PRIVACY POLICY

We aim to collect personal information only if it is reasonably necessary to providing the service, product or information you have requested from us.

Personal information has the meaning given to that term in the Privacy Act, and includes information or an opinion (whether true or not) about an identified individual, or an individual who is reasonably identifiable.

In the course of providing you with products and services, we collect personal information in a variety of ways. For example, we may collect personal information about you when you:

• or your employer or company purchases and uses our products, services, or subscriptions or memberships;
• make an enquiry about our products and/or services (including through our social media channels or website);
• engage with our electronic direct mail marketing;
• subscribe to our newsletters;
• or your employer or company provides us with goods or services;
• or your employer becomes a customer, distributor, contractor or supplier of EHG;
• contact our customer support;
• visit or use our website (https://exclusiveholidaygetaways.com.au/), applications or social media channels;
• you engage with our business and its employees in the course of receiving products or services from us; and
• apply as a candidate for a position of employment with EHG,

or otherwise interact with us in your capacity as consumer, business customer, distributor, partner, supplier, contractor or other person with a business relationship with us.

In general you can assume that we collect and hold the following personal information:

• name;
• address;
• email address;
• telephone number;
• date of birth; and
• financial information, including bank account and/or credit or debit car details for the purpose of processing payments made by you.

How We Collect Personal Information

Unless it is unreasonable and impracticable to do so, we collect your personal information from you directly, including by using cookies on our website. However in some cases we will collect information about you (or third parties associated with you) from a third party such as your employer or our corporate partners. At the time of collection, or as soon as practicable afterwards, we will take reasonable steps to notify you of the collection and of any matters relevant to the collection.

In some cases we will be required or authorised by Australian law, including or the order of a court or tribunal, to collect personal information about you.

Naturally we collect and hold a broad range of personal information gathered during the course of providing our products or services. However as stated above, we strive to ensure that we collect and hold only that personal information which is relevant and necessary to your specific matters.

How We Use Cookies

We may use cookies on some areas of our website. A cookie is a small file saved on your computer’s hard drive when you first visit our website. When you return to our website, the data saved in the cookie is sent back to the website. We use cookies to make your visit to our website easier by identifying you when you come back to our website and remembering your username and preferences. We may from time to time use cookies to analyse website traffic and serve relevant ads to our website visitors through third party services such as Google AdWords. These ads may appear on our website or other websites you visit. The cookies we use in no way give us access to your computer or any information about you, other than the information you choose to share with us. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. Be aware this may prevent you from taking full advantage of the website.

Purposes of Collection

We collect and hold your personal information primarily to:

• provide you with the products, services and information that you request from us;
• contact you in connection with the provision of products and services, and manage our relationship with you or your organisation;
• provide you with information about EHG’s products and services; and
• suggest EHG products and services to you.

If it is reasonable to expect that we would use or disclose your personal information for purposes that are related to the primary purposes, we may also use your personal information to:

• provide customer support, including by assisting you with enquiries or complaints;
• develop and improve the services, products and communications we provide, as well as our member service and relationships;
• in connection with the sale of our products or services, for billing, shipping, warranty, service communications or account/membership management purposes, or for registration to mobile applications or websites;
• receive and deal with feedback;
• conduct product development and market research;
• promote, advertise and market any of our products and services, including by email marketing, market surveys, personalizing your experience by presenting products and offers tailored to you (such as on our sites, applications or in other communications) and
• to comply with our legal obligations (including to comply with any law or any lawful request of a law enforcement agency or government authority), resolve any disputes that we may have with any of our clients, and enforce our agreements with third parties (such as your employer).

We may otherwise use your personal information to comply with any law, and to comply with any lawful request of a law enforcement agency or government authority.

Where possible, we will provide you with a choice to opt out of certain marketing communications. We will respect your request to decide whether or not to receive these marketing communications.

Direct Marketing

We may use your name, email address and telephone number for direct marketing purposes. Where possible, we will provide you with a choice to opt-out of any of our marketing communications. We will respect your request to decline to receive these marketing communications.

Third Parties

We may disclose your personal information to the following third parties for the purpose of enabling us to provide our products and services to you:

• Corporate partners providing goods and/or services to EHG members through EHG;
• IT technicians who may need access when providing on-site support (although it is. our practice for them to work under supervision);
• file storage service providers; and
• EHG’s charity partners.

These third parties will be permitted to access only the personal information they need to deliver the service to EHG or to you. EHG takes reasonable steps to ensure that these organisations are bound by confidentiality and privacy obligations in relation to the protection of your personal information.

We are not likely to disclose information to overseas recipients unless it is with your consent, or the disclosure is required or authorised by law.

We will not otherwise disclose information about you unless:

• the disclosure is required or authorised by law; or
• you have consented to our disclosing the information about you.

The privacy and collection practices of entities to whom we disclose personal information are governed by their own privacy policies and collection notices.

Personal Information Quality

We aim to ensure that your personal information is accurate, complete and up-to-date. To assist us in this, you need to provide true, accurate, current and complete information about yourself as requested and properly update the information supplied to us to keep it true, accurate, current and complete.

If you believe that the information is inaccurate or incomplete, please contact us and we will use all reasonable effort to correct the information.

In the event that we do not believe the information to be incorrect, we will take reasonable steps to add a statement to the information claiming that you believe the information is not accurate, complete or up-to-date.

Securing Your Personal Information

We are committed to keeping your information secure and will take reasonable steps to protect the personal information we hold from misuse, loss and unauthorised access, modification or disclosure. We will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer needed.

We have the following security measures in place to protect your information:

• our offices are securely locked after hours;
• all computers have password protection and virus protection;
• our office are monitored regularly by a security service; and
• our website is protected by a firewall.

Accessing and Correcting Your Personal Information

You may request access to, or correction of, all personal information that we hold about you, subject to any exceptions allowed by law. We will give you access to, or correct, your personal information unless there is a lawful reason for refusing your request for access or correction. If we refuse your request we will give you a written notice explaining our reasons for that refusal and details of the relevant complaints procedure.

Changes to this Privacy Policy

This Privacy Policy is not a static document. We reserve the rights to make changes to this Privacy Policy from time to time for any reason. We will publish any updated Privacy Policy on our website.

Change in control of EHG

If we sell or otherwise transfer part or the whole of EHG or our assets to another organisation (including in the course of a transaction like a sale, merger or acquisition, or as part of a dissolution, liquidation, administration, receivership or other form of insolvency), you agree that your personal information that is collected by EHG may be disclosed to a third party, prospective buyer, transferee or insolvency practitioner, and that this is reasonable to enable that party to continue or manage the business.

Complaints

If you have a complaint about our collection, use or disclosure of your personal information, or you wish to make a complaint about a breach of the Australian Privacy Principles, please contact our Privacy Officer using the information set out below.

When contacting the Privacy Officer, please set out details of your complaint and your contact details. Our Privacy Officer will contact you to acknowledge your request and ask for any other applicable information. Our Privacy Officer will then investigate the issue and advise you in writing of the outcome.

You can also make a complaint to the Office of the Australian Information Commissioner. Further information is available at www.oaic.gov.au.

Contacting Us

If you would like further information regarding this Privacy Policy, or if you have concerns about the information that we currently hold about you or any aspect of this Privacy Policy, please contact the Privacy Officer at: