Privacy policy

What's your Privacy Policy all about?

1. This Privacy Policy explains how Hamilton Island Enterprises Limited1 collects, holds, uses and discloses your personal information under the Australian Privacy Principles.

2. By providing personal information to us (or allowing another person to do so on your behalf), you agree that this Privacy Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Privacy Policy. If you do not agree with any part of this Privacy Policy, you must not provide your personal information to us and this may affect the products and services we can provide to you.

3. We may, in connection with particular products and services we offer or provide to you, make other privacy disclosures to you or seek your authority to use your personal information in ways which are different from or more specific than those stated in this Privacy Policy. In the event of any inconsistency between the provisions of this Privacy Policy and those other disclosures, the other disclosures will apply.

4. This Privacy Policy does not apply to our employee records.

Summary of contents

Personal information – collection, storage and how it’s used 5–19
Sensitive Information 20
Dealing with us anonymously or using a fake name 21-22
Marketing and Advertising 23-24
Third Party and Co-Branded sites 25-26
Online transactions, tracking technologies 27-39
Accessing and updating your personal information 40-43
Contacting us 44-46
Future changes 47

What is "personal information"?

5. Personal information” is information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identified individual, and any indication of intention in respect of an individual.

What personal information do we collect?

6. Generally, the type of personal information we collect about you is the information that is needed to facilitate your stay on Hamilton Island including travel arrangements, bookings and to organise the provision of related products and services on your behalf. For example, we may collect details such as your name, residential address, mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), and other details relevant to your stay or required by third parties providers (e.g. airlines, accommodation and tour providers).

7. When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback form you have sent to us. We also collect information that is required for use in the business activities of Hamilton Island Enterprises Limited, including for example, financial details necessary in order to process various transactions, and any other relevant personal information you may elect to provide to us.

8. We also collect information about how you use our products, including transaction and payment information, details of any contact you have with our staff and information regarding your internet activity (including your location) when you use our websites or online services.

How do we collect personal information?

9. We will ordinarily collect personal information about you directly from you or where it is provided to us. For example, we collect personal information directly from you through forms you fill out when contacting us, signing up for our email communication, requesting a quote, using our online chat service, entering a competition, making a booking or through your ongoing interaction with us.

10. When you call us on the telephone, we may monitor and in some cases record the telephone conversation for staff training and record-keeping purposes. Further, when we communicate with you by email or via online chat, we may keep a copy of our correspondence and use technology to identify you so that we will be in a position to know when you have opened the email or clicked on a link in the email.

11. In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. bookings by a travel agent, a family or group booking). Where this occurs, we will assume you have consented to your personal information being collected by us and to us handling it in accordance with this Privacy Policy. You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent.

Why do we collect personal information?

12. The collection, holding and use of your personal information is necessary for us to provide you with advice relating to holidaying on Hamilton Island and/or to assist you with booking accommodation on Hamilton Island, travelling to and from Hamilton Island and/or booking restaurants, activities, products and other services related to your stay on Hamilton Island including:

  • managing your reservation;
  • sending you information;
  • developing, improving and marketing our products and services;
  • servicing our relationship with you by, among other things, providing updates on promotions, products and services we think may interest you;
  • involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you;
  • for marketing activities including but not limited to mail-outs, emails, e-newsletters, SMS notifications and telephone calls;
  • responding to your questions;
  • solving your problems; and
  • verifying your identity.

13. If you contact us for a quote or information about our products and you decide not to holiday with us, we may keep your details on file to let you know about future offers.

Is personal information disclosed to third parties?

14. Yes but other than as disclosed below, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to: (i) lessen or prevent a threat to life, health or safety; (ii) for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences); (iii) disclosure is authorised or required by law; or (iv) disclosure is otherwise permitted by applicable privacy laws.

15. When we book products and services for you supplied by third parties (for example travel, accommodation, reef trips, water activities, transfers, tours), we usually do so as agent for or on behalf of those third parties. This means that we usually collect personal information about you both for our internal purposes (for example, to process your accommodation booking), and on behalf of the parties for whom we act as agent, for their internal purposes (for example, to provide the booked products and services). Accordingly, the consent you provide under this Privacy Policy to the collection and use of personal information by us (other than sensitive information), applies equally to the parties whose products and services we sell. For example, if we have booked your flight for you, then under this Privacy Policy you will have consented to your personal information being provided to the airline to enable your flight to be booked.

16. We act as agent for a number of third parties, so it is not possible for us to set out in this Privacy Policy how each of those third parties will use your personal information. If you wish to contact us for further information, please refer to the “Contact us” section below.

17. In accepting our Privacy Policy you also consent to the personal information about you which we collect or receive being processed, transferred and/or disclosed by us to third parties when we act as your agent and in the following circumstances:

  • as permitted or required by law;
  • to various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes;
  • to third party suppliers of IT based solutions that assist us in providing products and services to you;
  • to comply with a request from a qualified government department if we are satisfied that they have the authority to make such request;
  • where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter;
  • to third parties who may involve you in market research for the purpose of servicing our relationship with you and improving the products and services we provide; and
  • to third parties for the purpose of analysing trends in sales and travel destinations.

How long do you keep personal information?

18. We are only allowed to store your personal information for as long as necessary having regard to the purpose for which it was collected or a related or ancillary purpose. We may therefore delete your personal information after a reasonable period of time and, if you have not used our products and services for some time, you may have to re-enter or re-supply your personal information to us.

19. Sensitive personal information will only be kept in accordance with the conditions you consent to at the time of collection or as otherwise required by law.

Is sensitive personal information treated differently under your policy?

20. Yes. Sensitive personal information (as defined in the legislation) will only be collected directly from you. The use and disclosure of sensitive personal information will only be in accordance with the conditions you consent to at the time of collection or as otherwise required by law.

Dealing with us anonymously or using a fake name

21. We will generally need to know who you are in order to provide you with our products and services. Despite this, in some circumstances you are entitled to deal with us anonymously, or by using a pseudonym (fake name), for example when making general enquiries about the services we offer. You must tell us when you are using a pseudonym when applying for our services. If we need to identify you, we will tell you whether or not your real name is required to access those services.

22. In some circumstances, you may receive a better service or response if we know who you are. For example, we can keep you up-to-date and better understand a complaint you might have if we know who you are and the circumstances of your complaint.

Do you ever send me advertising materials?

23. From time to time, we may use your personal information to let you know about new developments, Hamilton Island information and special offers that may interest you. We may also let you know about products and services from our partners but we will not pass your personal information to them or sell it to third parties.

What if I don't want to receive advertising materials?

24. That's absolutely fine. Just let us know by calling us on +61 2 9433 3333 or emailing privacy@hamiltonisland.com.au. You are also able to update your preferences via an unsubscribe link that is made available to you at the base of advertising email communication.

Online links to Third Party and Co-Branded sites

25. Hamilton Island Enterprises Limited may establish relationships with business partners that allow visitors to our websites to link directly to sites operated by these partners. Some of these sites may be "co-branded" with our logo; however, these sites may not be operated or maintained by or on our behalf. These sites may collect personal information from you that may be shared with us. This Privacy Policy will apply to any personal information we obtain in this manner.

26. Despite this, we are not responsible for the content or practices of websites operated by third parties that are linked to our websites. These links are meant for the user's convenience only. Links to third party sites do not constitute sponsorship, endorsement or approval by us of the content, policies or practices of those third party sites. Once you have left our websites via such a link, you should check the applicable privacy policy of the third party site.

Tracking technologies

Cookies

27. Our websites are designed to make it easy for you to find out about our products, to apply for them and to manage your Hamilton Island experience. To do this we use cookies, which are pieces of information that a website transfers to your computer's memory or hard disk for record keeping purposes.

28. Cookies can help us make your experience of our websites more relevant, and they can also help us learn about how people use our websites (and therefore help make it better).

29. Most web browsers are set to accept cookies, but you can always change your computer settings to stop them. If you choose to do that, you may not be able to take full advantage of our online services.

