1. Background and scope

Members Travel Group is one of Australia’s largest travel agency groups and needs to collect, use, and disclose personal information to carry out its business functions and activities, which include making and managing travel bookings for our customers. We are deeply committed to safeguarding the privacy and confidentiality of personal information and have implemented various physical, electronic, and procedural safeguards to protect the personal information we hold.

This Privacy Policy (“Policy/Notice”) outlines how Members Travel Group uses, processes, manages and protects your personal information.

In some cases, Australian data protection laws (Privacy Act 1988 [Cth] and Australian Privacy Principles) may require stricter information handling practices than those outlined in this policy. In such instances, we will modify our information handling practices in your jurisdiction to comply with local data protection laws.

2. What personal information do we collect?

Personal information refers to data that relates to a living individual who can be identified from that data, or from that data combined with other information in a person’s possession. This includes any opinion expressed about an identified or reasonably identifiable individual, whether it’s true or not, and whether it’s recorded in a physical form or not, as well as any indication of intention regarding an individual.

In general, the personal information we collect about you is the information required to facilitate your travel arrangements and bookings, and to organize travel-related products and/or services on your behalf.

As such, we typically process the following types of personal information about you:

• Identifiers
• contact information (such as name, residential/mailing address, telephone number, email address);
• date of birth;
• passport details, national identity card details, driver’s license details;
• online identifiers (such as IP address, device data, and network information); 
• loyalty program / frequent flyer details; 
• Commercial Information, including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies; 
• Biometric information; 
• Internet or other electronic network activity (such as the device and network you are using to connect with us), as further described in section 10; 
• Geolocation data; 
• Audio (such voice recordings for quality control, service improvement, training and dispute resolution), electronic and visual information (such as video surveillance footage) used for security purposes,  
• Professional or employment-related information; 
• Payment account information (credit/debit card details, including card type, card number, security number and expiry date and other financial details necessary to process various transactions);  
• Health information such as your dietary requirements and health issues (if any); and  
• Other details relevant to your travel arrangements or required by the relevant travel service provider(s) (e.g., airlines and accommodation or tour providers).  

When you reach out to us, we may collect personal information related to those purposes. For instance, we may gather your personal information to get in touch with you about a competition you’ve entered (eg. if you win), or to address an inquiry or complaint you’ve made, or feedback you’ve given us. We also gather information needed for the business activities of Members Travel Group and our associated entities, such as financial details required to process different transactions, and any other relevant personal information you choose to provide us.

In certain situations, we might collect personal information from you that could be considered sensitive under your local data protection laws. Sensitive information can include your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual orientation, membership in political, professional or trade associations (used for booking special rates), biometric and genetic information, passwords, financial information, and health information. Please note that we may collect personal information relating to a child of any age from a responsible adult when necessary for travel arrangements, but we do not knowingly collect such information directly from children.

We will collect sensitive information only in accordance with Australian data protection laws, with your explicit, voluntary consent, and when it’s reasonably necessary for or directly related to our functions or activities (like providing travel-related products and services), unless we’re required or authorised to do so by law. As allowed or required under your local data protection laws, you voluntarily consent to us using and disclosing your sensitive information for the purpose it was collected.

For instance, if you provide health information for a travel insurance application, you voluntarily consent to us using and disclosing that health information to arrange the travel insurance on your behalf. Another example is if you share your religious beliefs with us because you’re interested in certain holiday packages, you voluntarily consent to us using and disclosing that information to facilitate your request.

We won’t use or disclose sensitive information for purposes other than those for which it was collected, unless we later ask for and receive your voluntary consent to use it for a different purpose.

3. How do we collect personal information?

We will only collect personal information in compliance with Australia data protection laws. We collect your personal information directly from you during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.

Generally, this collection will occur:

• when you deal with us either in person, by telephone, letter or email;
• when you visit any of our websites;
• or when you connect with us via social media.

We may collect personal information about you:

• when you purchase or make enquiries about travel arrangements or other travel-related products and services;
• when you enter competitions or register for promotions; when you subscribe to receive marketing from us (e.g., e-newsletters);
• when you request brochures or other information from us;
• or when you provide information, or use our services, on social media.

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., a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking.

Where you make a travel booking on behalf of another person(s) (e.g., a family or group booking or a travel booking made for an employee), you agree to have obtained the voluntary and informed consent of the other person(s) for Members Travel Group to collect, use and disclose the other person's personal information in accordance with this Notice and that you have otherwise made the other person(s) aware of this Notice.

You should let us know immediately if you become aware that your personal information has been provided to us by another person without your voluntary consent or if you did not obtain voluntary consent before providing another person's personal information to us.

We strive to keep your personal information that we store accurate, complete, and up-to-date. However, we greatly appreciate your help in this matter. Please contact us promptly if your personal information changes or if you find that we have incorrect personal information about you (refer to section 12 below). We won’t be liable for any losses resulting from inaccurate, inauthentic, insufficient, or incomplete personal information that you or someone on your behalf provides to us.

If you choose not to voluntarily consent to the collection and processing of your personal data, it may prevent us from providing certain services that rely on this data, or it may affect the quality of the services we can provide.

If you ask us to limit or stop using your personal information, or if you withdraw a previously given consent, it may impact our ability to serve you or affect the quality of our services. For instance, travel bookings usually require the traveler’s full name, contact details, and appropriate identification like passport details. Without this information, we can’t make bookings for you.

Your voluntary consent for the collection, use, and disclosure of your personal data remains valid until you withdraw it in writing. You can withdraw consent and ask us to stop collecting, using, and disclosing your personal data by submitting a written request to our privacy team using the contact information provided in section 12. Please note, withdrawing consent doesn’t affect our right to collect, use, and disclose personal data when it’s allowed or required by law.

Regarding data retention, we may keep your personal data as long as necessary to fulfil its intended purposes, or as required or allowed by law. We’ll stop retaining your personal data, or remove the means to associate the data with you, once it’s reasonable to assume that the data is no longer needed for its original purposes or for legal or business reasons.

4. How do we use your personal information?

We will process your information only when:

• You have voluntarily given your consent for such processing (which you can withdraw at any time, as detailed in section 4 above);
• The processing is necessary to provide our services to you;
• The processing is necessary for the performance of a contract to which you are a party;
• The processing is necessary for compliance with our legal obligations; and/or
• The processing is necessary for our legitimate interests or those of any third-party recipients that receive your personal information (as detailed in this section and section 6 below).

In detail: When you contact us about a travel booking or query, we generally collect your personal information to provide you with travel advice and/or to assist you with booking travel and/or travel-related products and services. However, the purpose for collection may vary depending on the specific circumstances as disclosed in this Notice (e.g., collection of your personal information for your participation in a competition, provision of feedback, etc.).

When you book or arrange travel-related products and services through us, we typically act as an agent for the relevant travel service providers (e.g., for a hotel). In this case, we process your personal information as necessary to provide the services you requested from us. This usually involves collecting personal information about you for our internal purposes as described in this Notice and for the travel service provider for whom we act as an agent (e.g., to provide you with the booked services). For example, if you book a flight through us, we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.

We may therefore share your personal information with our travel service providers such as hotels, airlines, car rental, or other providers, who fulfill your travel bookings. Please note that these travel service providers may also use your personal information as described in their respective privacy policies and may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or provide you with your requested services. We encourage you to review the privacy policies of any third-party travel service providers whose products you purchase through us. We will provide you with copies of all available relevant travel service provider terms, conditions, and privacy policies on request.

We act as an agent for or on behalf of many thousands of travel service providers around the world, so it is not possible for us to set out in this Notice all of the travel service providers for whom we act or their locations. For more information about the disclosure of personal information to travel service providers located overseas, please refer to section 6 below.

If you have any concerns regarding the transfer of your personal information to a travel service provider, or you wish to contact us for further information, please refer to the section 12 below.

Further purposes for which we process personal information include:

• Providing you with services and tools you choose to use (for example, saving travel preferences on our websites to a wish list or saving personal information to allow for pre-population of online forms);
• Identification of errors;
• Protecting against, deterring, detecting, and investigating fraudulent, unauthorised, or illegal activities;
• Regulatory reporting and compliance;
• Developing and improving our products and services and those of our related entities;
• Servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences;
• The provision of reports, analytics, and dashboards, to your employer on activities comprising their business travel programme as part of contracted business travel services;
• Involving you in market research, gauging customer satisfaction, and seeking feedback regarding our relationship with you and/or the service we have provided;
• To facilitate your participation in loyalty programs;
• For research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and travel destinations, and use of our websites;
• Internal reporting, analytics, accounting, and administration;
• To comply with our legal obligations, including complying with law enforcement or government authority requests, and any applicable customs/immigration requirements relating to your travel;
• To comply with a valid and authorised court order or other valid legal process; and
• Other purposes as authorised or required by law (e.g., to prevent a threat to life, health, or safety, or to enforce our legal rights).

