This Privacy Policy has been published to provide a clear and concise outline of how and when personal information is collected, disclosed, used, stored and otherwise handled by Smart Trips Pty Ltd under licence from Smart Trips Pty Ltd (A.C.N. 608 269 521) (“Smart Trip”, “we, “us”, “our” and other parts of speech denoting SmartTrips) in connection with the application and associated services.
The SmartTrips Service is a software application that stores personal travel documents and itineraries for your convenience.
We abide by the Privacy Act 1988 (Cth), in relation to disclosure, use and storage of personal information.
Open and Transparent Management of Personal Information
We will collect personal information of a kind reasonably necessary to provide the Smart Trips Service to you. That information may include information to establish your identity, those of your family and colleagues and correlate that personal information to public and private sources of information regarding travel, travel preferences, commercial and government databases regarding visa and other travel requirements.
The information is collected by us because of your input and may then be checked against information provided by government, governmental authorities and other agencies to which the Australian Privacy Principles apply.
Anonymity and Pseudonymity
If you have used or wish to use a name other than your own name about us, it must match the details about your credit card number, Australian Business number or equivalent taxation registration details, and all other details which you may be required to divulge your identity required by law.
The establishment and verification of individual identity is essential to the security of travellers and other citizens. As travel agents, we may be obliged to verify every user’s personal identity and sensitive personal information. As such, that information, and process of identification and verification are governed by this Privacy Policy
Examples of situations where your name may not match these details include the use of English names in place of other names, nicknames, patronymics or other family or personal names. Where your name has changed by marriage or by Deed Poll or, in the case of a corporation, the name has been changed, we may require evidence of both the former name, the circumstances of the change of name and evidence of official recognition of the change.
Collection of Personal Information
Personal information is information or details provided about an individual's or entity's identity. The nature of personal information collected by us generally but not exclusively comprises an individual's or entity's name and contact details (including address, phone, postal address and e-mail) as would be shown on a person’s driver's licence, passport or other forms of identification.
We do not verify any information which may be required by any travel or government bodies for any identity check. As part of the provision of the My Trips Service, we will collect personal information required for the purposes of the transaction. We will only collect and check personal information by lawful and fair means.
Such personal information is collected for the purposes of:
verifying the identity of our users and customers to ensure that our services are not used about and to perpetuate any fraudulent, misleading or deceptive conduct;
completing any legal documentation required to for travel or visa applications;
facilitating the provision of services by approved third parties as requested by the individual or entity.
collecting and storing information about your visits to our Websites, including viewed pages and links, and every other action undertaken on our website. We also collect the information that your browser will send to our website such as IP address, browser type, browser language, access times, and referring website addresses.
collecting information about our visitors’ age, gender, and general interests principally by way of Google Analytics Demographics and Interest Reporting. This data is used solely for internal marketing purposes and is never shared with any third party. The information gathered enables us to improve our services through better targeting of the specific needs of our core audiences. As a visitor to our site, you can choose not to share this data by opting-out of Google Analytics. You may do so by installing the Google Analytics opt-out Browser add-on.
using browser “cookies”. A "cookie" is a small piece of information that our websites may send to your computer when you visit our Websites. Cookies may be used for a variety of purposes such as storing user id number and password so that our Websites remember who you are when you return and therefore permit you to regain access to areas that are limited to registered users. By adjusting your browser settings, you can be alerted every time a cookie is sent to your computer or you can "turn off" all cookies.
We may also collect other types of personal information from time to time and will inform you upon collecting such information the purpose for which it is being collected.
We will keep personal information for if it is required for providing the SmartTrips Service and complying with legal obligations to keep such personal information. These obligations include compliance with both state and federal legislation, the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 and the Financial Transaction Reports Act 1988. When we no longer require personal information, we will delete it or de-identify it.
We will generally collect personal information from the individual or entity directly when that individual or entity completes an online registration form and sends their identity verification materials (including certified copies of any identification documents provided) to us to finalise user registration.
We will only collect and check personal information by lawful and fair means.
We will only collect personal information from you or from your legal representative or an agent you appoint or who is authorized by you to operate your login. We reserve the right to check the personal information you provide against databases and with agencies authorized by Australian law to collect and share personal information.
Unsolicited Personal Information
If we receive personal information and we did not solicit the information, we will determine within a reasonable time whether we could have collected the information under the terms of paragraph 3.
We may use or disclose the information for the purposes of making the determination under sub- clause 4.1.
If we determine that we could not have collected the personal information under paragraph 3 and the information is not contained in a Commonwealth record, we will, as soon as is practicable but only if it is lawful and reasonable to do so destroy the information or ensure that the information is de-identified.
If sub-clause 3. does not apply, then we will nevertheless continue to protect the information in accord with this Privacy Policy.
