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Thailand Holiday Group
At Thailand Holiday Group (THG), we understand that you care how your personal information is handled and we appreciate your trust that we will do so carefully and sensibly and in compliance with the Australian Privacy Principles of the Privacy Act 1988.
PURPOSE OF THE POLICY
This policy statement outlines how THG collects personal or sensitive information in its dealings with clients and other members of the public, including users of our website, and how we
manage that information.
INFORMATION WE COLLECT
We will regularly collect personal information including your name, address, phone number, fax number and email address, as well as the details of your assets and financial affairs that you provide us in connection with our provision of services to you.
Other information that may be collected from time to time if reasonably necessary includes your health condition and medical history, passport number, concession card number, driver’s license number and tax file number.
The personal information collected will be mainly held by us on electronic storage media, although paper records may also exist. Paper records will be held in secure premises, and electronic records will be accessible only by authorised personnel holding a valid password.
REASON FOR COLLECTION
This information will routinely be collected in order to assist us in providing products or services or fulfilling enquiries or requests.
The information collected is to identify the individual, to assess the suitability of and to compose the products and services that THG is to provide.
In connection with these purposes THG may disclose personal information to trade insurers, other suppliers, cheque guarantee providers, other organisations involved in THG’s business practices, an individual’s representative and as required by law.
If you provide us with personal information specifically for a particular purpose (a primary purpose) then you must expect that THG may also use and disclose that information for any of the aforementioned other purposes (a secondary purpose). In addition to the aforementioned purposes, a permitted secondary purpose will be any other purpose that is related to the primary purpose which an ordinary person would reasonably expect such information to be used for.
We may also from time to time use that information for purposes of conducting direct marketing to promote our products and services, surveying interest in other products and services, sending invitations to educational or social functions or for purposes of disseminating information which we think may be of interest to our clients and contacts.
If you are an applicant for employment, in addition to the above category of information, we may need to collect other personal information relevant to your application. Should your application be unsuccessful we may retain your information so that we may contact you should another employment opportunity arise.
If you do not consent to THG using and disclosing personal information in this manner then please contact us in the manner described below. However, in the absence of your consent, THG will not be able to provide you with the full range of products and services.
USE AND DISCLOSURE OF PERSONAL INFORMATION
Your personal information will only be used for these purposes and will NOT be shared, sold or given to any third parties, unless required or authorised under the exemptions set out in the Privacy Act.
CONSEQUENCES OF NON-DISCLOSURE OF PERSONAL INFORMATION
If you choose not to provide THG with the personal information as requested we may not be able to provide you with the full range of our products and services.
QUALITY OF PERSONAL INFORMATION
THG’s aim is to ensure that your personal information is relevant, accurate, complete and up-to-date. To assist us with this, please contact us if any of the personal information you have provided changes and we will use all reasonable efforts to update the data.
PERSONAL INFORMATION SECURITY
THG is committed to keeping secure the data you provide us and we will take all reasonable precautions to protect your personal information from interference, loss, misuse, modification or disclosure.
We generally do not contract out data storage or processing functions. If THG does contract out storage or processing of data containing personal information, we will take reasonable steps to ensure the recipient of the information acknowledges the private nature of any personal information disclosed, and that the recipient undertakes to abide by the privacy obligations under the Australian Privacy Principles in respect of any personal information received, subject to any permitted exceptions to those obligations.
It is conceivable that personal information may be disclosed by THG to a business or government agency located in a jurisdiction other than Australia, as we are based in Thailand as are our suppliers. We will not disclose personal information to an overseas (Outside of Thailand) recipient unless it is necessary for the negotiation or performance of a contract between you and the overseas recipient (or its Australian principal) that we are arranging on your behalf (a booking), or for the negotiation or performance of a contract between us and the overseas recipient that is necessary to give effect to your booking or is otherwise in your interest.
We will endeavour where possible not to deal with overseas recipients unless they have undertaken to comply with Australian Privacy Principles/ Thailand Privacy laws or we believe they are subject to a law in their jurisdiction that overall is at least substantially similar to the way in which the Australian Privacy Principles protect personal information and enforcement mechanisms are available in the event of a breach of privacy. If these circumstances do not apply then we will not release your personal information unless you expressly consent.
