Version 2 - Last updated April 2019
Apollo Motorhome Holidays Pty Ltd ACN 051 584 153 in Australia and its related bodies corporate (as that term is defined in section 50 of the Australian Corporations Act 2001 (Cth)), in Australia, New Zealand and the United States (referred to in this policy as we, us, our) recognise the importance of protecting the privacy of personal information we collect about you.
Your Personal Information
Personal Information is any information or opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is stored in a material form or not.
We only collect personal information that is directly related to, or reasonably necessary for, our functions and activities. The types of personal information we usually collect, how we collect such personal information, how we hold your personal information, the purposes for collection and use and to whom we disclose your personal information are detailed below.
Wherever practicable, we will enable you to deal with us anonymously or pseudonymously, however, in many cases it is not practicable to interact in this way.
If you choose not to provide some of your personal information, this may prevent us from providing our services or goods to you or limit our ability to provide the level of service you would normally expect from us.
What kind of Personal Information do we collect?
The service that you use or the goods you purchase will determine exactly what information we collect from you. The personal information we collect from you may include your:
- full name;
- home or mailing address;
- contact telephone number(s);
- contact facsimile number(s);
- date of birth;
- marital status and family details (next of kin);
- country of Residence;
- driver's licence number and state/country of origin (which may include a scan of your physical driver’s licence);
- frequent traveller program number;
- identification details (e.g. student, pensioner card);
- vehicle preference;
- financial information, such as your bank account, credit card number(s) and expiry date(s);
- passport details;
- email address;
- employment information, including company name, position and employee number;
- contact details of individuals who can provide professional references and other information required in the Cash Qualification process;
- reservations and rental details including dates, times and places of vehicle hire;
- sales details including date, place of vehicle purchase, amount of purchase price, and details of vehicle purchased;
- information with respect to vehicle purchase financing;
- preferences such as baby seat requirements, GPS requests, table and chair orders, etc; and
- vehicle damage circumstances and details.
How we collect Personal Information
Personal information will generally be collected directly from you when you rent or purchase a vehicle from us and through the use of any of our standard forms, our dealings with you over the internet, via email, or through a telephone conversation. The service that you use or the goods you purchase will determine how we collect personal information from you.
It is our usual practice to collect personal information about you directly from you (or from your authorised representative). This is done when we make a record of the personal information that is provided to us when you (or your representatives):
- visit one of our websites;
- fill out a hard copy or digital form;
- give information to our sales representatives;
- provide a testimonial, survey response or are part of a focus group;
- apply for membership to or sign on for any service that we provide;
- order or purchase goods or services from us;
- post a review or comment on one of our websites or social media pages or post a rating or review or other user generated content on one of our websites or apps;
- enter one of our competitions (or competitions run by our partners or associates);
- provide goods or services to us;
- participate in product promotional activities;
- click on one of our advertisements or offers (by using technology such as ‘cookies’);
- interact with us in relation to employment services, human resource management, and other corporate service functions;
- communicate with us (including e-mail and telephone) for security, dispute resolution and training purposes and when we operate video and audio surveillance devices in our premises;
- make a complaint or legal/ liability claims against us;
- sign documents on behalf of your employer, or an entity to whom you provide services, being an entity or person who is one of our suppliers or customers; and/or
- contact us by telephone, mail, email, online or by any digital form or social media.
There may, however, be some instances where personal information about you will be collected indirectly because it is unreasonable or impracticable to collect personal information directly from you or your authorised representative. For example we may collect personal information through a travel agent, a corporate program or through one of our partner programs. We will usually notify you about these instances in advance, or where that is not possible, as soon as reasonably practicable after the information has been collected.
We may collect personal information from our business or related entities and affiliates which collected your information in a different country (e.g. Australia, Canada, France, Germany, New Zealand, the United Kingdom and the USA).
We may also collect information about you by accessing data from other sources and then analysing that data with the information that we already hold about you in order to learn more about your preferences and interests.
If the personal information you provide us is incomplete or inaccurate, we may be unable to provide you, or someone else you know, with the goods, services or information you or they are seeking.
How we hold your personal information
We may hold the personal information we collect about you in various forms, including:
- physical (paper) form;
- storage through an electronic records system; and
- data management software or systems in accordance with our usual business practices.