Google Analytics

30. When you visit certain sections of our websites, Google Analytics, a website analytics service provided by Google, Inc (“Google”), will place cookies on your computer’s browser. The information generated by the cookies about your use of the website is transmitted to Google. This information is then used for the purpose of compiling statistical reports to enable us to measure and analyse the number of visits to our websites and pages, the average time spent on the site and the pages viewed. We will not (and will not allow any third party to) use Google Analytics to track or to collect any personal data of visitors to our websites. We will not associate any data gathered via use of cookies with any personal data from any source as part of our use of Google Analytics. For further information about Google Analytics please visit www.google.com/analytics and for details of Google Analytics’ Privacy Policy, please visit http://www.google.com/intl/en)ALL/privacypolicy.html.

31. You may choose to opt-out of Google Analytics using the Google Analytics Opt-out Browser Add-on which you may access at https://tools.google.com/dlpage/gaoptout/.

3rd Party Tracking

32. The use of tracking technologies (including cookies) by our Service Providers is not covered by our Privacy Policy. We do not have access or control over these cookies.

How do we store personal information?

33. We store your personal information in a number of ways including:

  • on secure servers;
  • in electronic systems and devices;
  • in telephone recordings;
  • in paper files; and
  • document retention services off-site.

34. This may include storage on our behalf by third party service providers. See our comments below about how we protect your information.

How do we protect personal information?

35. Hamilton Island Enterprises Limited has implemented various physical, electronic and managerial security procedures in order to protect personal information from loss and misuse, and from unauthorised access, modification, disclosure and interference.

36. If we no longer require your personal information, we will take reasonable steps to destroy or de-identify it unless we are required to keep it by law.

Are my online transactions secure?

37. Whilst we take reasonable measures, no data transmission over the Internet can be guaranteed as fully secure and accordingly, we cannot guarantee or warrant the security of any information you send to us using our online forms or products. You submit information over the Internet at your own risk.

38. With respect to online payments, we use a Secure Socket Layer (SSL), which scrambles your data to make it unreadable by third parties. It does this by:

39. See our comments above regarding the websites of third parties including those that are linked to our websites.

Can I access and if necessary correct my personal information?

40. On request, we will provide you with access to the information we hold about you, including for the purpose of correcting or updating that information, unless there is an exception which applies under the Australian Privacy Principles.

41. Your request to provide access to this information will be dealt with within a reasonable time.

42. If we refuse to provide you with access to, or correct, the information, we will notify you of our reasons for the refusal to the extent required and how you may complain about the refusal.

43. If there is a denial of access to your personal information or a dispute as to the correctness of any personal information held, we will provide you with reasons for the denial or its refusal to correct the personal information. If you disagree with our decision for the denial or refusal to correct the personal information, we will notify you of our reasons for the refusal to the extent required and how you may complain about the refusal.

Contacting us

44. We take privacy concerns seriously, and we'll work to address any problems we become aware of. If you have any further questions, concerns or wish to make a complaint about the way we manage your personal information, please call our Privacy Officer on +61 2 9433 3333 or email us at privacy@hamiltonisland.com.au.

45. We are committed to resolving any issue you may have as quickly as possible. We aim to respond to all complaints within 5 working business days; however timeframes may be longer depending on the nature of the complaint.

46. If your complaint is not resolved to your satisfaction through the internal procedures outlined above, you may elect to contact the Office of the Australian Information Commissioner (OAIC): GPO Box 5218 Sydney NSW 2001 Phone: 1300 363 992 Email: enquiries@oaic.gov.au www.oaic.gov.au

Changes to our Privacy Policy

47. From time to time it may be necessary for us to review and revise this Privacy Policy. We reserve the right to change our Privacy Policy at any time and for any reason. If we make a change to the Privacy Policy, the revised version will be posted on our websites.

Last updated December 2014.

1. For the purposes of this Privacy Policy, "Hamilton Island Enterprises Limited", "we", ‘our” or “us” means Hamilton Island Enterprises Pty Limited (ABN 61 009 946 909) and its each of its subsidiaries, related bodies corporate and business operations conducted under our brands including qualia, the Reefview Hotel, Beachclub, Palm Bungalows, Hamilton Island Holiday Homes, Hamilton Island Golf Club, Hamilton Island Yacht Club and Audi Hamilton Island Race Week.