Privacy - 28 February 2020

1. Privacy

     1.1       At Bunnik Tours, we respect the importance of your privacy and we are committed to safeguarding your personal information. We understand that how we collect, use, disclose and protect your information is important to you. In order to provide our service as a tour operator to you, we must collect personal information from you, and we will take all steps reasonable to ensure that your personal information is treated securely and in accordance with this privacy policy (Privacy Policy).

     1.2       Our Privacy Policy sets outs out how we collect, use, disclose, store, and protect your personal information.

     1.3       By providing personal information to us, you consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us and you.

     1.4       We may change this Privacy Policy from time to time by publishing changes to it on the Website. We encourage you to check the Website periodically to ensure that you are aware of our current Privacy Policy.

     1.5       By using the Website after changes have been made to the Privacy Policy, you are deemed to have consented to those changes.


2. Definitions

In this Privacy Policy:

     2.1       Bunnik Tours or we or us means Bunnik Travel Pty Ltd (ACN 077 203 466);

     2.2       Associate means any Associated Entity (as defined in section 50AAA of the Corporations Act 2001 (Cth)) of Bunnik Tours; including Small Group Touring Company Australia (ACN 626 199 906);

     2.3       personal information means information that can be associated with a specific person and can be used to identify that person and includes your information and the types of information described in clause 3.1 of this Privacy Policy;

     2.4       the word "person" includes an individual, the estate of an individual, a corporation, an authority, an association or a joint venture (whether incorporated or unincorporated), a partnership and a trustee of a trust or any other entity;

     2.5       Privacy Policy means this privacy policy (as amended from time to time);

     2.6       Service Providers means third-party providers over whom we have no (or limited) control such as airlines, ground operators (including, but not limited to, coaches, shipping, rail and cars for hire), restaurants and hoteliers,

     2.7       Website means the website provided by us which allows you to view or order or otherwise deal with services, products or goods provided or offered by us; which includes or any other web service, software, application or media managed by us or our agents or representatives;

     2.8       you or your means the person, firm or organisation (including you) entering into, or that has entered into, a contract, transaction or arrangement to obtain or make use of services, products or goods provided or offered by us or our agents or representatives;

     2.9       the parties agree that the whole or any part of any clause of this Privacy Policy that is illegal or unenforceable will be severed from this Privacy Policy and will not affect the continued operation of the remaining provisions of this Privacy Policy.


3. Collecting Personal Information

     3.1       We may collect the following types of personal information:

          3.1.1       name;

          3.1.2       gender;

          3.1.3       mailing or street address;

          3.1.4       email address;

          3.1.5       telephone number and other contact details;

          3.1.6       age or date of birth;

          3.1.7       photographs or other images;

          3.1.8       passport details, travel preferences and experiences, travel rewards and loyalty program membership details;

          3.1.9       health and medical information relating to your current and previous health status, current and previous medical conditions, dietary requirements and travel insurance details (where applicable);

          3.1.10     financial information such as credit card information or bank account numbers;

          3.1.11     your device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address, standard web log information and page interaction information;

          3.1.12     details of the services, products and goods we (or any of our Associates) have provided you or that you have enquired about, including any additional information necessary to deliver those services, products and goods and respond to your enquiries;

          3.1.13     any additional information relating to you that you provide to us directly through the Website or indirectly through your use of the Website or through other websites or accounts from which you permit us to collect information;

          3.1.14     information you provide us (or our Associated or agents or representatives) through customer surveys;

          3.1.15     personal information based on your activities on the Website; or

          3.1.16     any other personal information that may be required in order to facilitate your dealings with us.

     3.2       We may collect these types of personal information either directly from you or from third parties who include, but are not limited to:

          3.2.1       travel agents or agencies that you have dealt with,

          3.2.2       persons acting on our behalf;

          3.2.3       other persons related to or affiliated with us; or

          3.2.4       your insurer (including their agents) or medical persons or practitioners that you have dealt with (this information may be disclosed to us in your best interest or in the interest of other persons or in an emergency).

     3.3       We may also collect personal information when you:   

          3.3.1       register on, or make use of, the Website;

          3.3.2       request a service, product or good from us; or

          3.3.3       communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites.

     3.4       When you provide your personal information to us to make an online booking with us (or our representatives or agents) or to request other services or products from us, your contact details may be retained even if the transaction is not completed.

     3.5       Any sensitive information that we collect from you will be subject to a higher level of privacy protection.

     3.6       We may also record both in-bound and out-bound telephone calls or collect information when you use our Live Chat feature on the Website to speak with our consultants or representatives. We do this to ensure quality of service and for training purposes.


