DMT & Co Pty Ltd trading as (“Hotel Concierge”, us, we, our) is committed to the protection of personal privacy as required under the Privacy Act 1988 (Cth) (“the Privacy Act”) and has adopted a set of privacy principles based on the 10 National Privacy Principles contained in the Privacy Act.
The following policy governs the collection and use of your personal information by Hotel Concierge and its related entities, subsidiaries, contractors, employees and any staff of Hotel Concierge that will assist you. Our policy and its principles deal with and notify you of what personally information of yours is collected; how the information is used; with whom the information may be shared; what choices are available to you regarding collection, use and distribution of the information; what kind of security procedures are in place to ensure data quality and security; and how you can correct any inaccuracies in the information.
We are firmly committed to guarding the confidence you have placed in our company and to use, responsibly and professionally, any information you volunteer. We strive to collect only that information that we think is necessary for our legitimate business interests, such as to better understand you (our customer), to provide better service, to improve marketing of our products, to educate customers and to ensure that our proprietary information is protected. We are committed to using the information collected only for these purposes and for our primary purpose to broker your finance transactions with the appropriate lender and or other related institutions.
Hotel Concierge will only collect personal information that is necessary for one or more of its functions or activities. At all times the collection of information conducted by Hotel Concierge will be in a fair, lawful and non-intrusive way. Before, during or as soon practicable thereafter (if it is not possible prior), Hotel Concierge will take necessary steps in obtaining personal information from an individual and ensuring that the individual/s is aware of:
Our company identity, company details and contact details,
The ability to access their own information,
The purpose of the information collected,
The disclosure of information and related organisations to which Hotel Concierge usually discloses information to,
Any law or governing body that requires the collection of information,
And the possible outcome or consequences if the information is not provided.
In most cases personal information from an individual is collected only from that individual through the means of telephone, in person and websites. If Hotel Concierge collect personal information from other sources, Hotel Concierge will take reasonable steps to ensure the above points have been made aware to the individual.
II Use & Disclosure
Hotel Concierge will use and disclose personal information from an individual for its primary purpose unless the information collected is:
Consented by the individual,
For a secondary purpose which is related to the primary purpose,
Used for direct marketing and is not sensitive information and the individual is made aware they can ‘opt out’ of any further direct marketing,
In the specific circumstances relating to public or individual health and safety and public interest such as law enforcement, breaches of a law imposing a penalty or sanction or breaches of a prescribed law.
Personal information may also be disclosed to OTA’s (Online Travel Agents) and third party contractors for the purpose of fulfilling our housekeeping obligations and reservations booked by relevant parties.
III Data Quality
Hotel Concierge acknowledges and will take reasonable steps to ensure that the personal information it collects uses and or discloses is accurate, complete and up-to-date.
IV Data Security
Hotel Concierge will take reasonable steps to protect personal information from misuse, loss, unauthorised access, modification or disclosure.
Hotel Concierge will also take reasonable steps to destroy or permanently de-identify personal information if it is no longer required for any purpose for which the information may be used or disclosed under Principle 2.
Hotel Concierge will outline a policy document expressing information handling and management practices made available to anyone you requests it. Hotel Concierge will take reasonable steps to ensure the document outlines to the individual what sort of personal information Hotel Concierge hold, for what purposes, and how it collects, uses, holds and discloses that information.
VI Access and Correction
The personal information Hotel Concierge hold for an individual is made available for an individual to access upon request. Hotel Concierge will take reasonable steps to correct information to ensure its accuracy, it is complete and up-to-date. This service is made available to the individual and in a reasonable manner or form to suit the individual, except to the extent that:
Providing access would have an unreasonable impact on the privacy of other individuals; or
Providing access would not be lawful; or
Providing access would pose threat to the life or health of any individual.
Hotel Concierge may incur levies charges to individuals for providing access to personal information dependant on the administered work, time and involvement.
If the circumstances arise whereby an individual and Hotel Concierge disagree with the accuracy, completion and currency of personal information and the individual tender a statement claiming the information is not accurate, complete or up-to-date, Hotel Concierge will take reasonable steps to correct this. Hotel Concierge may also request the support of further documentation to support this claim.
Hotel Concierge will not adopt as its own identifier of an individual and will not use or disclose an identifier that has been assigned by an organisation to identify uniquely that person for the purposes of the organisation’s operations or a Commonwealth agency, unless:
The use of disclosure is necessary for Hotel Concierge to satisfy its obligations to the Commonwealth Government agency.
Wherever it is practicable and lawful to do so, individuals do have the option to interact anonymously when entering transactions with Hotel Concierge. Generally, however it will not be practicable and may not be conducive to the individual to provide a comprehensive analysis without requiring personal information and identification.
IX Transborder Data Flows
Hotel Concierge can and will only transfer personal information about an individual to a recipient in a foreign country if:
The individual has consented to do so; or
The transfer is required to ensure the performance of pre-contractual arrangement between the individual and Hotel Concierge; or
The recipient of the information is subject to a law, scheme or contract substantially similar to the NPP National Privacy Principles
X Sensitive Information
Hotel Concierge will not collect sensitive information unless:
The individual has consented; or
The collection of sensitive information is required by law; or
Under special circumstances related to public interest as law enforcement and public or individual health and safety.
XI Privacy Changes & New developments
XII Disclosure to Third Parties
Disclosure to Third Parties: Except as described in this Privacy Statement, Hotel Concierge uses good faith efforts not to provide third parties with access to your personally information. We will, however, make your personally information available to others:
When we have your consent (you “opt in”) to do so, in which case their use of your information is subject to their own privacy policies;
When we have retained companies to work with or on behalf of Hotel Concierge to provide products, goods or services that you have requested;
When the secondary purpose is related to the primary purpose;
When we are compelled to do so by a governmental agency, court or other entity (e.g., to respond to, court orders or legal process);
if we believe your actions violate any law, regulation, breach, or if you threaten the rights, property or safety of Hotel Concierge, its suppliers, advertisers, other customers or users, or any other party;
as and when we, in our sole discretion, believe such disclosure to be necessary or appropriate to investigate or resolve possible problems or inquiries, to protect our business and assets, to defend our interests and/or to comply with our legal and regulatory obligations; or
in the event of a bankruptcy, or a merger, acquisition, joint venture or other business combination involving us.
It is also possible that third parties may unlawfully intercept or access transmissions or private communications which is out of our control.
Other Third Party Links
Individual, You, Your, Yours a natural person. Identifier means a number assigned by an organisation to identify uniquely that individual for the purposes of the organisation’s operations. Example of this is a Medicare No. or TFN; however an individual’s name or ABN is not. Personal Information means information or an opinion about an individual that can identify, or can be reasonably ascertained from the information or opinion. Privacy Act means the Privacy Act 1988 (Cth), as amended from time to time. Private Sector The Privacy Amendment (Privacy Sector) Act 2000 covers the collection, use and disclosure of personal information to organisations with an annual turnover of $3 million or more, all health service providers and some small businesses. Sensitive Information information or an opinion about an individual’s:
racial or ethnic background, political opinions, philosophical beliefs, criminal record, health information, sexual preference or practices, religious beliefs or affiliations, membership of a professional, trade or political association. Third Party in regards to personal information, means any entity or organisation other than Hotel Concierge holding the information and the individual who is the subject of the information.