1.1. The protection of your privacy is important to us. We have prepared this document to ensure you are aware of your rights and our commitment to your privacy. Under the Privacy Act 1988 (Cth) (Privacy Act) there are Australian Privacy Principles (APPs). The APPs regulate the way in which we deal with your personal information.
1.2. This Policy is current as at 17 April 2014.
1.3. We reserve the right to amend this Policy at any time, without notice to you, to ensure that we maintain the highest standards. The date of this Policy will inform you as to whether there have been updates since your last visit.
2. Collection of personal information
2.1. The kinds of personal information we collect and hold about you may include:
2.1.1. your name and address;
2.1.2. your telephone numbers;
2.1.3. your email address;
2.1.4. your computer IP address from our website;
2.1.5. details of your previous dealings with us or any of our properties; and
2.1.6. your financial information (eg, for invoicing and payments of services, products and membership or personal credit information when you make payment to us);
2.1.7. tour license, passport or other identification details;
2.1.8. tour car registration number;
2.1.9. details pertaining to your caravan/trailer such as make, model and dimensions.
2.2. We may collect your personal information in the following ways:
2.2.1. in any discussion we have with you whether in person or by telephone;
2.2.2. through guest registration forms completed at any of our properties;
2.2.3. through our club membership application forms;
2.2.4. through our accounts and payments we make;
2.2.5. through our website or email server by way of 'cookies'. Cookies are small pieces of data that allow the website to remember something about you at a later time for example by storing information of how you use the site. You may configure the web browser to refuse or disable cookies;
2.2.6. through third parties, including companies running competitions on our behalf;
2.2.7. through customer feedback and survey forms; and
2.2.8. through the quality control checklist.
2.3. If we collect personal information about you, or about another individual from you, we will take all reasonable steps to ensure that the individual will be/has been made aware of this Policy and:
2.3.1. our identity and how to contact us;
2.3.2. that he or she can access the information;
2.3.3. the purpose for which we have collected the information;
2.3.4. the organisations or types of organisations that we usually disclose the information to;
2.3.5. any law that requires particular information to be collected;
2.3.6. the main consequences (if any) for the individual if all or part of the information is not provided;
2.3.7. whether we are likely to disclose personal information to overseas recipients, and if practicable, the relevant countries in which they are located; and
2.3.8. any other information required to be notified under the APPs.
Some of this information is included in this Policy.
3. Purposes for collecting, holding, using and disclosing personal information
3.1. You consent to us collecting, holding, using and disclosing your personal information for the following purposes:
3.1.1. to provide our products and services to you;
3.1.2. to communicate with you;
3.1.3. to provide you with information and updates, including, but not limited to, marketing material and special offers, either from us, any of our related entities or a third party business which we consider may be of interest to you;
3.1.4. personalising your experience with our products and services, for example, via connectivity with social media services;
3.1.5. to verify your membership status and for production of membership cards and renewal notices;
3.1.6. to arrange for accommodation or collection of prizes;
3.1.7. to compose diagnostic and statistical information for our computer network;
3.1.8. for accounting purposes such as calculation of franchise fees and royalties, billing of services, products and membership; and
3.1.9. to evaluate and improve the effectiveness of our website.
3.2. We may also collect, hold, use and disclosure your personal information for any other purpose you may reasonably expect, or for any other purposes disclosed to or authorised by you.
3.3. If you do not wish to receive marketing materials from us, you may "opt out" of our list and your name will be removed from our marketing list.
4. Disclosure of personal information
4.1. We may disclose personal information to:
4.1.1. contracted assessors for assessment of the quality control standards of our properties;
4.1.2. our property managers (to verify membership details, and to provide you with services);
4.1.3. a third party contractor who may be performing services for us which involves your personal information such as sponsors of our conferences, advertising agencies, suppliers and our public relations agency; and
4.1.4. any other party to which the law obliges us to.
4.2. Any disclosure that is required to be made to any third party will be made primarily for the purpose of providing or offering goods and services to you. If we disclose information to a third party, we generally require that the third party protect your information to the same extent that we do.
4.3. We will not sell your personal information to marketing bodies without your consent.
5. Access to and correction of your personal information
5.1. We believe it is important to make sure that the personal information we hold about you is accurate and up to date. To this end, our staff have procedures to monitor some of your personal information.
5.2. We also request that you contact us and tell us if any of your personal information has changed (eg. your address) or if you believe that the personal information is inaccurate. After you advise us we can then update our records and ensure that the personal information we hold is accurate and up to date.
5.3. You may contact us and request access to the personal information we hold about you, and advise us if that personal information needs to be amended or corrected in any way. You may contact our Privacy Officer at the contact details set out below.
5.4. Where practicable, we will allow you to deal with us anonymously or under a pseudonym. This option will not be available where we are required or authorised by law to deal with individuals who have properly identified themselves, or if we need to verify your identity in order to provide products or services to you. Further, if you choose not to give us personal information that we request from you, we may not be able to provide you with any goods or services you have asked us to supply.
6. The security of personal information
6.1. We are committed to maintaining the highest level of security of our client(s) files and personal information.
6.2. We hold your personal information as either physical records, records on our servers, and in some cases, records on third party servers, which may be located overseas.
6.3. We use the following security measures to protect personal information:
6.3.1. locked offices;
6.3.2. locked files;
6.3.3. passwords on all our computers;
6.3.4. a firewall on our computer network, which is monitored; and
6.3.5. virus protection software.
6.4. We will keep personal information as long as we need it for the purposes in clause 3 of this Policy, after which time we will destroy it or de-identify the personal information. Otherwise we may keep personal information for any period required by law.
7. Cross border disclosures of personal information
7.1. As at the date of this Policy, we are not likely to disclose personal information to overseas recipients. If in future we do propose to disclose personal information overseas, we will do so in compliance with the requirements of the Privacy Act.
7.2. From time to time we may engage an overseas recipient to provide services to us, such as cloud-based storage solutions. Please note that the use of overseas service providers to store personal information will not always involve a disclosure of personal information to that overseas provider. However, by providing us with your personal information, you consent to the storage of such information on overseas servers and acknowledge that APP 8.1 will not apply to such disclosure. For the avoidance of doubt, in the event that an overseas recipient breaches the APPs, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.
8. Do you have any concerns, queries, disputes or complaints?
Head Office, Level 2, 157 Grenfell Street
Adelaide SA 5000
Telephone: +618 8219 3000
8.2. We request that any dispute or complaint be submitted into writing to our Privacy Officer. Your dispute or complaint will be investigated and we will respond to you within a reasonable timeframe.
8.3. If you are dissatisfied with the handling of your complaint, you may contact the Office of the Australian Information Commissioner, see http://www.oaic.gov.au/privacy/making-a-privacy-complaint for further information.