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 application process.
3. We may, in connection with the application process, 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
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 transaction with us. For example, we may collect details such as your name, residential address, mailing address, telephone number, email address, financial information and credit/debit card details (including card type, card number, security number and expiry date).
7. When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. 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 services and 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, 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. 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 facilitate our transaction with you and to maintain our relationship with you, including in regard to future opportunities.
13. If you contact us regarding a transaction and you decide not to proceed, we may keep your details on file to let you know about future opportunities.
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. 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. Hamilton Island Enterprises Limited may disclose your personal information to overseas third party recipients.
16. 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?
17. 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 or had a transaction with us, you may have to re-enter or re-supply your personal information to us.
18. 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.
19. 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.
20. We will generally need to know who you are in order to facilitate the transaction. 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.
21. 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.
22. 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. Our privacy policy in relation to guests is available at https://www.hamiltonisland.com.au/privacy-policy.
What is I don't want to recieve advertising materials?
23. 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.
24. 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.
25. 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.
26. This Cookie Policy explains how Hamilton Island Enterprises Limited, uses cookies on our websites . Our websites are designed to make it easy for you to find out about us. To do this we use Cookies and other Technologies (such as "pixel tags," "web beacons," "clear GIFs", links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies). The term “cookie” is used throughout this Policy to cover all of these technologies, but we will also provide you with clear details about them all so that you can make informed choices about your cookie settings.
What are cookies?
27. A cookie is a small text file that a website saves on your computer or mobile device when you visit the site. It enables the website to remember your actions and preferences such as login, language, and display preferences. Cookies also allow us and third parties to obtain information about your visits to a Site. We use this information to process your requests and analyse your visiting patterns. This information assists us and others to deliver online and mobile advertisements, messages and content that are specific to your interests. You can find more information about cookies at: www.allaboutcookies.org.
How do we use cookies?
28. We use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer for a period of up to one year of inactivity. The following sets out how we use different categories of cookies and your options for managing cookies’ settings:
| Performance/ Analytics Cookies |
These cookies collect information about your use of our Site and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach our Site, and measure the effectiveness of advertising (including emails we send to you). These cookies do not collect information that individually identifies a Visitor. All information these cookies collect is aggregated and therefore anonymous. We predominantly use Google Analytics as our analytics service provider. Google, Inc (“Google”), will place cookies on your computer’s browser. The information generated by the cookies about your use of our website is transmitted to Google. This information is then used for the compiling of statistical reports. 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’ Privacy Policy, please visit: https://policies.google.com/privacy https://tools.google.com/dlpage/gaoptout
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| Functionality cookies |
These cookies allow our website to remember choices you make (language or the region you are in) and provide enhanced and more personal features so you don’t have to keep selecting your preferences every time you visit our website. The information these cookies collect is usually anonymised and they cannot track your browsing activity on other websites. Some Functional Cookies are essential to viewing maps or videos on our Site.
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| Targeting or Advertising cookies |
From time to time, we engage third parties to track and analyse usage and volume statistical information from individuals who visit our Sites. We sometime use cookies delivered by third parties to track the performance of Hamilton Island advertisements. For example, these cookies remember which browsers have visited our Sites. We also use third-party advertising networks (for Behavioural Marketing or Interest based advertising) that collect IP addresses and other information from web beacons (see below) on our Sites, from emails, and on third-party websites. Ad networks follow your online activities over time and across different sites or other online services by collecting Website Navigational Information through automated means, including through the use of cookies. This information enables you to be grouped with other people of similar interests and places you in a "market segment". We may then display advertisements on our sites which we believe people in your market segment will find relevant. We consider that this makes the advertising more interesting and useful to you, and also helps us increase the value we get out of our sites and from our advertisers, and therefore ultimately gives us a greater ability to invest in great content for the benefit of all our users. It is important to note that at no time will we or our service providers attempt to identify you individually, and at no time do we know who you are or what pages you individually have been looking at - we simply aggregate the relevant information to create the market segments of groups of people. We will at all times seek to comply with the regulatory framework applicable to onsite behavioural targeting technology in our implementation of it. The main networks used by us are as follows and you may manage your cookie and advertising targeting preferences with these networks directly:
Google - https://adssettings.google.com/u/0/authenticated,
Facebook -https://www.facebook.com/help/568137493302217
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| Third Party |
Third parties, including Meta, may use cookies, web beacons, and other storage technologies to collect or receive information from your websites and elsewhere on the Internet and use that information to provide measurement services, target and deliver ads. Other Technologies may be used for the same purposes as our Cookies, to allow us and third parties to know when you visit the Site, and to understand how you interact with emails or advertisements. Through Other Technologies, non-personal information (e.g., your operating system, your browser version, and the URL you came from) or aggregate information may be obtained and used to enhance your experience and understand traffic patterns.
