Privacy Policy
This privacy policy (Privacy Policy) sets out how Jonathan Fambart ABN 29 101 712 201 trading as Living Life Travel and/or Joncierge (we, our, us) collects, stores, uses, protects, shares and discloses your personal information.
By providing personal information to us (either directly or on behalf of someone else) you agree to the collection, storage, usage and disclosure of your personal information by us in the manner described in this Privacy Policy. This policy also applies to our website located at www.joncierge.com.au and www.livinflife.travel and its related services, products, websites, tools and applications (together the Website).
Capitalised words in this Privacy Policy have the same meaning as in the Terms of Service available on the Website.
1. Types of Personal Information we collect
As part of delivering our Website we may collect personal information about you as defined under the Privacy Act 1998 (Privacy Act). We will only collect personal information where it is reasonably necessary for the performance of our functions or activities. The personal information we collect may include the following:
· Booking information: this includes information that we collect in order to fulfil the provision of the Services to you. This includes generally any information that is needed to facilitate the booking of travel services on your behalf. For example we may collect your name, residential address, telephone number, email address, passport details, loyalty or frequent flyer cards and any additional information provided to us such as any disability access requests, seating requests or allergen details or other information you provide to us during the provision of the Services.
· Financial information: this includes information such as payment card details and bank account details. We use this information to send to our third party payment gateways when payment of fees are due.
· Website use information: When you use our Website, for example when you contact us, we collect information that enables the Website to be able to run.
· Surveys: information in connection with client surveys, questionnaires and promotions;
· Other information we collect related to your use of the Website: your device identity and type, I.P. address, geo-location information, page view statistics, advertising data and standard web log information and any other information provided by you to us via our Website or our online presence, or otherwise required by us or provided by you.
Sensitive Information
As part of delivering our Services, we may collect health and other sensitive information about you as defined by the Privacy Act. For example, we may collect information about your disability or allergen history to assist us in providing you our Services. In general, we attempt to limit the sensitive information we collect, however this may not always be possible due to the Services we provide. Where we collect sensitive information from you we will only do so if it is considered reasonably necessary for us to collect such information for us to perform our functions or activities and you consent, or collection is required or authorised by law or another exception under the Privacy Act applies.
2. How we collect Personal Information
We may collect personal information either directly from you, or from third parties, including where:
· you deal with us in person, email, telephone, SMS, social applications (such as LinkedIn, Facebook or Twitter) or otherwise
· you visit our Website or you use the Website generally;
· you subscribe to any of our newsletters;
· you contact us through our Website, in person, by phone or in writing;
· you submit any of our online forms;
· you interact with our Website, social applications, services, content and advertising; and
· you invest in our business or enquire as to a potential purchase of our business.
Where we collect your personal information from a third party, we will take reasonable steps to ensure that you are made aware of the information provided to us by the third party.
Social media and cookies
We may also collect personal information from you when you use or access our Website or our social media pages. Please review our Cookies Policy below.
3. Use of your Personal Information
We collect and use personal information for the following purposes:
· to provide our Services or information to you including to:
o facilitate the booking of travel services with Operators;
o provide travel advice;
o assist you in booking travel services and/or related products and services;
o ensure the Services are delivered to you;
o assist in streaming and personalising information for you;
o enable us to process your personal data;
o to manage our relationship with you, including information about similar services or send you an email reminder that a task you have performed on our Website remains uncompleted such an incomplete form;
o enable you to communicate with us regarding your use of the Website;
o confirm your identity;
o to provide information about you to our contractors, employees, consultants, agents or other third parties for the purpose of providing the services to you;
o communicate with you about your Account, or any transaction;
· to be de-identified for the purposes of generating statistical data and improving the Website;
· for record keeping and administrative purposes;
· to improve and optimise our service offering and customer experience;
· to comply with our legal obligations, resolve disputes or enforce our agreements with third parties;
· to administer and protect our services;
· to enable you to take part in a competition;
· to send you marketing and promotional messages and other information that may be of interest to you and for the purpose of direct marketing (in accordance with the Spam Act 2003 (Cth)). In this regard, we may use email, SMS, social media or mail to send you direct marketing communications. You can opt out of receiving marketing materials from us by using the opt-out facility provided (e.g. an unsubscribe link);
· to send you administrative messages, reminders, notices, updates, security alerts, and other information requested by you; and
· to consider an application of employment from you.
4. Disclosure of your Personal Information
We may disclose your personal information to our employees, service providers who assist us to provide the Services to you such as providers of website development services, postal and shipping agents, information technology service providers, contractors and other third parties who provide us with any assistance located inside or outside of Australia. We may also disclose your personal information to travel service Operators where travel services are requested and/or booked with such Operators.
Where we use a supplier outside of Australia, we will take reasonable steps in the circumstances to ensure that such overseas recipient does not breach the Australian Privacy Principles (except where such steps are not required under the Privacy Act).
We may also disclose your personal information to third parties to whom you expressly ask us to send the personal information to or to third parties where permitted under the Privacy Act. This also includes:
(a) your authorised representatives;
(b) third party service providers;
(c) government and regulatory authorities and other similar organisations, as required or authorised by law; and
(d) such entities that we propose to merge with or be acquired by.