4. Use of Personal Information

     4.1       We may collect, hold, use and disclose your personal information for the following purposes:

          4.1.1       to contact you;

          4.1.2       to conduct our business or provide you with services or products requested by you;

          4.1.3       to enable you to access and use the Website;

          4.1.4       to operate, protect, improve or optimise:

         the Website;

         our business or the business of our Associates;

         our user experience, such as to perform analytics, conduct research and for advertising and marketing.

          4.1.5       to send you service, support and administrative messages, reminders, technical notices, updates, security alerts;

          4.1.6       to send you information requested by you;

          4.1.7       to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners or Associates that we think you may find interesting;

          4.1.8       to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners or Associates;

          4.1.9       detect, investigate and prevent potentially unlawful acts or omissions, or acts or omissions with the potential to breach our terms and conditions, this Privacy Policy or other policies or arrangements between you and us;

          4.1.10     verify information for accuracy or completeness (including by way of verification with third parties);

          4.1.11     to comply with our legal obligations, resolve any disputes that we may have with any our customers or you, and enforce our agreements with you or any third parties;

          4.1.12     to manage our relationship with you, including providing you with updates about your travel arrangements, responding to your enquiries, completing reservations, dealing with complaints, contacting your nominated emergency contact in the event of an emergency;

          4.1.13     to protect you or other persons;

          4.1.14     providing relevant information, which may include sensitive personal information, to insurers, their agents and medical staff in circumstances where such persons (or Bunnik Tours) need to act on your behalf or in the interest of passengers or other persons or in a case of an emergency;

          4.1.15     for other purposes directed by you.

     4.2       We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

     4.3       Bunnik Tours or our business partners or Associates may send you direct marketing communications and information about our (of their) services and products. This may take the form of emails, SMS, mail or other forms of communication. You may opt-out of receiving marketing materials from us by contacting us using the details set out on the Website.

     4.4       By providing us with your personal information you consent to us (or any third party referred to in this Privacy Policy) using that information for the purposes referred to in the Privacy Policy.

     4.5       We may take or collect images that identify you when you travel with us or any of our Associates or third-party businesses or travel suppliers. These images may:

          4.5.1       take the form of photographs or videos or such other pictorial representation;

          4.5.2       be taken by us or any of our Associates or third-party businesses or travel suppliers;

          4.5.3       be used by us for advertisement purposes or such other purposes referred in this Privacy Policy;

          4.5.4       shared or provided by us to any of the persons referred to in clause 6.1.

     4.6       It is likely that these images will be sent overseas to the countries referred to in clause 6.2.

     4.7       By accepting our services, you authorise us to take and collect these images. Please notify us in writing by using the contact details set out in the Website if you do not wish for us to take or collect these images.


5. Accessing or correcting your personal information

     5.1       You can access the personal information we hold about you by contacting us using the information on the Website. Sometimes, we may not be able to provide you with access to all of your personal information and, where this is the case, we will tell you why. We may also need to verify your identity when you request your personal information.

     5.2       If you think that any personal information we hold about you is inaccurate, please contact us and we will take reasonable steps to ensure that it is corrected.


6. Disclosure of Personal Information

     6.1       We may disclose personal information for the purposes described in this Privacy Policy to:

          6.1.1       our employees, Associates and related persons;

          6.1.2       third party suppliers and Service Providers (including providers for the operation of our Website or our business or in connection with providing our products and services to you);

          6.1.3       contractors;

          6.1.4       professional advisers or consultants, dealers and agents;

          6.1.5       travel agents, airlines and tour companies;

          6.1.6       web hosting providers and IT systems administrators,

          6.1.7       debt collectors and payment systems operators (e.g. merchants receiving card payments);

          6.1.8       existing or potential agents, business partners or partners;

          6.1.9       sponsors or promoters of any competition;

          6.1.10     anyone to whom our assets or businesses (or any part of them) are transferred;

          6.1.11     specific third parties authorised by you to receive information held by us; or

          6.1.12     other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

     6.2       We are affiliated with a range of third party businesses and travel suppliers located overseas. It is likely that we will disclose personal information for the purposes referred to in this Privacy Policy to persons located overseas. The countries in which such persons may be located include (but are not limited to):

          6.2.1       Africa, Asia, North America, South America, Central America, the Middle East and Europe; and

          6.2.2       such other countries referred to on our Website.

