Privacy Policy
ITC Pacific Pty Ltd (ABN 94 056 186 200) is the parent entity of the ITC Pacific group, which includes Sno'n'Ski Group Holidays & Educational Adventures. References in this Privacy Policy to "ITC Pacific", "we", "our" or "us" mean ITC Pacific Pty Ltd and its subsidiary entities collectively, and all obligations, standards and commitments in this Privacy Policy apply to them accordingly. This Privacy Policy sets out how we protect the privacy of your personal information.
Please note that this Privacy Policy and all personal information collected and dealt with by ITC Pacific is subject to the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian Privacy Principles ("APP") contained in Schedule 1 of the Privacy Act, as amended from time to time.
Purpose
The purpose of this Privacy Policy is to:
-
Clearly communicate the personal and sensitive information handling practices of ITC Pacific;
-
Enhance the transparency of our information collection processes; and
-
To give individuals a better understanding of the sort of personal information that we hold, and the way ITC Pacific uses or discloses that information.
Scope
This Privacy Policy applies to the collection, holding, use and disclosures of personal and sensitive information provided about individuals to ITC Pacific through the use of the website, www.snonskigroups.com.au and www.educationaladventures.com.au ("the website"), other applications related to ITC Pacific and any services offered or provided by ITC Pacific ("services"). In this Privacy Policy we also explain how you can contact us if you have a query about any personal or sensitive information that we may be holding about you.
Acknowledgement
By continuing to use the website and/or services or when you purchase services from ITC Pacific, you acknowledge that you have had the opportunity to read this Privacy Policy. You also acknowledge and consent to ITC Pacific collecting, holding, and disclosing personal information supplied by you and retaining and/or using your personal information.
We may do so subject to the terms of this Privacy Policy, the website, any terms and conditions that apply to any goods or services that we provide to you, and any other applicable contracts.
If you provide us with personal and/or sensitive information of a third party individual, for example other people travelling with you, you will be responsible for informing the individual of the existence of this Privacy Policy and obtaining their consent for their personal or sensitive information to be provided to ITC Pacific for the purposes indicated in this Privacy Policy or as otherwise indicated at the time of collection.
Personal information
In this Privacy Policy, "personal information" has the same meaning as defined by section 6 of the Privacy Act, as amended:
information or an opinion about an identified individual, or an individual who is reasonably identifiable:
a) whether the information or opinion is true or not; and
b) whether the information or opinion is recorded in material form or not.
Personal information may include your name, address (including previous addresses), information about you (including medical information), contact telephone number(s), e-mail addresses, bank account and credit card details, and details about flight, hotel, transfers and other related travel details and/or other information that is necessary for the delivery of our services to you.
Sensitive information
We will only collect your sensitive information with your consent and where information is reasonably necessary for one or more of our services.
We will only use and disclose your sensitive information for the primary purpose for which it was collected or a purpose that is directly related to this primary purpose and is reasonably expected. You consent to the use and disclosure on this basis. If for example we have collected information about any medical conditions you are suffering, then you consent to us disclosing this information to our service providers (for example ground operators) if they reasonably have a need to know such information in order to safely supply services for your benefit.
We will not otherwise collect, use or disclose sensitive information about you unless required to do so by law.
In this Privacy Policy, "sensitive information" has the same meaning as defined by section 6 of the Privacy Act. Sensitive information may include information or an opinion about your health information.
Collection of personal information
In the course of regular business activity and in order to use the website and/or our services, ITC Pacific will from time to time collect, require and otherwise deal with your personal and/or sensitive information.
If you do not want any of your personal and/or sensitive information collected, you can stop using the website and/or our services at any time (subject to applicable contracts), however we may not be able to provide our services to you.
ITC Pacific collects personal and/or sensitive information from individuals in numerous ways, including for example when an individual:
-
Visits or uses the website or social media channels;
-
Contracts or corresponds with ITC Pacific in person or via telephone, email, mail or directly through our website;
-
Makes a purchase(s) from ITC Pacific or enquires about travel arrangements with us;
-
Makes payment of an invoice; or
-
Provides us with personal and/or sensitive information, including for example allowing information on social media to be shared with us or signing up for a promotion or competition or when you subscribe to receive marketing from us (e.g. a newsletter).
