Privacy Policy
Privacy Protection Principles
1. PURPOSE
Goldman Travel Corporation is committed to the protection of personal privacy as required under the Privacy Act 1988 (Cth) ("the Privacy Act") and has adopted a set of privacy principles based on the National Privacy Principles contained in Schedule 3 of the Privacy Act.
2. POLICY
This policy sets out Goldman Travel Corporations Privacy Protection Principles. These are the principles that Goldman Travel Corporation has adopted in order to protect information about individuals. These principles deal with the collection, use and disclosure of personal information, as well as access to information and intrusion issues. It also sets out the principles that Goldman Travel Corporation will adopt when considering the introduction of new technology or services.
Goldman Travel Corporation Privacy Protection Principles:
Principle 1 - Collection
Goldman Travel Corporation will only collect personal information that is necessary for one or more of its functions or activities. Goldman Travel Corporation will only collect personal information by lawful and fair means and not in an unreasonably intrusive way. At or before the time (or, if that is not practicable, as soon as practicable thereafter), Goldman Travel Corporation collects personal information about an individual from the individual, Goldman Travel Corporation will take reasonable steps to ensure that the individual is aware of:
(a) The identity of Goldman Travel Corporation and how to contact it;
(b) The fact that he or she is able to gain access to the information;
(c) The purposes for which the information is collected;
(d) The organisations (or the types of organisations) to which Goldman Travel Corporation usually discloses information of that kind; and
(e) The main consequences (if any) for the individual if all or part of the information is not provided.
If it is reasonable and practicable to do so, Goldman Travel Corporation will collect personal information about an individual only from that individual. If Goldman Travel Corporation collects personal information about an individual from someone else, Goldman Travel Corporation will take reasonable steps to ensure that the individual is or has been made aware of the matters listed from (a) to (e).
Principle 2 - Use & Disclosure
Goldman Travel Corporation will only use or disclose personal information about an individual for a purpose other than the primary purpose of collection (a secondary purpose) if:
(a) Both of the following apply:
(i) The secondary purpose is related to the primary purpose of collection and, if the personal information is sensitive information, directly related to the primary purpose of collection;
(ii) The individual would reasonably expect Goldman Travel Corporation to use or disclose the information for the secondary purpose; or
(b) The individual has consented to the use or disclosure; or
(c) The information is not sensitive information and the use of the information is for the purpose of direct marketing and: (i) It is impracticable for Goldman Travel Corporation to seek the individual's consent before that particular use; and (ii) Goldman Travel Corporation will not charge the individual for giving effect to a request by the individual to Goldman Travel Corporation not to receive direct marketing communications; and (iii) the individual has not made a request to Goldman Travel Corporation not to receive direct marketing communications; and (iv) in communication with the individual, Goldman Travel Corporation draws to the individual's attention, or prominently displays a notice, that he or she may express a wish not to receive any further direct marketing communications; and (v) each written marketing communication by Goldman Travel Corporation with the individual (up to and including the communication that involves the use) sets out Goldman Travel Corporation business address and telephone number and, if the communication with the individual is made by fax, telex or other electronic means, a number or address at which Goldman Travel Corporation can be directly contacted electronically; or
(d) Goldman Travel Corporation has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or
(e) The use or disclosure is required or authorised by or under law; or
(f) Goldman Travel Corporation reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body:
(i) The prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
(ii) The enforcement of laws relating to the confiscation of the proceeds of crime;
(iii) The protection of the public revenue;
(iv) The prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;
(v) The preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
(g) If Goldman Travel Corporation uses or discloses personal information under paragraph (f) above, it will make a written note of the use or disclosure.
(h) The first paragraph above operates in relation to personal information that Goldman Travel Corporation has collected from a related body corporate or business as if Goldman Travel Corporation primary purpose of collection of the information were the primary purpose for which the related body corporate or business collected the information.
Principle 3 - Data Quality
Goldman Travel Corporation will take reasonable steps to make sure that the personal information it collects, uses or discloses is accurate, complete and up-to-date.
Principle 4 - Data Security
Goldman Travel Corporation will take reasonable steps to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure.
Goldman Travel Corporation will take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed for any purpose for which the information may be used or disclosed under Goldman Travel Corporation Privacy Protection Principle 2.