     6.3       We will only disclose your personal information to overseas recipients where:

          6.3.1       It is necessary to complete the transaction or dealing that you have entered into;

          6.3.2       we believe on reasonable grounds that the overseas recipient is required to deal with your personal information; and

          6.3.3       it is otherwise permitted or required by law.

     6.4       Where you provide us with your personal information for the purposes of booking travel related services on your behalf or on behalf of another person, we may be required to provide such personal information to Service Providers you have selected or that are required for the purposes of completing a booking or providing other services or products to you. We have limited (or no) control over how Service Providers use, disclose or store personal information.

     6.5       You acknowledge and agree that we provide your personal information to Service Providers as your agent and not as the principal holder and we will not be required to ensure that Service Providers comply with applicable privacy laws, this Privacy Policy or otherwise be liable or accountable for your personal information including without limitation the Service Providers’ use and disclosure of your personal information.


7. Opting out

     7.1       We may from time to time use your personal information to identify new or existing products that we believe may be of interest to you. We may communicate this via email, SMS, mail or other forms of communication.

     7.2       You may opt out of receiving marketing, advertising and promotional notices, offers and communications from us  by clicking the unsubscribe link at the bottom of any of our emails to you or by emailing us at [email protected].


8. Using our Website and cookies

     8.1       As mentioned above, we may collect personal information about you when you use or access the Website.

     8.2       While we do not use browsing information to identify you personally, we may record certain information about your use of the Website, such as which pages you visit, the time and date of your visit and the internet protocol address assigned to your device.

     8.3       We may also use 'cookies' or other similar tracking technologies on the Website that help us track your website usage and remember your preferences and collect your personal information. Cookies are small files that store information on your computer, TV, mobile phone or other device. They enable the entity that put the cookie on your device to recognise you across different websites, services, devices and/or browsing sessions. You can disable cookies through your internet browser but the Website may not work as intended for you if you do so.

     8.4       By making use of the Website, You agree that we can place cookies on your device and accessing or making use of them when you visit the Website or otherwise in the conduct of our business.


9. Links to other websites

     9.1       The Website may contain links to third party websites, micro-sites or analytical tools (e.g. Google) not controlled or owned by us, such as reference, review, ancillary products and services sites or websites owned by related companies.

     9.2       Links to these third party websites on the Website are provided solely for your convenience (“Third Party Websites”). We do not warrant that the representations made on these Website are true and correct nor do we warrant the accuracy or safety of these websites.

     9.3       It is your responsibility to check the policies and practices of Third Party Websites before using them. We make no representations or warranties in relation to the privacy practices of any Third Party Website.

     9.4       You acknowledge and agree that:

          9.4.1       to the extent permitted by law, we are not be liable for any loss, expense or cost suffered by you as a result of your use of Third Party Websites; and

          9.4.2       we are not responsible for the privacy policies or the content of any Third Party Website.


10. Social Sharing Features

     10.1     The Website might offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on the Website with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature.

     10.2     For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.


11. Security

     11.1     We may hold your personal information in either electronic or hard copy form.

     11.2     We take reasonable steps to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure. For example:

          11.2.1     we have extensive firewall and intruder detection systems in place to constantly monitor online traffic and financial transactions. The secure connection between your browser and our systems for transfers of private information (which includes but is not limited to financial transactions, bookings forms and survey responses) uses TLS 1.2 (SSL) encryption. This security is compatible with all modern browsers.

          11.2.2     For credit card security, all online payments are transmitted via this SSL connection. Credit card information is transmitted immediately to a payment gateway solution via an encrypted port.

However, we cannot guarantee the security of your personal information. You acknowledge that you provide us with your personal information (including financial information) at your own risk and we are not be liable for any loss, expense or cost suffered by you as a result of a person using or accessing your personal information. You acknowledge that we are not responsible for, and to the extent permitted by law, you expressly release us from and against, any liability or loss incurred or suffered by you relating to or caused by any breach of the security that we have in place to protect your personal information.


12. Making a complaint

     12.1     If you think we have breached the Privacy Act 1988 (Cth), or you wish to make a complaint about the way we have handled your personal information, you can contact us using the details set out on the Website. Please include your name, email address and telephone number and clearly describe your complaint. We will respond to you regarding your complaint within a reasonable period of time.

     12.2     If you are dissatisfied with our handling of the issue, you have the right to lodge a complaint with the Office of the Australia Information Commissioner (OAIC). Please see the website of OAIC for further details about this.


13. Further information and Contacting Us

For further information about our Privacy Policy or practices, or to access or correct your personal information, or make a complaint, please contact us using the contact details set out in the Website or via [email protected].