Notification of the Collection of Personal Information
The entity which collects the personal information is Smart Trips Pty Ltd (A.C.N. 608 269 521). Smart Trips is a company registered under the laws of Australia having its office in Melbourne, Australia. All enquiries should be directed to info@smarttrips.com.au
We may obtain personal information from third parties including government agencies and private information service providers. We may (but are not obliged to) require those third parties to observe the privacy principles laid down by the Privacy Act 1988 (Cth).
The personal information that is collected from users of the SmartTrips Service may be required by the law of Australian States and Territories to ensure the security and validity of transactions and the movement of individuals across borders.
The main purpose of collecting personal information is to collate and organize travel documentation including information required for visa or other entry requirements to other countries and to obtain and provide accurate information to any relevant third party service providers for the purposes undertaking travel nationally and internationally.
We may decline to provide the service to persons who are unable or unwilling to provide accurate personal information.
We accordingly may divulge this personal information to other entities which apply the Australian Privacy Principles for the purposes referred to in paragraph 5.4;
See section 14 below for the methods of notifying us with regard to access to information collected and error correction;
Rights of access to check and, if necessary, correct your personal information are set out in clauses 13 and 14 below;
Use &. Disclosure of Personal Information
We will use and disclose your personal information for the purpose for which the personal information was initially collected.
We may also use that personal information for a purpose related to the initial purpose of collection if that other purpose would be within your reasonable expectations. Related purposes might include for example consumer research, cross promotions and such, adding your name to a contact list, guest list or invitation list which may be of benefit or interest to you.
We will only disclose your sensitive personal information for another purpose if it is directly related to the primary purpose for which it is collected. We will not disclose your sensitive personal information for a secondary purpose that is not directly related to the primary purposes without first obtaining your express consent.
We may however be required to disclose your sensitive personal information without your consent if the disclosure is:
required or authorised by law;
required in order to investigate an alleged unlawful activity;
required by an enforcement body for investigative activities; or
based on our reasonable belief that the use or disclosure is necessary to lessen or prevent a serious threat to the life, health or safety of any individual, or to public health or safety; or
any other permitted general situation as defined in the Privacy Act 1988 (Cth).
Where we use, or disclose information under paragraph (c), we will make a written note of the use or disclosure.
The information is collected by us as a result of your input and may then be checked against information provided by government, governmental authorities and other agencies to which the Australian Privacy Principles apply.
Disclosures may be made if the business is sold or otherwise subject to a change in control.
Information may be disclosed to people or companies we employ or who are our agents. We contract with such people or companies to protect your information in a manner consistent with this Privacy Policy, specifically not to use it except in performing services for us.
Information you disclose to third parties that you may have contacted through links on the Smart Trips Service or through other access enabled through the Smart Trips Service are subject to the Privacy
Policies of those third parties and you agree that such third-party privacy policies will govern your relationship with those third parties and we are relieved of any liability as to information supplied to third parties, even if it is done through initial contacts through the site or through continuing communication through the SmartTrips Service. The governing determination shall be made by reference to who is paid for the service. If you pay us for the services or products our privacy policy governs, then you pay the third party for the services or products their privacy policy governs.
Direct marketing
From time to time we may use your personal information to identify offerings or special events which may be of interest to the individual available through us or its business partners.
Like most business organisations, we rely on third party suppliers who are contracted to conduct specialised activities such as finance transactions, marketing, research, and such. While personal information may be provided to these suppliers in order to enable them to perform the agreed tasks, we will make every effort to ensure that the supplier handles the personal information in accordance with the Privacy Act 1988 (Cth), this Privacy Policy and confidentiality principles. We will use its reasonable endeavours to ensure all such suppliers comply with this privacy policy.
If you receive e-mails from us such as newsletters or other mailings, we may use "Web beacons" (these are small pieces of data embedded on the pages of websites), customized links or similar technologies to determine whether the e-mail we sent has been opened and which links you click. We may combine the information we collect about you from one Website or service with others, including information from other companies. All of this is done to better design our services for your benefit, and to afford you a more efficient, consistent and personalized experience in your interactions with our Websites.
If you do not wish to receive direct marketing information, please let us know. We will take immediate steps to ensure that you do not receive any direct marketing information in future.
Cross-border Disclosure of Personal Information
We will not disclose your personal information to overseas recipients without your express consent or unless you are an overseas recipient yourself.
The only circumstances in which your personal information will be disclosed to overseas recipients will be in situations where those recipients themselves have agreed to the terms and conditions of entry to the site, including acceptance of our Privacy Policy or it is required by the law of that overseas country.
Adoption, Use or Disclosure of Government Related Identifiers
We will not adopt a government related identifier of an individual as its own identifier of the individual unless it is required or authorized by an Australian law or a court order or otherwise authorized under paragraphs 9.2 or 9.3 of the Australian Privacy Principles.
Personal Information Quality
Our objective is to ensure that all personal information collected by us is accurate, complete and up-to- date. To assist us in achieving our objective, please contact us if any of your details change. Further, if you believe that the information we hold is not accurate, complete or up-to-date, please contact us in order to have the information corrected.