We may also collect personal and/or sensitive information about you from third parties or where ITC Pacific is required to do so by law.
ITC Pacific does not generally take steps to:
-
Verify personal and/or sensitive information about any individual disclosed to it; or
-
Seek additional personal and/or sensitive information about any individual on the basis of information disclosed to it, except in circumstances where it is reasonably necessary for us to do so or as may be required by law.
We note that in certain circumstances, if you do not consent to the use of your personal and/or sensitive information as outlined in this Privacy Policy or at the time of collection, you may not have access to our services and we might not be able to provide you with our services.
Personal information about children and young people
Some of our services, including group and school-based travel arranged through ITC Pacific, involve the collection of personal and/or sensitive information about children and young people. Where this occurs, we generally collect this information from, and with the consent of, a parent, guardian, teacher or school acting on behalf of the child or young person, rather than directly from them.
We only collect the personal and/or sensitive information about children and young people that is reasonably necessary to arrange, manage and safely deliver the relevant travel service, which may include name, date of birth, emergency contact details, and relevant medical, dietary or health information required to ensure their safety and wellbeing while travelling.
We are committed to handling the personal information of children and young people in a manner appropriate to their vulnerability. We will review and, where necessary, update this Privacy Policy to reflect the Children's Online Privacy Code once it is developed and registered by the Office of the Australian Information Commissioner (OAIC).
Use of personal information
Any personal information collected by ITC Pacific will be used for the purpose for which it was given to us, for purposes which are directly related to those purposes, for purposes which you have otherwise consented to, or for other purposes in accordance with the Privacy Act, law or this Privacy Policy.
Use of technology and AI-enabled tools
We may use approved technology tools, including AI-enabled tools, to help prepare and manage your travel arrangements. These tools are used within our information security and privacy controls. Any output produced with these tools is reviewed by our staff before it is relied upon or provided to you. We remain responsible for the accuracy of the information and services we provide.
Where the use of these tools involves the transfer of personal information to systems located outside Australia, this is addressed further under “Overseas disclosure” below.
Disclosure
We may disclose personal and/or sensitive information we hold to:
-
Our directors, officers, employees and other associated companies or related entities or organisations;
-
Our contracted service providers;
-
Credit card providers, credit reporting and fraud checking agencies;
-
Government, regulatory and law enforcement agencies where the disclosure is required or authorised by law;
-
Our professional advisors, including our accountants, auditors and lawyers;
-
Third party suppliers of products or services which you have selected (such as airlines, ground operators, hotels and insurance providers);
-
Third party travel service providers who assist in fulfilling the booking you have made;
-
Our online booking facility operator and host and others who assist in providing these services;
-
Third party sponsors or co-sponsors of promotions on our website. Only information collected during a promotion will be disclosed to these parties;
-
Third parties when we contract out some of our functions and activities, such as call centre operators. In these circumstances, we prohibit third parties from using your personal information, except for the specific purpose for which we supply it. Where applicable, we may handle or disclose personal information relying on applicable exemptions under the Privacy Act, including but not limited to, the related bodies corporate exemption and the employee exemption.
Overseas disclosure
We may disclose personal and/or sensitive information to overseas recipients in order to provide services. Generally, we will only disclose your personal information to these overseas recipients in connection with our services such as facilitation or fulfilment of your travel booking and/or to enable the performance of administrative and technical services by them on our behalf.
We do not operate our own overseas servers or data centres. However, we store and back up personal information using cloud-based systems such as Microsoft 365 and SharePoint, which are provided by global technology companies. Depending on how these providers operate their infrastructure, information may be stored, backed up or processed in countries outside Australia, which may include the United States. Where practicable, we will identify the relevant countries; however, it is not always practicable to specify a particular country, as our cloud service providers may store or process information across multiple locations depending on their own operational requirements.
Before disclosing your personal information to an overseas recipient, we take reasonable steps to ensure that the overseas recipient does not breach the Australian Privacy Principles in relation to that information, except where an exception under the Privacy Act applies (for example, where you have consented to the disclosure after being expressly informed that we do not require the overseas recipient to comply with the Australian Privacy Principles).