Where permitted by Australian data protection laws, we may use your personal information to send you targeted marketing activities relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information. These may include, but are not limited to, mail outs, electronic marketing, and notifications as described below, and telephone calls. We will only use your personal information to send electronic marketing materials to you (including e-newsletters, email, SMS, MMS, and iM) if you have opted-in to receive them or not opted out of receiving them, depending upon the applicable law. You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of our consultants to do so for you.

Should you no longer wish to receive promotional/marketing material from us, participate in market research, or receive other types of communication from us, please refer to section 12 below. You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM, or other forms of electronic marketing. Please also see the “Your rights” section of this policy to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes (section 8 below).

5. Is personal information disclosed to third parties?

We do not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this policy and, in particular, as set out below, and in accordance with Australian data protection laws. Note that, in this policy, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity. 

Your personal information may be disclosed to the following types of third parties: 

• our independent contractors, suppliers and service providers, including without limitation:
• in each of the circumstances set out in section 4 above; 
• suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting providers we may use); 
• publishers, printers and distributors of marketing material; 
• 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 agencies);  
• our related entities and brands; 
• travel-related service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers, travel risk management companies, travel insurance companies, and other related service providers; 
• any third party to whom we assign or novate any of our rights or obligations;  
• financial institutions such as banks, when processing financial transactions; 
• credit providers, issuers and payment service providers; 
• a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);  
• your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes; 
• third parties who provide services to our business travel clients, in order to facilitate the delivery of those services;   
• a person who can verify to us that they have a relationship with you (e.g., a family member) where you are not contactable, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);  
• as required or authorised by applicable law, and to comply with our legal obligations; 
• customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel; 
• government agencies and public authorities to comply with a valid and authorised request, including a court order or other valid legal process;  
• various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; 
• enforcement agencies 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; and 
• third-party services or applications when you use these to log into your account (e.g., if you use a third-party service or application to log into your account, we share certain personal information with that third party). 
• The Royal Automobile Club of Queensland Limited, an any of its associated companies or subsidiaries.

When you ask us to book flights for you, we share your personal information (such as name, email address, and/or mobile number) with the relevant airline. This allows airlines to directly inform passengers about irregular flight operations and disruptions like flight cancellations or schedule changes. Similarly, we share your personal information with the relevant rail provider when booking rail journeys, if required.

Apart from these instances, we won’t disclose your personal information without your voluntary consent. Exceptions to this are if we believe that disclosure is necessary to reduce or prevent a threat to an individual’s life, health, or safety, or to public health or safety, or for an enforcement body to take certain actions (like preventing, detecting, investigating, prosecuting, or punishing criminal offences), or if such disclosure is authorised or required by law (including applicable privacy/data protection laws).

On our websites, you can choose to use features that are accessed through, or partnered with, entities not affiliated with us. These features, including social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information according to their own privacy policies. We strongly recommend that you review the third parties’ privacy policies if you use these features.

6. Is personal information transferred overseas?

We may disclose your personal information to certain overseas recipients, as set out below. We will ensure that any such international transfers are necessary for the performance of a contract between you and the overseas recipient, and/or are made subject to appropriate or suitable safeguards as required by Australian data protection laws.

It is possible that information will be transferred to an overseas recipient located in a jurisdiction where you will not be able to seek redress under Australian data protection laws and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by Australian data protection laws, we will not be liable for how these overseas recipients handle, store, and otherwise process your personal information. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards as required by your local laws.

1. Travel service providers located overseas
   In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers. We deal with many different travel service providers all over the world, so the location of a travel service provider relevant to your personal information will depend on the travel services being provided. The relevant travel service providers will in most cases receive your personal information in the country in which they will provide the services to you or in which their business or management is based.  
2. Our third-party service providers located overseas
   We may also disclose your personal information to third-parties located overseas for the purpose of performing services for us, including the storage and processing of such information. Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of your travel booking and/or to enable the performance of administrative and technical services by them on our behalf. 

