World Limited, Experience New Zealand Travel Limited, The Walshe Group Pty Limited, Walshes World Agencies Pty Limited, Hawaii Tourism Australia Pty Limited, Southern Travelnet Pty Limited, Southern Travelnet Limited, Alliance International Marketing Services Limited, The Walshe Group (Singapore) PTE. Limited, The Walshe Group Limited (Hong Kong), Arline International Marketing Services Pty Limited, Hawaii Tourism Oceania Limited, Experience Travel Limited, Pacific Attitude Limited (joint venture).