In the course of providing services to customers who are travelling overseas, it is likely that THG will disclose personal information to Australian and Thai based travel organisations such as airlines and tour companies who will in turn disclose that information to an overseas recipient. You should be aware that THG holds no responsibility for the treatment of your personal information by that overseas recipient, although the Australian travel organisation to which we provided it will also be bound by the Australian Privacy Principles. Therefore, the Australian travel organisation will be responsible to ensure that the overseas recipient has undertaken to comply with Australian Privacy Principles or the Australian travel organisation believes the overseas recipient is subject to a law in its jurisdiction that overall is at least substantially similar to the way in which the Australian Privacy Principles protect personal information and enforcement mechanisms are available in the event of a breach of privacy.
THG will retain the personal information for so long as is reasonably necessary for its purposes but we will destroy or permanently remove the identifying features of personal information if it is no longer needed.
ACCESS TO PERSONAL INFORMATION
You can request us to provide access to the personal information that we hold about you.
You may request us to amend the details of the personal information we hold. We will amend the details on request provided we are satisfied that the amendment is valid. We may in some circumstances request you to provide documentary evidence or other corroboration of validity (e.g. provision of a marriage certificate or a registered deed poll to amend your name). If we do not consider it appropriate to make an amendment we will notify you within a reasonable time including written reasons for the refusal.
If we refuse to amend details of any personal information that we hold following a request from you, you may request that we include in our records a statement associated with the applicable information that will make apparent to users of the information that you contest its validity (“a qualifying statement”).
If you consider that THG has wrongly failed to amend its records or not complied with the Australian Privacy Principles in its treatment of your personal information you may lodge a written complaint detailing the grounds of complaint. All complaints received will be considered by a senior manager of the organisation and a written response, including a statement of any remedial action to be taken if appropriate, will be provided to you within a reasonable time.
To request access, request an amendment, request a qualifying statement or make a complaint please contact us using the details provided below.
Personal information in email we receive from you, including email addresses, will only be used for the purposes given and are subject to the conditions set out in this privacy statement. However, communications over the Internet are inherently insecure. Sending personal information in an email remains entirely at your own risk and THG will not be responsible for any unauthorised use of this information by third parties.
VISITING OUR WEBSITE
We may collect information on website activity, such as the number of visitors, the number of pages viewed, navigation patterns, what systems users have and the date and time of visits. This information is collected for statistical purposes only and will not be used to identify you.
We may also utilise “cookies” which enable us to monitor website traffic patterns and to serve you more efficiently if you revisit the site. A “cookie” is a small software file that is placed on your computer and enables our website to recognise your computer upon a return visit. You can set your browser to notify you when you receive a cookie and this will provide you with an opportunity to either accept or reject it in each instance. Please be aware that disabling cookies may impede your use of the website to some extent.
If you allow the cookie to apply then the data collected will enable better understanding of your pattern of use and areas of interest which facilitates the improvement of our website, both as to content and its ease of use.
We use two types of cookies, depending on whether you are a registered user or a casual visitor to our website. If you are a registered user with an allocated Agent ID then the cookie information will be linked to your user account, and you will thereby be personally identified. If you are a casual visitor (including registered users who choose not to login) then the operation of the cookie is “session based” and will expire 20 minutes after your browser ceases to be active, or upon the browser being closed. A session based cookie will not identify you personally, only the unique identification code of the computer you are using.
Cookies may be used to identify the location of your computer which assists us to tailor products and services appropriate to users in particular locations. Information about your location may be collected in a number of ways including:
Using your IP Address to determine the State/country that you are in;
Using your GeoLocation information to determine your exact location (a user must opt in to use this service);
Storing of postcode / agent search queries.
The information collected about your location is to help you make the most use of the THG website by making it easier for you to find an agent that is in your local area. This information will be stored only temporarily if your visit to the website is “session based” or if you login as a registered user in a cookie on your computer. This information is not retained or stored by THG on our database and THG does NOT distribute it to third parties.
We may also use pixel tags which interact with a user’s web browser to allow certain data about our IT systems’ interaction with users to be collected, such as whether email we have sent has been opened and viewed. The purpose of collecting this information is to assess the general effectiveness of our email transmissions and other electronic communications.
The THG website may contain links to third-party websites. Please take note that THG is in no way responsible for the content or the privacy practices on these sites.
If you have any questions about this privacy statement, the privacy practices of THG, or you wish to make a request or lodge a complaint, please do so in writing to:
The Privacy Manager
Further information on the Privacy Act and the National Privacy Principles can be found on the Australian Information Commissioner’s website at: www.privacy.gov.au
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