Scope

In this Privacy Policy (Policy), Complex Travel Group (we, us) means Complex Travel Group Pty Ltd and its related businesses RoundAbout Travel, Flat Beds, QFlyer, Y Premium and Onboard Luxury. This Policy explains how we will handle and protect your personal information. It also explains how you may request to access and correct your personal information, how to make a privacy complaint and how we will handle complaints. We recommend that you review this Policy regularly as we may amend it from time to time to meet our legal obligations, reflect our current practices and ensure we are transparent about our information management. By continuing to deal with us, you accept this Policy as it applies from time to time. Complex Travel Group operates from Australia and this Policy provides information in accordance with our obligations under the Privacy Act. By providing personal information to us, either directly or allowing another person to do so on your behalf, you acknowledge that this Policy will apply to how we handle your personal information. If you do not wish your personal information to be handled in accordance with this Policy, we recommend that you do not provide your personal information to us. If you do not provide us with all the personal information we request, or if you do not provide any consent we require to be authorised to collect and handle certain personal information, this may affect our ability to provide services to you or respond to your inquiry, request or complaint.

What Personal Information do we collect and how?

The personal information we usually collect about you includes your name, home address, telephone number, email address, credit and debit card details, details of your flight or holiday, passport details, other travel details and any special needs you may have. We may from time to time monitor and review any information transmitted or received through our websites, or through telephone or e-mail communications. During monitoring, the information may be examined, recorded or copied. We will tell you when you telephone us, or if we call you if we will record the call. Please advise us if you don’t want the call to be recorded. When you access our websites, use any of our mobile applications or open an electronic communication from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet. Alone, IP addresses are not personal information, but we may link IP addresses to other personal information we hold about you and use it for the purpose of fraud prevention and protection. In some circumstances we may need to collect personal information that is sensitive information. We will normally only collect your sensitive information with your consent and where it is required for your travel arrangements such as allergies, disabilities that require special arrangements or in the event of an accident. We collect your personal information directly from you in the course of providing a product or service or when you otherwise deal with us. For example, your personal information will be collected when you deal with us over the telephone, send us a letter or an email, visit our websites or use our mobile applications, complete an online registration or enquiry form, provide information to complete a booking or subscribe to a service provided by us or register as a member, or participate in one of our surveys, competitions or promotions. We may also collect your personal information from others who make a booking on your behalf and they should be authorised to provide us nwith your information. Please see the section titled ‘Cookies‘ for further information about what data we collect through our use of cookies, analytics and other technologies and for what purposes.

For what purposes do we collect your personal information?

We collect your personal information for the following purposes in relation to providing you with our travel services and advice and to assist you with booking travel and travel related products and services:

1. Complete your travel bookings;
2. Provide you with travel products, services and advice;
3. Consider your request for a product or service;
4. Provide you with information about other products and services that may be of interest to you including information about our business partners’ products and services. Please see the section titled ‘Direct Marketing and your Privacy‘ for further information about receiving direct marketing;
5. Assist in arrangements and reservations with suppliers (such as airlines, tour operators, cruise operators, car hire operators, hotels and insurance providers) in relation to the provision of a product or service;
6. Collect and process payments, though us or a third party;
7. Perform all other administrative and operational tasks (including operational reporting, risk management, systems development and testing, staff training, and market or customer satisfaction research);
8. Facilitate your participation in loyalty programs;
9. For quality assurance and other purposes and so that we can censor, edit, remove or prohibit the transmission or receipt of any information communicated through our systems that we deem inappropriate or in violation of our terms and conditions;
10. Register you as a client or member;
11. Complete a travel profile about you;
12. Enable you to, participate in a survey, competition or promotion,
13. Process a transaction through our websites, over the phone, via email, through a mobile application or one of our agents;
14. Analyse how our products and services (including any websites) are used and understand the effectiveness of our communications;
15. Personalise the service or communication we provide to you, tailor your experience on our website or other websites to your interests and make more appropriate travel recommendations;
16. Investigate, detect and protect us and other third parties against, negligence, breach of contract, fraud, theft and other illegal activities; and
17. Respond to and manage inquiries, complaints, feedback and claims.

When do we disclose your personal information? 

We may disclose your personal information for the above purposes to:

1. suppliers of products or services which you have selected (such as airlines, tour operators, cruise operations, car hire operators, hotels and insurance providers);
2. third party travel service providers who assist in fulfilling the booking you have made;
3. a person making your travel booking on your behalf;
4. third party sponsors or co-sponsors of promotions on our website. Only information collected during a promotion will be disclosed to these parties;
5. other Complex Travel Group entities;
6. government authorities and our insurers in the event of an accident, disaster or emergency; and
7. Complex Travel Group’s contractors, suppliers and service providers, including:
   • suppliers of IT based solutions that assist us in providing products and services to you, such as any external data hosting provider(s) we use;
   • publishers, printers and distributors of marketing material;
   • travel analytics and reporting;
   • event and expo organisers;
   • marketing, market research, research and analysis and communications agencies;
   • mailing houses, freight services, courier services; and
   • external business advisers (such as lawyers, accountants, auditors and recruitment consultants); and
   • others where we are authorised or required by law or have your consent to do so.