Principle 5 - Openness
Goldman Travel Corporation will set out in a document clearly expressed policies on its management of personal information. Goldman Travel Corporation will make the document available to anyone who asks for it. On request by an individual, Goldman Travel Corporation will take reasonable steps to let the individual know, generally, what sort of personal information it holds, for what purposes, and how it collects, uses, and discloses that information.
Principle 6 - Access and Correction
If Goldman Travel Corporation holds personal information about an individual, it will provide the individual with access to the information on request by the individual, in a form or manner suitable to the individual's reasonable needs, except to the extent that:
(a) In the case of personal information, providing access would pose a serious and imminent threat to the life or health of any individual; or
(b) Providing access would have an unreasonable impact upon the privacy of other individuals; or
(c) The request for access is frivolous or vexatious; or
(d) The information relates to existing or anticipated legal proceedings between Goldman Travel Corporation and the individual, and the information would not be accessible by the process of discovery in those proceedings; or
(e) Providing access would reveal the intentions of Goldman Travel Corporation in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
(f) Providing access would be unlawful; or
(g) Denying access is required or authorised by or under law; or
(h) Providing access would be likely to prejudice an investigation of possible unlawful activity; or
(i) Providing access would be likely to prejudice:
(i) The prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or
(ii) The enforcement of laws relating to the confiscation of the proceeds of crime; or
(iii) The protection of the public revenue; or
(iv) The prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
(v) The preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders; by or on behalf of an enforcement body; or
(j) An enforcement body performing a lawful security function asks Goldman Travel Corporation not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia. However, where providing access would reveal evaluative information generated within Goldman Travel Corporation in connection with a commercially sensitive decision-making process, Goldman Travel Corporation may give the individual an explanation for the commercially sensitive decision rather than direct access to the information. If Goldman Travel Corporation has given an individual an explanation under the above paragraph and the individual believes that direct access to the evaluative information is necessary to provide a reasonable explanation of the reasons for the decision, Goldman Travel Corporation will, at the request of the individual, undertake a review of the decision not to release the information. Personnel other than the original decision-maker will undertake the review. If Goldman Travel Corporation is not required to provide the individual with access to the information because of one or more of paragraphs (a) - (j) above (inclusive), Goldman Travel Corporation will, if reasonable, consider whether the use of mutually agreed intermediaries would allow sufficient access to meet the needs of both parties. If Goldman Travel Corporation levies charges for providing access to personal information, those charges:
(a) Will not be excessive; and
(b) Will not apply to lodging a request for access.
If Goldman Travel Corporation holds personal information about an individual and the individual is able to establish that the information is not accurate, complete and up-to-date, Goldman Travel Corporation will take reasonable steps to correct the information so that it is accurate, complete and up-to-date. If the individual and Goldman Travel Corporation disagree about whether the information is accurate, complete and up-to-date, and the individual asks Goldman Travel Corporation to associate with the information a statement claiming that the information is not accurate, complete or up-to-date, Goldman Travel Corporation will take reasonable steps to do so. Goldman Travel Corporation will provide reasons for denial of access or a refusal to correct personal information.
Principle 7 - Identifiers
Except as specifically authorised under the Privacy Act, Goldman Travel Corporation will not adopt as its own identifier of an individual an identifier of the individual that has been assigned by:
(a) An agency; or
(b) An agent of an agency acting in its capacity as agent; or
(c) A contracted service provider for a Commonwealth contract acting in its capacity as contracted service provider for that contract.
Goldman Travel Corporation will not use or disclose an identifier assigned to an individual by an agency (or by an agent or contracted service provider mentioned above) unless:
(i) The use of disclosure is necessary for Goldman Travel Corporation to fulfill its obligations to the agency;
(ii) One or more of paragraphs (e) to (h) in Privacy Protection Principle 2 above (inclusive) apply to the use or disclosure; or
(iii) The use or disclosure is permitted under the regulations to the Privacy Act.
Note - the terms 'agency' and 'contracted service provider' in Privacy Protection Principle 7 are defined in the Privacy Act, but, in general, relate to Commonwealth Government agencies.
Principle 8 - Anonymity
Wherever it is lawful and practicable, individuals will have the option of not identifying themselves when entering transactions with Goldman Travel Corporation. However, in most cases it will not be practicable for the transactions to proceed to finality or for Goldman Travel Corporation to provide pre and post-paid services without requiring their identification.