Purposes of collection
The purposes for which we collect your personal information depend on your interaction with us. But generally, we collect your personal information for the purposes of:
- providing the goods or services you request;
- manage your requests for products and services including delivery, processing payments, providing refunds, discounts and incentives;
- researching, developing, managing, protecting and improving our services;
- conducting credit checks and credit reporting, processing payments or collection of outstanding amounts;
- conducting customer satisfaction surveys and informing you of any improvements we have made to our goods or services;
- maintaining and developing our software and other business systems;
- dealing with complaints or enquiries; and
- providing you with direct marketing materials, which is information about other goods or services we provide, or goods or services that our related entities and other organisations that we have affiliations with, offer that may be of interest to you.
How we use the information we collect
We use and disclose your personal information for the “Purposes of Collection” set out above and for the following additional purposes:
- sending you material on our activities and products that we believe may be of interest to you and tailoring marketing services to suit your needs (including direct marketing);
- maintain and improve customer services, including conducting product and market research and analysis;
- to improve our operational processes, enhance your customer experience and to monitor and review our compliance with relevant regulations and codes of conduct in our dealings with you;
- to monitor the quality and safety of our products and services;
- administer programs or events that are sponsored by us;
- generate customer lists for the purposes of market research;
- facilitate your interaction with us on our website;
- meet our legal obligations and to notify you of matters that we are required to do so by law (such as product recalls);
- interact with Regulators or other Government agencies;
- manage and resolve any legal or commercial complaints and issues;
- to manage our contractual relationships with vendors, suppliers and other third parties with whom we do business;
- investigate fraud and to carry out loss prevention activities; and/or
- carry out internal functions including training.
We may sometimes use the personal information we collect for one or more secondary purposes, that is, for use in a way different from the original reasons for collection set out above. We will only do this in one of the following circumstances:
- where you have consented;
- where the secondary purpose is directly related to the primary purpose, and you would reasonably expect us to use or disclose the information in such a way;
- where we are permitted or required by law; or
- it is in the interests of public safety to do so.
To whom we may disclose personal information
We may disclose your personal information to other related entities and non-related organisations including:
- vehicle manufacturers, in particular motorhome and campervan manufacturers;
- related entities that form part of our corporate group (including overseas entities) as well as licensees or agents of our corporate group;
- your company or organisation if you use our services or purchase our goods under a corporate account;
- to one of our program partners if you are a member of their frequent traveler program and have asked us to send them details of your rental agreement with us;
- our contracted service providers;
- credit card providers;
- credit reporting and fraud checking agencies where necessary to register a default;
- debt collection agencies, in the event of your default in payment of monies owed to us;
- professional advisers (such as lawyers, accountants or auditors) to the extent that is reasonably required;
- payment systems operators and financial institutions;
- third parties for the purpose of providing financing of your purchases of goods from us;
- third party service providers that provide us with communication (e-mail) or data storage services;
- technology services including application, development and technical support, processing, storing, hosting and data analysis;
- travel agents and other travel/ event related service providers;
- administrative services, including mailing services, printing, archival and contract management services;
- third party agents or contractors with whom we contract in the ordinary course of business;
- organisations authorised by us to conduct promotional, research or marketing activities;
- city councils and government or private organisations responsible for the processing or handling of traffic related infringements;
- driver licensing authorities;
- one or more third parties in the event that we go through a business transition, such as a merger, being acquired by another company, or selling all or part of our assets;
- government, regulatory and law enforcement agencies where the disclosure is required or authorised by law; and
- any persons acting on your behalf including those persons nominated by you, executors, trustees and legal representatives.
When you provide your personal details, you consent to us using your personal information for direct marketing purposes (for an indefinite period). From time to time, we may contact you with information about products and services offered by us and our related entities and our business partners or affiliates, which we think may be of interest to you. When we contact you it may be by mail, telephone, email, SMS or via social media. These communications may relate to products and services that we and our affiliates provide, and other products that may be of interest to you.
We also hope to deliver to you advertising for products and services that you need or want. For example, we partner with websites with whom you have shared your interests, condition and concerns directly and asks that they serve our ads to users who have expressed an interest in our products or services. We may also partner with advertising companies to serve you ads based on your web browsing activity, purchases and/or interests. Some techniques for delivering content based on your interests are referred to as online behavioural advertising.
You may opt out of direct marketing communications from us by submitting a request using the contact details under the heading “How to contact us - complaints and feedback” below. If you are accessing our services in New Zealand and the Unsolicited Electronic Messages Act 2007 applies, or if you are accessing our services in Australia and the Spam Act 2003 (Cth) applies, we will not send marketing communications to you without your consent. Except as set out above, we will not sell or otherwise transfer your contact details to other parties for direct marketing purposes.
We store your personal information in different ways, including in paper and in electronic form, both at our own premises and with the assistance of our service providers.