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Links to Other Websites
29. To enhance your experience, our Sites may include links to other, unaffiliated sites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We have no responsibility for the content, privacy and security practices, and policies of third-party sites or services to which links or access are provided through the Service. We encourage you to read the privacy policies or statements of the other websites you visit.
Social Media Features
30. Our sites may use social media features, such as the Facebook ‘like’ button (“Social Media Features”). These features may collect your IP address and which page you are visiting on our Sites and may set a cookie to enable the feature to function properly. You may be given the option by such Social Media Features to post information about your activities on our Sites to your profile page that is provided by a third party social media network. Social Media Features are either hosted by a third party or hosted directly on our Sites. Your interactions with these features are governed by the privacy policy of the company providing the relevant Social Media Features. Most Social Media Sharing functionality on our Website in operated by the AddThis widget. You can opt out here.
How to control cookies
Performance or Functionality cookies
31. Most web browsers are set to accept cookies, but you can always change your computer settings to stop them. We are not responsible for your browser settings. You can control and/or delete cookies as you wish at any time. For details, see aboutcookies.org or follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note that if you disable your web browser’s ability to accept cookies, you may have to manually adjust some preferences every time you visit a site and you may not be able to use all the features of the our websites or perform certain transactions.
Analytics
32. 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/.
Targeting, Advertising and Behavioural Marketing
33. Certain targeted advertisements that we (or a service provider acting on our behalf) display to you based on information about your online activities across websites and other interactive properties operated by third parties may include the “Ad Choices” icon or another mechanism to opt out of receiving interest-based advertisements. You may click on the AdChoices icon or visit www.aboutads.info to receive more information about the collection and use of information about your online activities for interest based advertising or to learn how to opt out of having your data used for interest based advertising by Digital Advertising Alliance (DAA) participating companies.
- The Network Advertising Initiative’s (NAI) Opt-Out Tool at www.networkadvertising.org/choices allows you to opt out from the use of information about your online activities for interest based advertising by NAI member companies.
- European users can also visit www.youronlinechoices.com to learn how to opt out of having their data used for interest-based advertising by European Interactive Digital Advertising Alliance (EDAA) member companies.
Alternatively, you can visit the following sites to opt-out of the main Ad networks used on Hamilton Island Websites: Google Click Here to Opt Out Quantcast Click Here to Opt Out Meta (Facebook and Instagram) Click Here to Opt Out
Mobile Identifiers
34. On your mobile device, your operating system may provide you with additional options to opt out of interest based advertising or to otherwise reset your mobile identifiers. For example, you may use the “Limit Ad Tracking” setting (on iOS devices) or a setting to “Opt out of Interest-Based Ads” (on Android) which allows you to limit the use of information about your use of apps for purposes of serving ads targeted to your interests.
Further Information
35. Please contact privacy@hamiltonisland.com.au if you would like more information on the cookies that we use and their purposes.
36. 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.
37. This may include storage on our behalf by third party service providers, including overseas third party service providers. See our comments below about how we protect your information.
How do we protect personal information?
38. 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.
39. 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.
40. 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.
41. 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:
- Server authentication: the web server sends a digital certificate to your computer so that you can be sure of its identity (and know that the transaction is protected - you'll see a lock symbol on the bottom right of the browser window).
- Client authentication: your computer authenticates itself to the server by showing its digital signature.
- Encryption: during the internet connection, data that's transferred from your computer to the server is scrambled, so that only your computer and the server can understand the contents of the transaction. This prevents other internet users from intercepting the information sent.
42. See our comments above regarding the websites of third parties including those that are linked to our websites.
43. 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.
44. Your request to provide access to this information will be dealt with within a reasonable time.
45. 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.
46. 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.
47. 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.
48. 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.
49. 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
50. 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 2 May 2023
1.For the purposes of this Privacy Policy, "Hamilton Island Enterprises Limited", "we", ‘our” or “us” means Hamilton Island Enterprises 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 Reef View Hotel, Beach Club, Palm Bungalows, Hamilton Island Holiday Homes, Hamilton Island Golf Club, Hamilton Island Yacht Club and Hamilton Island Race Week.
2. Our website”, “our site” or “our sites” refers to www.hamiltonisland.com.au, www.bookings.hamiltonisland.com.au, www.hamiltonislandholidayhomes.com.au, www.hamiltonislandrealestate.com.au, www.qualia.com.au, www.hamiltonislandgolfclub.com.au, www.hamiltonislandraceweek.com.au ↩