1. Privacy Statement
Personal information is defined in the Privacy Act 1988 (Cth) and means information or an opinion about an identified individual, or an individual who is reasonably identifiable.
2. Collection of personal information
2.1. Types of information we collect
The personal information we collect will depend on your relationship with us and the service you may request from us. HRS only collects personal information for the purposes of conducting our business as an accommodation aggregator and provider of accommodation booking and payment technology solutions. The personal information we collect may include:
- Your name, address and contact details (telephone and email);
- Payment information for accommodation bookings or services requested through our websites or directly from us;
- Itinerary and other travel related information (including any dietary and special assistance requirements);
- IP address or MAC address when using our website or mobile applications;
- Loyalty membership information; and
- Information relating to your dealings with us.
2.2. Collecting health and other sensitive information
We may collect health or other sensitive information about you if relevant to your accommodation arrangements, for example, where you make a special request, provide your dietary requirements or otherwise provide us with health information.
Depending on the circumstances in which we are collecting health information from you, we collect health information so that we can establish your requirements and make any special assistance or other accommodation arrangements for you.
Where possible, we will allow you to interact with us anonymously or using a pseudonym. For example, if you contact us with a general enquiry, we will not ask for your name unless we need it to adequately handle your enquiry.
However, for most of our functions and activities we usually need your name and contact information.
2.4. How we collect your personal information
We collect your personal information in a number of ways. We may collect your personal information directly from you or in the course of our dealings with you, including when you:
- Provide personal information to us, for example, when you make or update a booking, register your accommodation details for distribution through us, subscribe to our email or other communications, enter a competition, provide feedback to us or otherwise interact with us;
- Visit our website, social media channels or mobile applications;
- Apply for a position with us; and
- Contact our Accommodation Services or Hotel Partnerships teams. We record all calls in and out of our Accommodation Services and so we will collect any personal information you provide during the call.
We may also collect personal information about you from someone other than you. This may include our related entities and:
- A person who makes, changes or enquires about a booking on your behalf or who otherwise interacts with us on your behalf (such as your employer or other representative as part of a corporate or group booking or travel/booking agents);
- Our travel service provider partners, including travel management companies, online booking tool technology providers and card payment facilitators who are authorised to facilitate accommodation bookings and payment on your behalf; and
- Recruitment agencies and previous employers, if you have applied for a position with us and with your consent.
We may combine personal information we receive about you (whether from you, our partners, related entities or third parties) with other information that we hold about you.
2.5. Why we collect personal information
We collect your personal information so that we can provide you with our services, contact you and carry out our functions and activities.
The purposes for which we collect your personal information may include:
- Processing and making arrangements for your accommodation booking and any additional products or services you request during the booking process;
- Verifying your identity;
- Communicating with you before and after your accommodation booking, including to request feedback;
- Determining issues of traveller safety and security, including special assistance requirements;
- Providing and operating our competitions, promotions and events;
- Contacting you with marketing and promotional material about our offers or promotions, and those of our related entities, partners and other third parties, and to identify products and services that may be of interest to you;
- Responding to feedback, queries and complaints;
- Helping us to continuously improve the services and products we offer; and
- Maintaining records and complying with our legal obligations.
3. Use and disclosure of your personal information
We will use and disclose your personal information for the purpose for which it was collected. We will also use or disclose your personal information for a secondary (but related) purpose, where you would reasonably expect us to or we have your consent.
We may also disclose your personal information:
- To accommodation providers with whom you have made a booking;
- To accommodation aggregators/content providers through whom your booking is confirmed;
- To travel service provider partners, including travel management companies, online booking tool technology providers and card payment facilitators who are authorised to facilitate bookings and payment for bookings on your behalf;
- To insurance entities authorised to receive your details for the purpose of traveller tracking, safety and security;
- To the cardholder of the credit card used to pay for your booking;
- To our third party product and service providers, including those marketing and advertising services, data analysis and business intelligence services, payment fulfilment and fraud protection services and security services;
- In the event of an emergency or other serious incident, to government departments and agencies and other support organisations and persons involved in the incident response, and to your family member(s) who contact us seeking information about your travel arrangements;
- To our professional advisers and insurers;
- Where permitted or required by law or order of a court/tribunal; and
- To comply with our legal, audit, reporting and investigations requirements and for operational or regulatory compliance purposes.
4. Business or group travel
If your booking contains more than one guest (whether you and your family or a friend, or a group booking for 10 or more) or you are travelling under a business account, then we will collect your personal information from you or the person who made or updated the booking on your behalf. We may also disclose your personal information to the person who made or updated your booking and other persons included in the booking.