If you access third-party services to login to the Website, or to share information with, these third-party services may be able to collect your information in accordance with their privacy policies. We may also send your personally identifiable information to our payment service providers.
Any information that you post or share or otherwise disclose to the Website or our social media platforms, becomes available to the public, as controlled by any applicable privacy settings you set.
We may also share information you provide us for testimonials and social media marketing, and you expressly consent to such use and disclosure for such purposes.
We may also aggregate and/or make anonymous your personal information including sensitive information to make it available for the purposes of generating statistical data for the conducting of research and improving the Website.
5. Cookies Policy
We also use cookies and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Website. Persistent Cookies can be removed by following Internet browser help file directions. Cookies may enable automatic logins when you visit in the future and may enable content customisation.
If you do not wish information to be stored as a cookie, you can disable cookies in your web browser.
We may also use third party vendor re-marketing tracking cookies, including the Google Adwords tracking cookie. This means we will continue to show ads to you across the internet, specifically on the Google network. The third-party vendors, including Google, will place cookies on web browsers in order to serve ads based on past visits to our Website. You can opt out of Google's use of cookies or device identifiers by visiting Google's Ads Settings. Alternatively, you visit the Network Advertising Initiative opt-out page or control the use of device identifiers by using your device’s settings.
6. Storage & security
We use third-party cloud providers that provide hosting, data storage and other services.
We take reasonable steps to ensure your personal information is secure and protected from misuse or unauthorised access. Our information technology systems are password protected, and we use a range of administrative and technical measures to protect these systems. However, we cannot guarantee the security of your personal information.
We will retain your personal information for the period necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.
7. Links
From time to time we may include embedded content from, and links to, other websites. Those websites are not under our control. The links and embedded content are provided for your convenience only. We do not endorse, and are not responsible for the content, validity, accuracy or your use of, those websites. You should check the terms and conditions of use of those websites before you use them.
You may not create a link to the Website from another website (other than to the home page) without our prior written consent, which may be given or withheld at our sole discretion.
8. Requesting access or correcting your Personal Information
Subject to the Privacy Act, you have a right to access and correct any personal information about you that we may hold. If you wish to request access to the personal information, we hold about you, please contact us using the contact details set out below including your name and contact details. We may need to verify your identity before providing you with your personal information. In some cases, we may be unable to provide you with access to all your personal information and where this occurs, we will explain why. We will deal with all requests for access to personal information within a reasonable timeframe.
If you think that any personal information we hold about you is inaccurate, please contact us using the contact details set out below and we will take reasonable steps to ensure that it is corrected.
If we receive a request from you to access or correct personal information we will respond to you within a reasonable time after receiving your request and in the manner requested by you, if it is reasonable and practicable for us to do so. We may charge a reasonable fee for giving access to the information.
9. If we can’t collect your Personal Information
If you do not provide us with the personal information described above, some or all of the following may happen:
· we may not be able to provide the Website to you, either to the same standard or at all;
· we may not be able to provide you with information about the Website that you may want; or
· we may be unable to tailor the content of our Website to your preferences and your experience of our services may not be as enjoyable or useful.
10. Notifiable data breach
In the event that there is a data breach and we are required to comply with the notification of eligible data breaches provisions in Part IIIC of the Privacy Act or any other subsequent sections or legislation which supersede this Part IIIC, we will follow our relevant notifiable data breach procedures in compliance with the Privacy Act and relevant laws.
11. Updates
This Privacy Policy is subject to occasional revision and we reserve the right, at our sole discretion, to modify or replace any part of this Privacy Policy. It is your responsibility to check this Privacy Policy periodically for changes. Continued use of our Website shall indicate your acknowledgement of that it is your responsibility to review the Privacy Policy periodically and become aware of any modifications. We may amend this Privacy Policy from time to time. Not all changes to our Privacy Policy will require your consent, for example where office security procedures are changed. We will notify you of any change to our information handling policy that requires your consent before being implemented.
12. Enquiries, requests & complaints
Enquiries regarding this Privacy Policy or the personal information we may hold on you, should be addressed with the Privacy Officer, whose contact details are below.
If you think your personal information, held by us, may have been compromised in any way or you have any other Privacy related complaints or issues, you should also raise the matter with the Privacy Officer.
We will ensure your claims are investigated and a formal response will be provided to you, within a reasonable time, considering the circumstances of your claims. If any corrective action is determined to be required, as a result of that investigation, we will take all reasonable steps to rectify the situation and advise you of such, again within a reasonable time considering the circumstances.
If we do not resolve your enquiry, concern or complaint to your satisfaction or you require further information in relation to any privacy matters, please contact the Office of the Australian Information Commission, whose contact details are below.
Office of the Australian information Commission
Telephone 1300 363 992
Email enquiries@oaic.gov.au
Office Address Level 3, 175 Pitt Street, Sydney NSW 2000
Postal Address GPO Box 5218, Sydney NSW 2001
Website www.oaic.gov.au
Contacting us
Entity
Jonathan Fambart ABN 29 101 712 201 trading as Living Life Travel and/or Joncierge