Privacy Policy

ABERCROMBIE & KENT AUSTRALIA PTY LTD (A&K)

MANAGEMENT OF PERSONAL INFORMATION

At A&K, we recognise the importance of your privacy and understand your concerns about the security of the personal information you provide to us. We are committed to protecting the personal information that you share with us. We comply with the Australian Privacy Principles (APPs) as contained in the Privacy Act 1988 (Cth). The APPs detail how personal information may be collected, used, disclosed, stored and destroyed, and how an individual may gain access to or make complaints about the personal information held about them.

"Personal information" is information or an opinion about an identified individual, or about an individual who is reasonably identifiable.

"Sensitive Information", a sub-set of personal information, is information or an opinion about an individual's racial or ethnic origin, political opinions, political association membership, religious beliefs or affiliations, philosophical beliefs, professional or trade association membership, trade union membership, sexual orientation or practices, criminal record, health information and genetic information.

"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.

This policy details how A&K manages personal information (including sensitive information and health information) about you.

In the course of doing business, we endeavour to collect business information only. However, the collection of personal information in some instances is necessary or unavoidable.

What personal information we collect and hold

The kinds of personal information we collect from you or about you depend on the transaction you have entered into with us, the goods / services you or your organisation have contracted us to provide, and the goods / services you or your organisation are interested in receiving. We collect personal information from you in order to provide you with the best quality travel products and services.

The kinds of personal information that we commonly collect and hold from you or about you include: your name, address, phone, fax and mobile numbers, email address, date of birth, nationality, religion, drivers licence details, passport details, bank account details and credit card details. We also collect information relating to your current and previous health status, medical history, travel preferences and experiences, travel insurance and travel rewards and loyalty programs. We also collect this information from or about your family members, next of kin, emergency contact details and/or other members of your travelling party.

When you browse the A&K website www.abercrombiekent.com.au and have not registered for any online service from A&K, you browse anonymously. Personal Information is not collected as you browse. A&K does, however, use 'cookies,' 'client variables' and 'session variables' to collect information about how the Site and server are used and to recognize you as an A&K online service user when you re-enter our Site. Information, such as the server your computer is logged onto, your browser type, and whether you entered the Site via a Web site or E-mail hyperlink, is collected and tracked in aggregate. This information is used for the purpose of measuring response rates to the web page and email hyperlinks as well as overall Site activity and performance.

When you register for or request any Site service, you may be asked to provide us with Personal Information which is used to enhance your Site experience, expedite communications, allow you to receive electronic / postal mailings from A&K, or to be contacted as requested. Additionally, we may request your upcoming travel plans and the next destination you plan to visit which allows us to further personalise your Site and the email messages you may receive to meet your specific needs, as well as make A&K product improvements. We may also use this Personal Information in aggregate to generate market research reports.

How we collect and hold personal information

We aim to collect personal information only directly from you, unless it is unreasonable or impracticable for us to do so. For example, we collect personal information from you or about you from your letters, emails, and telephone calls with us, or your activity on our website. We also collect personal information from you or about you from application forms and documents that you submit to or through us. We may collect personal information about you as submitted by your family members and/or other members of your travelling party.

However, in many instances we may also receive personal information about you, your family members and/or other members of your travelling party as submitted by third parties, such as your travel agent/s who are making the travel arrangements for you, travel insurers, airlines, hotel partners, tour operators and providers and affiliated travel suppliers.

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.

Why we collect, hold, use and disclose personal information

We collect, hold, use and disclose personal information from you or about you where it is reasonably necessary for us to carry out our business functions and activities. For example, we collect, hold, use and disclose your personal information as necessary to provide our travel products and services to you or your organisation.

Our business necessarily works closely with travel suppliers, airlines, hotel partners, ground tour operators, caterers and travel insurers etc. We routinely disclose your personal information to these third parties for them to assist us in carrying out our business functions and activities.

We also routinely disclose your personal information to other entities within the global A&K group of travel companies.