Principle 9 - Transborder Data Flows
Goldman Travel Corporation will transfer personal information about an individual to someone (other than Goldman Travel Corporation or the individual) who is in a foreign country only if:
(a) Goldman Travel Corporation reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to Goldman Travel Corporation Privacy Protection Principles; or
(b) The individual consents to the transfer; or
(c) The transfer is necessary for the performance of a contract between the individual and
Goldman Travel Corporation, or for the implementation of pre-contractual measures taken in response to the individual's request; or
(d) The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Goldman Travel Corporation and a third party; or
(e) All of the following apply:
(i) The transfer is for the benefit of the individual; and
(ii) It is not practicable to obtain the consent of the individual to that transfer; and
(iii) If it were practicable to obtain such consent, the individual would be likely to give it; or
(f) Goldman Travel Corporation has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with Goldman Travel Corporation Privacy Protection Principles.
Principle 10 - Sensitive Information
Goldman Travel Corporation will not collect Sensitive Information about an individual unless:
(a) The individual has consented; or
(b) The collection is required by law; or
(c) The collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns:
(i) Is physically or legally incapable of giving consent to the collection; or
(ii) Physically cannot communicate consent to the collection; or
(d) The collection is necessary for the establishment, exercise or defence of a legal or equitable claim.
Principle 11 - Privacy of Network Communications
When installing, operating, or maintaining its network, Goldman Travel Corporation will take whatever measures are practicable, or are required by law, to ensure the privacy of communications passing over its network. Interception (Monitoring and Recording). Interception of a communication during the course of its passage across the network is prohibited unless it is necessary for the effective performance of functions or activities relating to:
the installation of any line or equipment used in connection with the network, or
the operation or maintenance of the network, or the identifying or tracing of a person suspected of having contravened a provision of Part VIIB of the Crimes Act 1914 (Cth); interception requested by law enforcement and security agencies (which will only be undertaken on production of a lawful warrant and where Goldman Travel Corporation is satisfied that the warrant has been issued in accordance with the requirements with the Telecommunications (Interception) Act 1979 (Cth). In addition, recording will only be undertaken where aural/visual monitoring is not suitable for the purpose and voice recording will only be undertaken where authorised by the customer or by law.)
Interception will only be undertaken in accordance with company procedures. Only staff who have received instruction on the appropriate monitoring and recording procedures and who are aware of their responsibilities for the protection of customer privacy and confidentiality will be permitted to undertake monitoring functions.
Participant Monitoring. Participant monitoring may be undertaken for the purposes of improving the quality of service to customers and the training of staff, or where there is a specific operational, security or technical reason to do so. Customer consent will be obtained prior to undertaking participant monitoring unless it is not practicable to do so, such as in the case of calls or monitoring which are typically of very short duration.
Principle 12 - New Services and Developments and Procedures.
Goldman Travel Corporation will consider the privacy impact of new business processes and services before they are introduced.
Privacy expectations
Goldman Travel Corporation will provide services with privacy standards that are commensurate with community expectations and which enables individual customers to choose a higher degree of privacy protection where practicable.
Privacy implications of change
The privacy impact arising from the introduction of the new services or products will be balanced against their benefit to the general community and will take into consideration the extent, means and cost by which privacy concerns can be mitigated. Where practicable, Goldman Travel Corporation will provide customers with the ability to choose between differing degrees of privacy protection. Education and choice In order that customers may make an informed choice as to their usage of new services or products, where appropriate Goldman Travel Corporation will advise customers of the privacy implications of those services.
Where practicable, and where to do so would not undermine commercially sensitive material, Goldman Travel Corporation will respond to queries concerning any implications for privacy protection of existing and new services and make publicly available information about any implications for privacy protection in relation to those services.
Principle 13 - Compliance Audit
Goldman Travel Corporation will maintain an independent compliance audit program to ensure its Privacy Protection Principles and policies remain appropriate and that Goldman Travel Corporation operates in compliance with those Principles and policies.
3 DEFINITIONS
Identifier includes a number assigned by an organisation to an individual to identify uniquely that individual for the purposes of the organisation's operations. However, an individual's name or ABN (as defined in A New Tax System (Australian Business Number) Act 1999) is not an identifier. Individual means a natural person.
Monitoring means the listening to, reading or recording of a communication during the course of its passage over a telecommunication system. Participant monitoring means the listening to, reading or recording of, a communication during the course of its passage over a telecommunication system by a party to that communication and by using equipment forming part of the service. Personal Information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Privacy Act means the Privacy Act 1988 (Cth), as amended from time to time. Sensitive Information means:
(a) information or an opinion about an individual's:
(i) racial or ethnic origin; or
(ii) political opinions; or
(iii) membership of a political association; or
(iv) religious beliefs or affiliations; or
(v) philosophical beliefs; or
(vi) membership of a professional or trade association; or
(vii) membership of a trade union; or
(viii) sexual preferences or practices; or
(ix) criminal record; that is also personal information; or
(b) health information about an individual.
