Privacy Policy

Entire Travel Group Pty Ltd

ABN 60 625 410 755

Our commitment

Travel requires personal information to move between travellers, travel advisers and suppliers. We are committed to handling that information transparently, securely and only for legitimate purposes connected with our services, legal obligations and business operations.

This policy explains what we collect, why we collect it, how it may be used or disclosed, how we protect it, and how you may request access, correction or make a complaint.

1. About this Privacy Policy

Entire Travel Group Pty Ltd (Entire Travel Group, we, us or our) is an Australian travel business that markets, arranges and coordinates travel products and services. We work with customers who contact us directly and with travel advisers who provide information to us on behalf of their clients and other travellers.

We are bound by the Privacy Act 1988 (Cth), including the Australian Privacy Principles (APPs). This policy describes how we manage personal information in an open and transparent way. It applies to our websites, enquiries, quotations, bookings, customer service, marketing activities and other business dealings.

This policy does not replace any collection notice, booking condition, promotion term or other specific notice that we provide for a particular transaction or activity. Those documents should be read together with this policy.

2. What personal information means

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or not and whether it is recorded in a material form or not.

Sensitive information is a category of personal information that includes health information and information about matters such as racial or ethnic origin, religious beliefs, sexual orientation, criminal record and membership of professional or trade associations. We only collect sensitive information where it is reasonably necessary for our functions or activities and where permitted by law, usually with consent.

3. Personal information we may collect

The information we collect depends on your dealings with us and the travel services requested. It may include:

• identity and contact details, including name, title, address, email address and telephone number;
• date of birth, age, gender or title where relevant to a booking or supplier requirement;
• passport, visa, nationality, citizenship and other travel-document information;
• booking, itinerary and travel history information, including destinations, dates, companions, transport, accommodation and activity preferences;
• frequent-flyer, loyalty-program and membership details;
• emergency-contact and next-of-kin information;
• dietary, mobility, accessibility, health, medical or other special-assistance information needed to assess or arrange travel services;
• payment and transaction information. Payment-card processing may be performed by a payment provider and we do not intentionally retain full card details unless required and permitted for the transaction;
• communications, enquiries, complaints, feedback and customer-service records;
• information about travel advisers, suppliers, contractors and business contacts;
• marketing preferences, competition entries and subscription information; and
• website and technical information, including IP address, device and browser information, pages visited, referral source and cookie or similar technology data.

4. How we collect personal information

We may collect personal information:

• directly from you, including through our websites, enquiry and subscription forms, telephone calls, emails, messages, promotions and other correspondence;
• from a travel adviser, family member, travelling companion, employer, group organiser or other person acting for you or arranging travel involving you;
• from airlines, hotels, cruise lines, rail operators, tour operators, destination management companies, insurers, payment providers and other travel or service suppliers;
• from our related businesses, contractors, technology providers and marketing service providers;
• from publicly available sources where collection is lawful and reasonably necessary; and
• automatically when you use our websites or digital services, through cookies, logs and similar technologies.

If you provide personal information about another person, you should be authorised to do so and should ensure the person understands that their information may be provided to and handled by us in accordance with this policy.

Where reasonable and practicable, we will collect personal information directly from the individual. If we receive personal information from another source, we will take reasonable steps to provide any required notification or otherwise ensure the individual is aware of the relevant circumstances.

5. Why we collect, use and disclose personal information

We collect, hold, use and disclose personal information for purposes including:

• responding to enquiries and preparing quotations or proposed itineraries;
• creating, confirming, administering and servicing travel bookings;
• communicating with customers, travellers, travel advisers and suppliers before, during and after travel;
• providing support, managing changes, disruptions, refunds, complaints, claims and emergencies;
• processing payments, reconciling accounts, preventing fraud and maintaining business records;
• arranging special requests, accessibility support, dietary requirements or other traveller needs;
• complying with immigration, border, security, public-health, taxation, financial, sanctions, law-enforcement and other legal or regulatory requirements;
• managing suppliers, advisers, contractors and other commercial relationships;
• operating, maintaining, securing and improving our websites, systems, products and services;
• conducting analytics, quality assurance, training, auditing, risk management and business planning;
• administering subscriptions, promotions, competitions and events; and
• sending direct marketing where permitted, subject to your right to opt out.

If we are unable to collect information that is reasonably necessary, we may not be able to provide an accurate quotation, make or service a booking, accommodate a request, meet a supplier requirement or respond effectively to an enquiry or complaint.

6. Sensitive information and traveller requirements

Travel arrangements may require sensitive information, particularly health, disability, mobility, dietary or religious information. We will collect and use this information only where reasonably necessary and permitted by law, generally with the consent of the individual concerned.

We may disclose relevant sensitive information to travel advisers, airlines, accommodation providers, cruise lines, tour operators, insurers, assistance providers or other suppliers where needed to assess or provide the requested service. Travellers should consider whether a supplier needs the information and provide no more than is reasonably necessary.