We may collect sensitive information from you or about you where there is a legal requirement to do so, or where we are otherwise permitted by law. In all other situations, we will specifically seek your consent. For example, we may seek to collect sensitive information about you where it is necessary or desirable for your travel experience.

If we do not collect, hold, use or disclose your personal information (including sensitive information and health information), or if you do not consent, then we may not be able to answer your enquiry, complete the transaction you have entered into, or provide the travel products and services that you or your organisation have contracted us to provide.

We also collect, hold, use and disclose your personal information for related purposes that you would reasonably expect, such as our administrative and accounting functions, identification checks, fraud checks, providing you with information about other travel products and services offered by us, marketing and promotions, market research, customer feedback and quality assurance surveys, newsletter and magazine communications, statistical collation and website traffic analysis.

A&K strives to ensure that we provide the best possible products and services to our customers. From time to time, we may use the personal information that we have collected to identify and communicate other travel products and services that may benefit you or be of interest to you. We may also contact you to inform you about new, existing and improved products, services and special offers. Where we use your personal information for marketing and promotional communications, you can opt out at any time by notifying us. Opt out procedures are also included in our marketing communications.

We value opinions and comments from A&K customers, and you may have the opportunity to give us your feedback through surveys. In conducting these surveys, we may ask for your personal information so that we can appropriately identify you. Survey data and personal information collected may be linked to you or aggregated and used to make improvements to A&K products and services. Participation in these surveys is completely voluntary and you therefore have a choice whether or not to disclose the requested personal information.

Where we wish to use or disclose your personal information for other purposes, we will obtain your consent.

We may also disclose your personal information to third parties (including government departments and enforcement bodies) where required or permitted by law.

How we hold and store personal 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 and loss, and from unauthorised access, modification and disclosure:

  • Data held and stored on paper is stored in lockable filing cabinets, locked offices, and secure premises, with secured entry and monitored alarms.
  • Data held and stored electronically (including in the Cloud) is protected by internal and external firewalls, limited access via file passwords, and files can be designated read-only or no access. We also require our IT contractors and other third parties to implement privacy safeguards.
  • Data stored or archived off-site is contained within secure facilities. We also require our storage contractors to implement privacy safeguards.
  • Where we disclose personal information to third parties (including contractors and affiliated businesses located locally and overseas), our contractual arrangements with them include specific privacy requirements.
  • Our staff receive regular training on privacy procedures.

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 shredded or sent for secure destruction.
  • Electronic records are deleted from all locations, to the best of our ability, or encrypted and/or placed beyond use.

Overseas Disclosure

Our business is necessarily affiliated with a range of businesses and travel suppliers located overseas. In the course of doing business with you, we will routinely disclose some of your personal information (including sensitive information and health information) to these overseas recipients. However, we will only do so where:

  • it is necessary to complete the transaction you have entered into; and
  • you have provided consent; or
  • we believe on reasonable grounds that the overseas recipient is required to deal with your personal information by enforceable laws which are similar to the requirements under the APPs; or
  • it is otherwise permitted by law.

Our overseas affiliates are located in the regions in which we provide travel services, currently being Africa, Antarctica, the Arctic, Australasia and the South Pacific, the Caribbean, Central America, Europe, the Indian sub-continent, North Africa, the Middle East, South America and the Orient.

Requests for Access and Correction

We have procedures in place for dealing with and responding to requests for access to, and correction of, 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 or to correct the information as requested, we will give you written reasons why. For further information, please contact us.

To assist us to keep our records up-to-date, please notify us of any changes to your personal information.

Complaints and Concerns

We have procedures in place for dealing 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 us.

Contact

Privacy Officer

Abercrombie & Kent (Australia) Pty Ltd

Level 3, 290 Coventry Street

South Melbourne, VIC, 3205

T: +61 (0)3 9536 1800

F: +61 (0)3 9536 1805

mailto:[email protected]

April 2014

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