Seriously Improper Conduct includes corruption, a serious abuse of power, a serious dereliction of duty, or any other seriously reprehensible behaviour.
Surveillance means the systematic observance of a person's behaviour, communication or personal information. Third Party in relation to personal information, means any organisation or individual other than COL holding the information and the individual who is the subject of the information. Unless otherwise specified, words in this document have the meaning set out in the Privacy Act.
4 REFERENCES
Doc. No. Title
1. Privacy Statement
2. Privacy Protection Policy/Procedure
5 RESPONSIBLE EXECUTIVE
Managing Director : Tom Goldman
Signed:
APPROVED
Trading as Goldman Travel Corporation Pty Ltd, www.goldmantravel.com.au
Privacy Statement
Goldman Travel Corporation Pty Ltd (ABN 71105456899 ), trading as "Goldman Travel Corporation".
Goldman Travel Corporation is committed to providing you with the highest levels of customer service. This includes protecting your privacy. We are also bound by new sections of the Commonwealth Privacy Act 1988, which set out a number of principles concerning the protection of your personal information.
This statement, called "Protecting Your Privacy Online", sets out important information about privacy protections that we extend to your personal information. It relates to personal information that you provide to us through our website(s) (e.g. when you subscribe to our services online).
For more detail on GTC's approach to privacy generally, please refer to GTC's PRIVACY POLICY available on our website at our place of business and at any time upon request.
How we collect personal information
GTC collects personal information in a number of ways, including:
Directly from you, such as when you enter your personal details on our websites (e.g. during registration or application for products and services), when you provide information by phone or in documents such as an application form;
From third parties such as your representatives; P From publicly available sources of information;
From the organisations identified below under "When we disclose your personal information";
From our own records.
How we use your personal information
Your personal information may be used to:
Identify you and to assist you to subscribe to our website services more easily;
Provide the services you require;
Administer and manage those services, including charging, billing and debt recovery;
To help us gain an understanding of your publicity needs in order for us to provide you with better, more personalised services that are tailored to your needs;
Inform you of ways the services provided to you could be improved;
Conduct appropriate checks for credit-worthiness and for fraud;
Research and develop our services;
Maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
Your personal information is also collected to promote and market to you other services which we consider may be of interest to you. You may notify us at any time that you do not wish to receive marketing or promotional material by calling us by phone or by using the or email contacts listed within our site.
GTC Websites
GTC provides a range of web-based services. Most of these services are provided on our web site www.goldmantravel.com.au . We refer to these as "our web sites".
The marketing information provided on our websites will be determined by where you decide to visit on the site. Advertisements will also be presented to you, but the placement of these is not related specifically to any details we hold about you.
Personal information collected for our websites
The types of personal information we collect from you will depend on how you use our websites. Such information may include your name, date of birth, gender, current and previous addresses, telephone/mobile phone number, email address, bank account or credit card details, occupation, driver's license number and your GTC username or password. We may also collect details of your GTC services (including their status) and your personal interests.
If you choose not to provide personal information, we may not be able to provide you with the services you require, or the level of service on which we pride ourselves.
Other information
Our websites record other information as well. This information is used to improve the structure and performance of those sites to provide users with an improved service. Whenever a page is requested from our web server, we record the time, date and URL of the request, along with information on the browser software that is being used. GTC uses "cookies". Cookies are pieces of information that a web site can transfer to an individual's computer hard drive for record keeping. Cookies can make using our websites easier by storing information about your preferences on a particular website. This will enable you to take full advantage of the services we offer. The use of cookies is an industry standard and you'll find most major websites use them. Most Internet browsers are pre-set to accept cookies. If you prefer not to receive cookies, you can adjust your Internet browser to disable cookies or to warn you when cookies are being used.
GTC uses ad-serving services for our websites. These may use cookies for anonymous profiling of users to tailor advertising to user preferences but they do not collect personally identifiable information from our web sites. You may opt-out of anonymous profiling if you wish.