Personal Information Security
We are committed to keeping your personal information secure, and we will take all reasonable precautions to protect your personal information from unauthorised access, loss, misuse or alteration.
Your personal information may be stored in hard copy documents, or electronically on our software or systems used by us.
We maintain computer and network security using passwords to control and restrict access to authorised staff for approved purposes. Where information is particularly sensitive, the information is overwritten and then manually deleted.
Our employees are trained to safeguard your private information.
Customer data is not necessarily encrypted but only authorized employees are permitted to view your data.
Our employees are given access to your data only on a "need to know" basis and all employees have signed written employment agreements requiring them to maintain the confidentiality of our and customer data.
Our employees undergo a background check before hiring.
Our facilities are secured by various protective devices and systems.
Access to Personal Information
You may request access to the personal information we hold about you. The procedure for gaining access is as follows:
In some circumstances, we may not be in a position to provide access. Such circumstances include where:
If we deny access to your personal information, we will provide you with reasons in writing. The reasons for the refusal may include an explanation for the commercially sensitive decision-making process.
All requests for access to your personal information must be made in writing or by email and addressed to
You must provide as much detail as possible regarding your request.
We will acknowledge your request within 14 days, and access will usually be granted within 14 days, or if it is more complicated, 30 days. We will inform you if this timeframe is not achievable.
You will be asked to verify your identity.
A fee may apply to such access in the event that a request for access is onerous or time consuming. Such a fee will cover staff costs involved in locating and collating information, and reproduction costs.
Depending on the circumstances, you may be forwarded the information by mail or email, or you may be required to personally inspect your records at the appropriate place.
You will be given the opportunity to correct any personal information which is no longer accurate.
access would create a serious threat to safety;
providing access will have an unreasonable impact upon the privacy of other individuals;
denying access is required or authorised by law;
the request is frivolous;
legal proceedings are under way;
negotiations may be prejudiced by such access; or
access would reveal a commercially sensitive decision-making process.
Your Responsibilities to Protect Your Information
If you wish to send us secure online communication, please click here.
You agree that you will provide information about yourself that is accurate, current and complete.Information that is not accurate may not be subject to privacy protection.
You have the responsibility to protect your personal information, particularly in the context of use of the Websites, to protect your user ID, password and any other confidential access codes. We do not have responsibility for your actions in failing to protect your user ID, password or any other confidential access codes. In the event, you think your user ID, password or any other confidential access codes has been disclosed to others, please notify us at info@smarttrips.com.au
You must maintain the confidentiality of what you submit to us so that no one else may gain access to your account. Make sure you click on the "sign out" button. You must notify us of any theft of your personal data as soon as you become aware that there might have been a loss (within 2 days).
1We have no liability for problems created by your actions as described in this clause.
Correction
If we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out of date, incomplete, irrelevant or misleading or you request us to correct the information, we will take such steps as are reasonable in the circumstances to ensure that, having regard to the purpose for which it is held, the information is up-to-date, complete, relevant and not misleading.
If we correct personal information about you that you previously disclosed to another entity that must abide by Australian Privacy Principles, then we will take such steps as are reasonable in the circumstances to notify the other entity unless it is impractical or unlawful to do so.
If we refuse to correct your personal information as requested by you, we will give you a written notice which sets out:
The reasons for the refusal except to the extent it would be unreasonable to do so; and
The mechanism available to complain about the refusal; and
Any other matter prescribed by the Privacy Regulations.
If we refuse your request to correct your personal information and you request us to associate with the information a statement that the information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take such steps as are reasonable in the circumstances to associate the statement in such a way that will make the statement apparent to users of the information.
Complaints
If you believe that your privacy has been infringed, you are entitled to complain. All complaints should initially be in writing and directed to info@smarttrips.com.au we will respond to your complaint as soon as possible, within 14 working days, to let you know who is responsible for managing your query. We will try to resolve the complaint within 30 working days. When this is not possible we will contact you to provide an estimate of how long it will take to handle the complaint.
If you believe we have not adequately dealt with your complaint, you may complain to the Australian Information Commissioner whose contact details are as follows:
Officer of the Australian Information Commissioner Level 3, 175 Pitt Street, Sydney, NSW 2000
Postal Address: GPO Box 5218 Sydney NSW 2001 Or GPO Box 2999 Canberra ACT 2601
Telephone: 1300 363 992
Email: enquiries@oaic.gov.au Web: http://www.oaic.gov.au/
Changes to This Policy
We reserve the right to change this Privacy Policy at any time, subject to applicable law. If we make a material change to its privacy policies, including a material change in the way we disclose your information or a material change of policy due to a sale or transfer or our business, we will notify you at least 30 days prior to the effective date of such a change. We will notify you by using one of the following methods:
we will post a notice on the Websites at portjacksonpress.com.au describing the change; or
we will send you an e-mail at the last e-mail address you have given us, notifying you of the change. You may also have additional rights under state or federal law in the event of a change in our privacy policy.