If your booking is made through your employer’s business travel arrangement, we may collect your personal information from and disclose your personal information to your employer (or representative), including your itinerary, information relating to your booking including check-in, “no-show” or cancellation status and any incident reports.
5. Cross-border disclosures
We may disclose your personal information to organisations or persons located outside of Australia. The countries in which these organisations or persons are located will depend on the circumstances, but in the course of our ordinary operations, we generally disclose personal information to third parties located in the countries where:
- You are travelling to or from; and
- Our third party service providers are located, that is Germany, Fiji and India.
6. Job Applicants
When you apply for a job with us, we will generally collect the personal information that you include in your application, such as your contact details, career history and education details. We may also collect sensitive information from you, for example, medical information or criminal history, if it is relevant to the role that you are applying for, and whether you identify as Aboriginal or Torres Strait Islander, for our Indigenous Participation Plan.
We may also obtain personal information about you from third parties with your consent, for example, from your previous employers or nominated referees. We collect personal information for the purpose of assessing and progressing your application. We will hold your personal information for future job opportunities with us, unless you tell us not to.
We may disclose your personal information to our related entities, your referees and also to third party suppliers that we use to help with our recruitment processes, such as recruitment agencies and organisations that conduct competency or psychometric tests. We may also disclose your personal information to law enforcement agencies to verify whether you have a criminal record.
7. Cookies and web-tracking tools
Cookies are tiny files sent to your browser and stored by your browser on your computer or other device that you’re using to access our website or use our mobile applications.
Our cookies may collect your IP address or MAC address, the city associated with your IP or MAC address, the date and time of your visit to our website, pages viewed, the URL of the website that you viewed before our website and the type of browser you use.
We also use Google Analytics which is a web-tracking tool that generates detailed statistics about traffic to our websites and traffic sources. This tool can also measure and record conversions and sales. It only provides us with aggregated data (not personal information of our website visitors).
The cookies and web-tracking tools allow our websites and mobile applications to interact more efficiently with the device you are using and to help us improve the content and functioning of our websites and mobile applications.
We use personal information that we hold about you to identify services and products that may be of interest to you.
We may, or we may use a third party service provider, to contact you by email, text message or other digital service, phone or post to let you know about our promotions, and those of our partners, or third party travel service providers that may be of interest to you.
You can contact us at any time if you no longer wish to receive marketing materials from us, our related entities or our partners. If you receive a marketing email from us, you can opt-out from that particular category of marketing email by clicking on the link to remove yourself at the bottom of the email.
9. Storage and Security of your personal information
We mostly hold personal information electronically in our IT systems and databases. We also hold personal information in telephone recordings and in hard copy paper files. We use third party service providers to store some personal information.
We take reasonable steps to protect the information that we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure.
We do this by having physical and electronic security systems and by limiting who can access your personal information. We conduct privacy and security awareness training with all employees on commencement and annually. We also have online and network security systems in place for our websites, so that the information you provide us online is protected and secure. However, because of the nature of the internet, we cannot guarantee the security of your personal information.
Please contact us if you become aware of any breach of security.
10. Access to and correction of your personal information
We will take all reasonable steps to ensure that the personal information we hold is accurate, complete, relevant, up-to-date and not misleading. You have a right to request access to or correction of your personal information held by us.
If you wish to access, correct or update any personal information that we hold about you, please contact us on the details below. We will need to verify your identity before we can process your request.
We will respond to your request within a reasonable time of you making the request and give you access in the manner you requested, unless it is unreasonable or impracticable for us to do so.
Sometimes we will be able to respond to your query over the phone, but sometimes we may need your request in writing and we might need some time to gather the requested information and get back to you. These more complex requests usually take us between 14 and 30 days.
If we refuse to correct your personal information that we hold, you can ask us to associate with that information a statement that the information is inaccurate, out-of-date, irrelevant or misleading.
11. Lodging a complaint
If you have a complaint about how we have handled your personal information, you can make a complaint by contacting us on the details below:
Once we have received your complaint, we will investigate and respond to you within a reasonable period of time.
We take any privacy complaint seriously and will deal with your complaint fairly and promptly. However, if you are not satisfied with our response or how we handled your complaint, you may complain to the Office of the Australian Information Commissioner (in writing) to:
- Post: Office of the Australian Information Commissioner (OAIC), GPO Box 5218, Sydney NSW 2001
- Email: email@example.com
We will post all updates to our privacy page.
13. Contacting us
You may contact us via:
- Email: firstname.lastname@example.org
- Post: Privacy Officer, HRS, Level 7, 50 Carrington Street, Sydney, NSW 2000
- Phone: (02) 8585 0888
We will respond in writing (if you provide a contact address) within a reasonable period of time.