GTC gathers usage information from our websites and other websites. This is aggregated for purposes of our services. Personally identifiable characteristics are removed and users remain anonymous, unless you have given prior express consent for GTC to recognise your usage. This data is gathered by us to examine Internet trends and demographics and to assist in improving the structure and ease of use of our websites.
When we disclose your personal information for the purposes set out above (under "How we use your personal information") we may disclose your personal information to organisations outside GTC. Where appropriate, these disclosures are subject to privacy and confidentiality protections. The organisations to which we usually disclose information include:
Outsourced service providers who manage the services we provide to you, including:
information technology services;
installation, maintenance and repair services;
marketing services;
market research;
Your representatives (e.g. your authorised representatives or legal advisers);
Credit-reporting and fraud-checking agencies;
Credit providers for credit related purposes such as creditworthiness, credit rating, credit provision and financing;
Our professional advisers, including our accountants, auditors and lawyers;
Government and regulatory authorities and other organisations, as required or authorised by law;
Organisations involved in:
Assessment, valuation and/or (if any) transfer/sale of all or part of our assets or business (including accounts and trade receivables); and
Managing our corporate risk and funding (e.g. banks or other financial institutions); and
Help us to ensure we hold accurate information
GTC takes all reasonable precautions to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of the information we hold depends to a large extent on the information you provide. That's why we recommend you:
let us know if there are any errors in your personal informatio and keep us up to date with changes to your personal information such as your name or address.
You can easily edit or delete the personal information you provide to us on our websites (unless it is mandatory information required for your membership application), but to do so, you will need to log in as a registered user, using your username and password.
If you wish to access or modify personal information which you have provided via our websites, but cannot access that information at our websites, please send an email using the Contact Us page on the GTC website.
You can access your personal information
You have a right to access your personal information, subject to some exceptions allowed by law. If you would like to do so, please let us know by sending an email using the Contact Us page on the GTC website. You may be required to put your request in writing for security reasons.
Security of your information
We take reasonable steps to ensure that your personal information is stored securely. Transmissions sent to or from our websites are routinely monitored for quality control and systems administration. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. While we strive to protect your personal information from misuse, loss and unauthorised access, we cannot guarantee the security of any information you transmit to us or receive from our online products or services. These activities are conducted at your own risk. Once we receive your transmission, we make our best effort to ensure its security.
Credit card information is among the most important data we collect. GTC operates secure servers to minimise the risk of unauthorised use of such information. Credit card information that is transmitted via our secure servers is encrypted in accordance with the highest standards over the EFTPOS network. For obvious reasons, please do not send credit card information through unsecured email.
What else you should know about privacy
Remember to close your browser when you have finished your user session. This is to ensure that others cannot access your personal information and correspondence if you share a computer with someone else. You as an individual are responsible for the security of and access to your own computer.Please be aware that whenever you voluntarily disclose personal information over the Internet (for example: in discussion forums, via email, or in chat sites) that this information can be collected and used by others. In short, if you post personal information in publicly accessible online forums, you may receive unsolicited messages from other parties in return.Ultimately, you are solely responsible for maintaining the secrecy of your username and passwords and any account information. Please be careful and responsible whenever you are using the Internet and our websites.
When we disclose your personal information
For the purposes set out above (under "How we use your personal information") we may disclose your personal information to organisations outside GTC. Where appropriate, these disclosures are subject to privacy and confidentiality protections. The organisations to which we usually disclose information include:
Outsourced service providers who manage the services we provide to you, including:
information technology services;
installation, maintenance and repair services;
marketing services; market research; and events management.
Your representatives (e.g. your authorised representatives or legal advisers); Credit-reporting and fraud-checking agencies; Credit providers for credit related purposes such as creditworthiness, credit rating, credit provision and financing; Our professional advisers, including our accountants, auditors and lawyers; Government and regulatory authorities and other organisations, as required or authorised by law; Organisations involved in:
Assessment, valuation and/or (if any) transfer/sale of all or part of our assets or business (including accounts and trade receivables); and
Managing our corporate risk and funding (e.g. banks or other financial institutions); and Our related companies or businesses.
How to contact us
If you have any questions in relation to privacy, please contact us by phone between 8.30 am and 6.00 pm, Monday to Friday. Alternatively, you can:
Use the Contact Us page on the GTC website to send your questions and comments via email to sales@goldmantravel.com.au ; or Write to our CEO & Managing Director, Tom Goldman (our Privacy Manager), at Level 18 , Westfield Tower One, 520 Oxford St, Bondi Junction NSW 2022.