Storage and security
ITC Pacific will take reasonable steps to protect the personal and/or sensitive information we hold from misuse, interference, loss and unauthorised access, modification or disclosure. ITC Pacific may store personal information physically and/or electronically, including using secure cloud-based systems such as Microsoft 365 and SharePoint. This includes technical measures, such as encryption and access controls, and organisational measures, such as staff training and internal policies, appropriate to the sensitivity of the information involved.
Retention and destruction of personal information
We will only retain your personal and/or sensitive information for as long as is reasonably necessary to fulfil the purpose for which it was collected, to comply with our contractual and legal obligations (for example, taxation and record-keeping requirements), or to resolve any disputes.
Where we no longer require your personal and/or sensitive information for any purpose for which it may be used or disclosed under this Privacy Policy or the Privacy Act, we will take reasonable steps to destroy the information or ensure that it is de-identified.
Data breach notification
We have processes in place to identify, assess and respond to data breaches involving personal information that we hold.
If we experience a data breach that is likely to result in serious harm to any individual whose personal information is involved (an eligible data breach), we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) in accordance with the Notifiable Data Breaches scheme under Part IIIC of the Privacy Act.
Cookies
To ensure we are meeting the needs and requirements of our website users, and to continue to develop our online services, we may collect aggregated information through the use of cookies. We may use cookies to collect data about your visit and to allow you to navigate from page to page without having to reload each time.
You may control, refuse and/or delete cookies by using the appropriate setting on your browser as you wish, however, if you do so you may not be able to access portions of our website.
Links - external website
Please note that our website may contain links to other external websites. These links are provided as a convenience to you. ITC Pacific is not affiliated with these sites and accordingly has no control over, and is not responsible for, their content, activities, privacy practice or other policies. Links to external websites are not covered by this Privacy Policy.
Direct marketing communications
We may contact you using the contact details, which you provide to us in order to provide you with direct marketing communications about our services in accordance with the law.
You may opt out of receiving direct marketing communications from us at any time by contacting us using the details set out below or by functionality within such communications.
Our marketing communications sent by email or SMS are provided in accordance with the Spam Act 2003 (Cth), and any telemarketing calls we make are provided in accordance with the Do Not Call Register Act 2006 (Cth).
Changes to privacy policy
Please note that our website may contain links to other external websites. These links are provided as a convenience to you. ITC Pacific is not affiliated with these sites and accordingly has no control over, and is not responsible for, their content, activities, privacy practice or other policies. Links to external websites are not covered by this Privacy Policy.
Access to personal information
If you would like access to your personal and/or sensitive information, please contact our office directly via the contact details found below under "Contact".
Correction to personal information
In the event ITC Pacific holds personal and/or sensitive information about you and you believe that any of the information we hold about you is inaccurate, out of date, incomplete, please make a request to our office for correction. Contact details can be found below.
Contact
If you have any questions or concerns about how we handle your personal or sensitive information or if you wish to access or amend personal and/or sensitive information we hold about you, please make a request in writing.
All correspondence should be directed to:
Post: PO Box 1354, Milton, 4064
Email: groups@snonski.com.au
Phone: 1300 889 076
If you decide to contact us for any of the reasons above, we request that you provide us with sufficient details regarding your reason for getting in touch with us.
We note that if necessary, we will ask you to provide us with a copy of your ID, passport or other valid identity document.
Complaints
If you have any enquiries about this Privacy Policy or wish to make a complaint about a matter relating to privacy please contact us using the details set out above (refer to "Contact").
We will investigate and consider any complaint received by us and a response will be provided to the complainant as soon as practicable.
If you are not satisfied with the way in which we handle your inquiry or complaint in regard to your personal information, if applicable, you may contact the Office of the Australian Information Commissioner ("OAIC"). Contact details for the OAIC can be found at www.oaic.gov.au.
In certain circumstances, you may also have other legal remedies available to you, including under the statutory tort for serious invasions of privacy contained in the Privacy Act.