7. Who we may disclose information to

We may disclose personal information to recipients including:

• airlines, accommodation providers, cruise lines, rail operators, vehicle providers, tour operators, destination management companies, attractions, guides and other travel suppliers;
• computer reservation systems, ticketing systems and travel technology platforms;
• travel advisers, group organisers, travelling companions and persons authorised by the traveller;
• payment processors, banks, fraud-prevention providers, accountants, auditors and professional advisers;
• IT, cloud hosting, communications, document, analytics, customer relationship, marketing and website service providers;
• insurers, assistance companies, claims managers, investigators and emergency-service providers;
• government, regulatory, border, immigration, customs, health, security and law-enforcement bodies where required or authorised; and
• other parties with consent or where permitted or required by law.

We do not sell personal information as a standalone commercial product.

8. Overseas disclosures

International travel necessarily involves information being sent to recipients outside Australia. Depending on the itinerary and service requested, overseas recipients may be located in any country in which a traveller transits, visits, receives services or requires support. They may also be located in countries where our suppliers or technology service providers operate or host data.

Overseas recipients may include airlines, hotels, cruise lines, rail operators, tour operators, destination management companies, ground handlers, attractions, insurers, assistance providers, government authorities and technology providers.

Before disclosing personal information to an overseas recipient, we take reasonable steps where required by APP 8 to ensure the recipient does not breach the APPs in relation to the information. In some circumstances an exception under the Privacy Act may apply. Privacy protections and remedies available overseas may differ from those in Australia.

Because our destination and supplier network changes and an itinerary may involve many countries, it is not practicable to list every possible country in this policy. You may contact us before booking if you require more information about likely overseas disclosures for a proposed itinerary.

9. Direct marketing

We may use contact details to send information about travel products, destinations, offers, events, competitions or services where permitted by law. Marketing communications may be tailored using information about stated interests, prior dealings or interactions with our websites and communications.

You may opt out at any time by using the unsubscribe facility in an electronic communication or contacting us. We will action opt-out requests within the period required by law. Even if you opt out of marketing, we may still send operational communications relating to an enquiry, booking, payment, legal obligation, service message or account.

10. Cookies, analytics and online services

Our websites use cookies and similar technologies to operate site functions, remember preferences, understand website use, improve content and performance, and support marketing where consent or other lawful authority is required.

Where our website provides cookie choices, declining non-essential cookies will prevent or limit the associated tracking. A necessary preference cookie may still be used to remember your choice. You may also control cookies through your browser, although disabling some cookies may affect website functionality.

Our websites may contain links to external websites or embedded services. Those operators have their own privacy practices and we are not responsible for how they handle personal information outside services controlled by us.

11. Security and data breaches

We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, modification or disclosure. Measures may include access controls, authentication, staff obligations, supplier controls, system monitoring, secure hosting, backup and recovery arrangements, and secure disposal or de-identification practices.

No method of transmission or storage is completely secure. If we become aware of a data breach, we will investigate and respond in accordance with applicable law, including the Notifiable Data Breaches scheme where it applies.

12. Retention and disposal

We retain personal information for as long as reasonably necessary for the purpose for which it was collected, to service travel arrangements, maintain business and accounting records, manage disputes or claims, and comply with legal, regulatory, taxation, insurance and contractual requirements.

Retention periods vary according to the type of information and transaction. When personal information is no longer required and we are not legally required to retain it, we take reasonable steps to destroy it securely or de-identify it. Some information may remain in secure backups until those backups are overwritten or otherwise disposed of through normal processes.

13. Access to and correction of personal information

You may request access to personal information we hold about you and request correction if you believe it is inaccurate, out of date, incomplete, irrelevant or misleading.

To protect privacy, we may ask you to verify your identity and clarify the information requested. We will respond within a reasonable period. We may refuse access or correction where permitted by law, but if we do so we will generally provide written reasons and information about available complaint mechanisms.

We do not charge for making an access or correction request. Where permitted, we may charge a reasonable amount for giving access and will discuss that amount before proceeding.

14. Anonymity and pseudonyms

Where it is lawful and practicable, you may deal with us anonymously or using a pseudonym. This is generally not practicable where we must identify a traveller to prepare an accurate quotation, make or service a booking, process a payment, issue travel documents, satisfy supplier requirements or comply with law.

15. Complaints

If you have a concern or complaint about how we have handled personal information, please contact our Privacy Officer using the details below. Please provide enough information for us to understand and investigate the issue.

1. We will acknowledge the complaint and assess what information is required.
2. We will investigate the matter and aim to provide a substantive response within a reasonable period, normally within 30 days.
3. If additional time is reasonably required, we will explain the reason and provide an updated response timeframe.

If you are not satisfied with our response, you may contact the Office of the Australian Information Commissioner. Information about making a privacy complaint is available at https://www.oaic.gov.au/www.oaic.gov.au.

16. Automated decision-making

If we arrange for a computer program to use personal information to make, or do something substantially and directly related to making, a decision that could reasonably be expected to significantly affect an individual’s rights or interests, we will include the information required by the Privacy Act in this policy. This may include the kinds of decisions involved, the personal information used and how the program is used in the decision-making process.

Routine website search, sorting, workflow automation, fraud alerts, analytics or marketing segmentation do not necessarily constitute a significant automated decision. Where human review is appropriate, we may use automated tools to support rather than replace that review.

17. Changes to this policy

We may update this policy from time to time to reflect changes to our practices, services, technology or legal obligations. The current version will be published on our website and will show its effective date. Material changes may also be communicated through other appropriate channels.

18. Contact us