Tweed Ultima Holdings Pty Ltd as trustee for the JSMS Family Trust t/as Tweed Ultima Apartments and any other related entities (together, ‘Tweed Ultima’) is committed to ensuring the protection of the privacy of the personal information it collects or receives during the course of its business.
Purpose of the Policy
This document sets out the policy of Tweed Ultima and its related entities in relation to the protection of the privacy of personal information and is made in compliance with Tweed Ultima’s obligations under the Privacy Act 1988 (Privacy Act) and the Australian Privacy Principles (APPs).
Application of the Policy
This policy applies to any individuals about whom Tweed Ultima currently holds, or may collect in the future, their personal information.
The purpose of this policy is to inform such individuals about:
- what types of personal information we collect, and
- what we do with this personal information
Collection of Personal Information
What is personal information?
‘Personal information’ is information or an opinion, whether true or not, about an individual whose identity is apparent or can be reasonably identifiable. Information may or may not be recorded in material form in order to be classified as personal information.
Examples of personal information includes any information where a person is reasonably identifiable, such as:
- a person’s name, address, phone number and email address
- bank account details
- information about what a person likes and their opinions
- information about where a person works
What is sensitive information?
This policy also refers to ‘sensitive information’. Sensitive information is a category of personal information and is information about a person’s:
- racial or ethnic origin, political opinions, membership of a professional or trade association
- religious or philosophical beliefs
- sexual preferences or practices
- health, genetic or biometric information
- criminal records
Information that is not personal information
Information is not personal information where Tweed Ultima has removed any reference to an individual so that the person cannot be reasonably identifiable from the information. Tweed Ultima can use this information for its own purposes and for commercial gain.
How and when we collect personal information
Tweed Ultima collects personal information in a number of ways in the course of conducting its business, including when it is:
- booking a room
- checking-in and paying for accommodation
- paying for function room hire
- hotel stays and services provided during a stay
- requests, complaints and or/disputes
- contacted via telephone, email or in person
- online booking enquiries
- functions bookings and enquires
- signing up individuals to or administering its electronic mailing lists
- conducting promotions or competitions through social media and other platforms
Where reasonable and practicable, Tweed Ultima will collect personal information directly from the person and inform them of the collection. However, in some circumstances we will collect personal information through service providers, agents or publicly available sources (e.g. phone book).
Personal information we collect and hold
The types of personal information we collect and hold includes:
- names, titles, contact and address details
- dates of birth and gender
- bank account details, including credit card number
- information contained on a form of identification (such as ID card, passport or drivers license)
- email addresses
- IP addresses
- your arrival and departure dates
- your preferences and interests (for example, smoking or non-smoking room, type of bedding, etc.)
- your questions/comments, during or following a stay
- information about what our customers like and their opinions
We hold personal information we collect in a number of formats including hard copy and on our computer systems.
If Tweed Ultima receives personal information it did not request, and Tweed Ultima determines that it would not be permitted to collect this information under the APPs, Tweed Ultima will destroy or de-identify the information as soon as practicable.
Why do we collect personal information?
We collect personal information for purposes including to enable us to provide our services to you, to contact and communicate with you, for internal record keeping and for marketing. We may also use personal information we collect for associated secondary purposes where you could reasonably expect its use or disclosure.
Collection of Sensitive Information
Unless required or authorised by law, Tweed Ultima will not collect sensitive information about an individual unless:
- it has the consent of the person to whom it relates, and
- the information is reasonably necessary to one or more of Tweed Ultima’s functions or activities
Tweed Ultima is not required to comply with the Privacy Act when handling the personal information of its employees if the personal information is directly related to:
- a current or former employment relationship
- an employee record relating to the employee
This means that the APPs do not apply to Tweed Ultima when it handles current or past employee records for something that is directly related to the employment relationship. Tweed Ultima is also not required to grant its employees access to their personal information held by Tweed Ultima under the Privacy Act, although it may have an obligation to disclose certain employee records under other legislation.
Use and Disclosure of Personal Information
We may use or disclose personal information that we collect for its primary purpose (e.g. selling our goods to you) or for related secondary purposes that a person would reasonably expect us to use or disclose that information (e.g. where we provide your address to courier drivers who deliver our goods).
Otherwise, Tweed Ultima will not use or disclose personal information to third parties without the consent of the individual to whom it relates unless the disclosure is:
- required or authorised under law, or
- it is permitted under an exception to the Privacy Act
Security of Personal Information
Tweed Ultima takes all reasonable steps to ensure that personal information is stored in a manner that reasonably protects it from misuse, unauthorised access, modification or disclosure. Tweed Ultima does not guarantee that personal information cannot be accessed by unauthorised third parties. Where personal information is no longer required for the purpose for which it was obtained, we will take reasonable steps to destroy or de-identify this information.
Your Rights and Choices
Accessing and correcting personal information
Tweed Ultima will grant someone access to their personal information, or correct personal information, as soon as possible once a request has been made. All requests should be made to:
+61 7 5599 3500
20 Stuart Street
Tweed Heads South, NSW 2485
Tweed Ultima is not required to provide access to personal information if:
- providing access would pose a serious threat to the life, health or safety of any individual or public health or safety
- providing access would have an unreasonable impact on the privacy of other individuals
- the request is frivolous or vexatious
- the information relates to an existing or anticipated legal proceeding
- denying access is required or authorised by law
- providing access would prejudice Tweed Ultima’s rights or commercial interests
- there are other legal grounds to deny the request
Complaints that Tweed Ultima or its agents or third parties have breached this policy should be made in writing by post or email to Tweed Ultima, to the above address.
Tweed Ultima deals with all complaints through an internal process. We will assess your complaint and respond to you within a reasonable period of time. Any subsequent action in relation to a complaint will depend on individual circumstances.
Status of this Policy
This policy is not intended to create contractually binding obligations upon Tweed Ultima.
This policy (and any other Tweed Ultima policy) may be varied or withdrawn from time to time by Tweed Ultima in its discretion
This policy does not form a part of employee employment contracts and is not contractually binding upon Tweed Ultima.
Date 06 June 2019