Given the nature of our travel products and services some of the third parties we may disclose your personal information to, to facilitate your travel booking and/or to enable the performance of administrative and technical services by them on our behalf, may be located overseas.  In the event that we or a part of our business undergo re-organisation or are sold or licensed to a third party, any personal information we hold about you may be transferred to that re-organised entity, licensee or third party.

Websites, Apps and Systems

We operate a number of websites, mobile applications and systems (our sites). Please see the section titled ‘Cookies’ for further information about what data we collect through our use of cookies, analytics and other technologies and for what purposes.

Cookies

Our sites rely on cookies to provide a number of services to you. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently to improve the user experience, as well as to provide certain information to the owners of the site including in relation to what ads to show you. They enable us to recognise your browser next time you visit our sites. If you do not wish to use cookies, you can adjust your browser settings to reject cookies or notify you when they are being used. You may opt-out of certain Session Data being collected while you are using a mobile device by clicking here. If you have not chosen to reject cookies, when you access our sites, we will place cookies, pixels or other code on your computer to collect information about your usage of our sites and information about the device you are using. The collection of this data helps us recognise you when you visit our sites again and helps us better understand how our sites are used. This information allows us to improve our sites content and navigation. We may use service providers to collect this data on our behalf. Unless you specifically inform us of your details we will not know who you are. Our sites set cookies which remain on your computer for differing times. Some expire at the end of each session and some remain for longer so that when you return to our sites, you will have a better user experience. When using our sites, you may search for products and services in the area in which you are located. If you choose to do so, depending on the mobile device or application you are using, we may collect your geo-location information to search for the applicable products and services or to personalise and improve your individual viewing experiences on our sites and provide information that may be of interest to you. You may at any time disable our collection and use of your location information by turning location services off at the device level. When you visit certain sections of our sites, Google Analytics, a site 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 our sites 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 sites and its 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 sites. 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 click here and for details of Google Analytics’ Privacy Policy, please click here. You may choose to opt-out of Google Analytics using the Google Analytics Opt-out Browser Add-on which you may access here.

Storage and Security of Personal Information 

We store personal information in a combination of secure computer storage facilities, paper based facilities and other records. We take reasonable steps to maintain the security of the information we store in our systems or in physical records. We use a combination of security measures to prevent the unauthorised access of our servers and regularly review our security policies. Your personal information will be stored in secured locations and on servers controlled by us or one of our service providers, located either at our offices or at the offices of our service providers.

Accessing and Updating your Personal Information 

You may ask us for access to any personal information we hold about you, subject to some exceptions in the Privacy Act. You can also ask us to correct personal information that we hold about you. You can contact our Privacy Officer using the details in the section titled ‘Contact our Privacy Officer‘ below to request access to or correction of the personal information we hold about you. We will need to verify your identity before responding to your request. We may charge a reasonable fee for providing your personal information. However, we will not charge for the making of the request. If we refuse access to all of some of the personal information you request or to correct your information, we will write to you and explain why and how you can complain.

Direct Marketing and your Privacy

Serving customers well is very important to us. As part of this service, we may use your personal information to identify a product or service that you may be interested in. We may with your consent where required by applicable law, use the contact details you have provided to contact you from time to time whether by phone, email, SMS or post to tell you about new or exciting products or services and special offers that we believe may be of interest to you, including information about our business partners’ products and services. You can opt-out of receiving direct marketing communications from us, including communications from us on behalf of our business partners at any time by contacting our Privacy Officer using the details in the section titled ‘Contact our Privacy Officer‘ below, or by using the unsubscribe facility in the electronic communication you receive. You can also opt-out of this kind of advertising by clicking here. By opting out of this kind of advertising you may still receive ads from us or ads from other parties that are broadly targeted.

Privacy Complaints

If you wish to complain about our handling of your personal information, please contact our Privacy Officer using the details below. We will investigate all complaints and respond to you as soon as practicable. We will need to verify your identity. If we find a complaint justified, we will resolve it. If necessary, we will change our policies and procedures to maintain our high standards of performance, service and customer care. If your complaint is not satisfactorily resolved, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). For more information on privacy, you can contact the OAIC’s hotline service on 1300 363 992 or visit the OAIC’s website at www.oaic.gov.au.

Contact our Privacy Officer

If you have a privacy complaint or wish to correct, update or access the personal information that we hold about you, please contact our Privacy Officer using the following details:

Email: privacyofficer@complextravel.com.au

Phone: 1300 318 227

Address: Privacy Officer, Complex Travel Group Pty Ltd, Level 11, 99 Gawler Place, Adelaide SA 5000