Last Updated: 14 June 2018
ATDW PRIVACY POLICY
The terms “We”, “Us”, “Our”, “ATDW” and “STO” refer to the Australian Tourism Data Warehouse Pty Ltd (ACN 096 876 783), or our State Tourism Organisation (STO) customers namely, Tourism and Events Queensland (ABN 77 745 152 359), Destination NSW (ABN 52 890 768 976), VisitCanberra (ABN 72 397 293 490), Visit Victoria (ABN 18 381 772 530), Tourism Tasmania (ABN 58 800 480 938), South Australia Tourism Commission (ABN 80 485 623 691), Tourism Western Australia (ABN 95 468 665 668), Tourism Northern Territory (ABN 17 435 764 236).
ATDW operates a web-based platform for its customers and STO customers (the “Platform”). The Platform helps Australian tourism businesses provide their content (including information concerning their products and destinations) for publication on websites or mobile applications.
This Privacy Policy is intended to inform you about how we treat your Personal Information. If you do not agree to any part of this Privacy Policy, then we cannot permit you to use the Platform, and you should stop accessing the Platform and deactivate your account.
DEFINITIONS
“ATDW-Online account” means your ATDW-Online account with us.
“Business Contact Information” means information You provide to Us for publication on websites or mobile applications so that customers can make contact with you. Business Contact Information may include your business email address, your business phone number, business location and business website.
"Personal Information" means information relating to you (being a living individual) from which your identity is either clear or can reasonably be determined from that information or from that information in conjunction with other information that is in, or is likely to come into, the possession of ATDW or an STO. Personal Information may include your name, email address, phone number and location.
WHAT TYPES OF INFORMATION DOES ATDW GATHER ABOUT ITS USERS?
1. Information that you give us
We receive, store and process information that you make available to us when accessing or using our Platform. Examples include when you:
1. fill in any form on the Platform, such as when you register or update the details of your ATDW-Online account, or when you supply identification verification information;
2. access or use the Platform, pay for any associated services that may be available (such as but not limited to translations);
3. link your account on a third party site (e.g. Facebook) to your ATDW-Online account, in which case we will obtain the Personal Information that you have provided to the third party site, to the extent allowed by your settings with the third party site and authorized by you; or
4. Communicate with ATDW or an STO.
2. Mobile Data
When you use certain features of the Platform (in particular our mobile applications), we may receive, store and process different types of information about your location, including general information (e.g., IP address, post code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Platform or specific features of the Platform).
If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer's instructions for further details.
3. Log Data
We may also receive, store and process Log Data. Log Data is information that is automatically recorded by our servers whenever you access or use the Platform, and includes data such as your IP Address, the date and time you access or use the Platform, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, pages viewed and the order of those pages, and the amount of time spent on particular pages. Log Data may be collected even if you are not registered with ATDW or logged in to your ATDW-Online account.
4. Cookies and other Tracking Technologies
ATDW uses cookies and other similar technologies, such as mobile application identifiers, on the Platform. As a result, when you access or use the Platform, you will provide or make available certain information to Us.
5. Third-party social plugins
Our Platform may use social plugins which are provided and operated by third-party companies.
As a result of this, you may send to the third-party company the information that you are viewing on a certain part of our Platform. If you are not logged into your account with the third-party company, then the third party may not know your identity. If you are logged into your account with the third-party company, then the third party may be able to link information about your visit to our Platform to your account with them. Similarly, your interactions with the social plugin may be recorded by the third party.
Please refer to the third party's privacy policy to find out more about its data practices, such as what data is collected about you and how the third party uses such data.
HOW WE USE AND PROCESS THE INFORMATION THAT YOU PROVIDE OR MAKE AVAILABLE
We use, store and process Information about you for the following general purposes:
1. to enable you to access and use the Platform;
2. to operate, protect, improve and optimize the Platform, ATDW’s business, and our users' experience, such as to perform analytics, conduct research, personalize or otherwise customize your experience, and for advertising and marketing;
3. to help create and maintain a trusted and safer environment on the Platform, such as fraud detection and prevention, conducting investigations and risk assessments, verifying the address of your listings, verifying any identifications provided by you, and conducting checks against databases such as public government databases;
4. to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
5. to administer surveys, contests, or other promotional activities or events sponsored or managed by ATDW or STOs; and
6. to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties.
QUALITY OF PERSONAL INFORMATION
We will take all reasonable steps to ensure that Personal Information we hold is accurate, complete, relevant, up-to-date and not misleading on a regular and ongoing basis.