7. Security of information

We are dedicated to protecting personal information and will use suitable technical and organisational measures to safeguard any personal information given to us from accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. Members Travel Group has put in place various physical, electronic, and organisational security procedures to protect the personal information it holds from loss, misuse, and unauthorised access, modification, disclosure, and interference.

Members Travel Group regularly updates its security technologies and aims to protect your personal information as thoroughly as we protect our own confidential information. However, Members Travel Group is not accountable for the actions of any third-party or their security measures concerning information that third-parties may collect or process via their websites or services.

Once we no longer need personal information for our business purposes, or as required by law, we will destroy or make it unidentifiable.

8. Your rights in relation to the personal information we collect

If you wish to make an access request to:

• Access, update, modify, rectify, erase, object to, or get a copy of the personal information we hold about you; or
• Limit or stop us from using any of the personal information we hold about you, including by withdrawing any voluntary consent you’ve previously given for the processing of such information; or
• Request a copy of any personal information that has been processed based on your voluntary consent or as necessary to perform a contract to which you’re a party, in a suitable machine-readable format or have that personal information transmitted by us to another controller, you can make this request by contacting us as outlined in section 12 below. You’ll receive an acknowledgement of your request.

We’ll always process your requests within the timeframes set by applicable privacy laws. Please note, we reserve the right to extend this period for complex requests or as otherwise allowed by applicable law.

We reserve the right to deny your access for any reason permitted under applicable laws. Such exemptions may include national security, corporate finance, and confidential references. If we deny access or correction, we’ll provide you with written reasons for the denial unless it’s unreasonable to do so and, where required by local data protection laws, will note your request and the denial in our records.

You have the right to lodge a complaint with a relevant supervisory authority.

Further correspondence regarding your request should only be made in writing to our privacy team as outlined in section 12 below.

You must always provide accurate information and agree to update it when necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it’s not correct.

You can tell us at any time not to send you marketing communications by email by clicking on the unsubscribe link within the marketing emails you receive from us or by contacting us as indicated in section 12 below.

In any of the situations listed above, we may ask that you prove your identity by providing us with a copy of a valid means of identification for us to comply with our security obligations and to prevent unauthorised disclosure of personal information.

To the extent permissible by law, we reserve the right to charge you a reasonable administrative fee for any manifestly unfounded or excessive requests concerning your access to your personal information, and for any additional copies of the personal information you request from us.

9. Tracking Technologies and Cookies

We may use third-party web analytics services on our websites and mobile apps, such as those listed in our Cookies Policy. The analytics providers that administer these services use technologies such as cookies and web beacons to help us analyse how visitors use our websites and apps.

For information regarding our use of cookies and tracking technologies, refer to our Cookies Policy on our website.

10. IP Addresses

When you access our website, use any of our mobile applications or open electronic correspondence or communications 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.

We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (e.g., to better tailor our marketing and advertising materials, provided you have not opted out of receiving electronic marketing). 

11. Linked Sites

Our website may contain links to third-party websites over which we have no control. We are not responsible for the privacy practices or the content of such websites. We encourage you to read the privacy policies of any linked third-party websites you visit as their privacy policy and practices may differ from ours.

12. Feedback / Complaints / Contact

You can direct any questions or complaints about the use or disclosure of your personal information to the contact information below.

If you have any enquiries, comments or complaints about this Notice or our handling of your personal information, please contact your Travel Advisor or by using the details set out below and we will respond as soon as practicable.

Matter	Email or Postal Address
Privacy	privacy@memberstravelgroup.com.au
Complaints	complaints@memberstravelgroup.com.au
Feedback / Information	feedback@memberstravelgroup.com.au
Head Office Address	450 Hunter Street, Newcastle, NSW, 2300 AU

 

13. Changes to our policy

We may amend this policy from time to time. If we make a change to the policy, the revised version will be posted on our website. We will post a prominent notice on our website to notify you of any significant changes to our policy and indicate at the end of the policy when it was most recently updated. It is your responsibility, and we encourage you, to check the website from time to time in order to determine whether there have been any changes.

This Privacy Policy was last updated on June 19th, 2024