The security of your personal information is important to us. We take all reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, interference, unauthorised access, modification or disclosure, including electronic and physical security measures. We use industry standard safeguards to ensure the security of personal information through physical, electronic and managerial procedures. In addition, our employees and the contractors who provide services related to our information technology systems are obliged to respect the confidentiality of any personal information held by us.
Our computer systems may be operated by us or by our service providers. In all cases, we have rigorous information security requirements aimed at eliminating risks of unauthorised access to, and loss, misuse or wrongful alteration of, the personal information that we handle. Examples of these measures include:
- control of access to personal information through access and identity management systems (such as passwords); and
- our personnel are bound by and trained on internal information security policies and are required to keep personal information secure at all times.
We also have policies in place for data retention across all key areas. We keep your personal information for as long as it is required to provide you with the products and services you requested from us and to comply with legal requirements. If we no longer require your personal information for any purpose, including legal purposes, we will take reasonable steps to securely destroy or de-identify your personal information.
Our websites are professionally hosted and operate in a secure environment. While we strive to ensure the security, integrity and privacy of personal information submitted to our website, unfortunately, no data transmission over the Internet can be guaranteed to be totally secure and we take no responsibility for the security of data transmissions to and from our website or other IT systems.
Seeking access to, and correcting, information
We will take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up to date.
You may access the personal information we hold about you, by making a written request. We will respond to your request within a reasonable period. We may charge you a reasonable fee for providing access to your personal information (but not for making a request for access).
We may decline a request for access to personal information in circumstances prescribed by the Privacy Act of 1993 (in New Zealand) or the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia), and if we do, we will provide you with a written notice that sets out the reasons for the refusal (unless it would be unreasonable to provide those reasons).
If, upon receiving access to your personal information or at any other time, you believe the personal information we hold about you is inaccurate, incomplete or out of date, please notify us immediately. We will take reasonable steps to correct the information so that it is accurate, complete and up to date.
If we refuse to correct your personal information, we will provide you with a written notice that set out the reasons for our refusal (unless it would be unreasonable to provide those reasons) and provide you with a statement regarding the mechanisms available to you to make a complaint.
Disclosing personal information overseas
We store your personal information in Australia. We may disclose your personal information to our affiliates in Canada, France, Germany, New Zealand, the United Kingdom and the USA.
If we collect your personal information, you are taken to consent to the disclosure, transfer, storing or processing of your personal information outside of Australia. You acknowledge and agree that by providing your consent:
- we will not be required to take steps as are reasonable in the circumstances to ensure that such third parties comply with the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia);
- if the overseas recipient handles your Personal Information in breach of the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia):
- we will not be liable under the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia); and
- you will not be able to seek redress under the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia).
- the overseas recipient may not be subject to any privacy law or principles similar to the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia);
- you may be unable to seek redress overseas; and
- the overseas recipient is subject to a foreign law that could compel the disclosure of personal information to a third party, such as an overseas authority.
How to contact us - complaints and feedback
If you wish to make a complaint about a breach of the Privacy Act of 1993 (in New Zealand) or the Privacy Act 1988 (Cth) and Australian Privacy Principles (in Australia) or a privacy code that applies to us, please contact us as set out below and we will take reasonable steps to investigate the complaint and respond to you.
Street address: Apollo Motorhome Holidays, 698 Nudgee Road Northgate Queensland 4013
Email address: [email protected]
Telephone: 07 3265 9219
Fax: 07 3265 9201
If you are not satisfied with the way in which we handle your query, concern or complaint, you can contact the following Government bodies:
In Australia, the Office of the Australian Information Commissioner:
Phone: 1300 363 922 (calling from within Australia)
Mail: GPO Box 5218, Sydney NSW 2001, Australia
Email: [email protected]
In New Zealand, the Office of the Privacy Commissioner:
Phone: 0800 803 909 (calling from within New Zealand)
Mail: PO Box 10094, Wellington 6143, New Zealand
Email: [email protected]
Links to other sites
We provide links to websites outside of our website, as well as to third party websites. These linked sites are not under our control, and we cannot accept responsibility for the conduct of companies linked to our website. Before disclosing your personal information on any other website, we advise you to examine the terms and conditions of using that websites and its privacy statement. If you provide us with information about any third party, you must obtain that person’s permission to give us the information and inform them that you have given the information to us.
Changes to this policy
We may change this policy at any time. Any updated version of this policy will appear on this website.
Further privacy information
For more information about privacy issues in Australia and protecting your privacy, visit the website of the Office of the Australian Information Commissioner (https://www.oaic.gov.au).