WHEN ATDW or an STO DISCLOSES OR SHARES PERSONAL INFORMATION, AND TO WHOM
We may disclose your Personal Information to State or Commonwealth government agencies, for example, Government Research providers, for the purposes identified above.
Your Business Contact Information is not covered by this Privacy Policy as there are separate legal arrangements in place between you and us in relation to the use and management of your Business Contact Information. Accordingly, for the purposes of this Privacy Policy we consider your Business Contact Information as distinct and separate from your Personal Information.
DOES ATDW DISCLOSE PERSONAL INFORMATION TO OVERSEAS RECIPIENTS?
ATDW does not disclose Personal Information to any overseas recipients.
BUSINESS TRANSFERS BY ATDW
If ATDW undertakes or is involved in any merger, acquisition, reorganization or sale of assets, then we may sell, transfer, disclose or share some or all of our assets, including our database of Personal Information. In this event, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy.
HOW TO ACCESS, CHANGE OR DELETE YOUR PERSONAL INFORMATION, OR CANCEL YOUR ATDW-ONLINE ACCOUNT
The Australian Privacy Principles under the Australian Privacy Act 1988 (Cth) allows you to access and correct your Personal Information that we hold in certain circumstances. You may access, review, update, correct or delete the Personal Information in your ATDW-Online account. If you would like to correct your information or cancel your ATDW-Online account entirely, you can do so by logging in to your account.
SECURING YOUR PERSONAL INFORMATION
We are continuously implementing and updating administrative, technical, and physical security measures to help protect your Personal Information against unauthorised access, destruction or alteration, this includes investing substantially in server, database and firewall technologies.
YOUR PRIVACY WHEN YOU ACCESS THIRD-PARTY WEBSITES AND RESOURCES
The Platform will contain links to other websites not owned or controlled by ATDW. ATDW does not have any control over third party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.
Some portions of the Platform implement Google Maps/Earth mapping services, including Google Maps API(s). Your use of Google Maps/Earth is subject to Google's terms of use (located at http://www.google.com/intl/en_us/help/terms_maps.html) and Google's privacy policy (located at http://www.google.com/privacy.html), as may be amended by Google from time to time.
CHANGES TO THIS PRIVACY POLICY
We may change how we collect and then use Personal Information at any time and without prior notice, at our sole discretion. We may change this Privacy Policy at any time. If we make material changes to the Privacy Policy, we will notify you either by posting the changed Privacy Policy on the Platform or by sending an email to you.
We will also update the "Last Updated Date" at the top of this Privacy Policy. If we let you know of changes through an email communication, then the date on which we send the email will be deemed to be the date of your receipt of that email.
It's important that you review the changed Privacy Policy. If you do not wish to agree to the changed Privacy Policy, then we will not be able to continue to permit you to use the Platform, and your only option will be to stop accessing the Platform and deactivate your ATDW-Online account.
GOT FEEDBACK? CONTACTING US
Your privacy is very important to us. If you'd like to contact us (including providing feedback about this Privacy Policy), please email us at [email protected].
COMPLAINTS
If you wish to make a complaint about how we handle your Personal Information, please contact our Privacy Officer at [email protected]
Please provide as much detail about the facts surrounding your complaint so we can resolve it accordingly and please allow us at least 7 days to respond to your complaint.
If we fail to resolve your complaint, you may refer the matter to the Australian Information Commissioner (see www.oaic.gov.au).
RIGHTS UNDER EU LAW
This section will only apply if you have rights under EU data protection laws. You can exercise these rights by contacting ATDW’s Privacy Officer at [email protected].
Please note that these rights are:
a. only available to you under certain conditions, and
b. subject to certain exceptions and exemptions to safeguard the public interest (e.g. the detection of crime) and our interests.
1. ‘Right to be forgotten’: You may have the right to ask us to delete or remove your personal information.
2. Withdraw your consent: Where you have given us your consent to process or use your personal information, you may have the right to change your mind and withdraw that consent.
3. Access to your personal information: You may have the right to request access your personal information. Subject to any applicable exceptions, we will provide you with a copy of your personal information within the timeframes prescribed by law.
4. Details on use and processing: You may have a right to request that we provide you with further details on how we use and process your personal information.
5. Restrictions during an inquiry: You may have the right to restrict how we process your personal information while we consider an inquiry you have raised.
6. Complaints and objections: You may have the right to:
a. lodge a complaint with a supervisory authority;
b. object to any processing of personal information on “legitimate interests” rounds or “public interests” grounds, unless our reasons for the processing outweighs your interests, rights and freedoms; and
c. object to direct marketing (including any profiling for such purposes).
