Travello Pty LTD
ABN: 80 600 440 953
PRIVACY POLICY (as at 25 May 2018)
Background to this Privacy Policy
Travello Pty Ltd (we/us)
takes the issue of the privacy of your Personal Data seriously.
Personal data means any information relating to
an identified or identifiable natural person ('Data Subject') and an
identifiable person is one who can be identified, directly or indirectly, in
particular by reference to an identification number or to one or more factors
specific to his physical, physiological, mental, economic, cultural or social
identity.
This privacy policy applies to your permitted
access to this website and/or the use of the Travello
App as regards to any Personal Data that may be collected from you or provided
by you during such access or as a result of your access to our website or as a
result of your using the Travello App.
This privacy policy has been published to provide
to you a clear and concise outline of how and when Personal Data is collected,
stored and/or used by us.
IF
YOU USE ANY SERVICE PROVIDED BY US OR YOU PROVIDE VOLUNTARILY ANY PERSONAL DATA
TO US THEN YOU SPECIFICALLY REPRESENT TO US THAT YOU HAVE READ, UNDERSTOOD AND
CONSENTED TO THE COLLECTION, USE AND STORAGE OF YOUR PERSONAL DATA.
From time to time, we may change the provisions
of this Privacy Policy without specific notice to you. We strongly recommend that you check this
document on a regular basis to ensure that you understand the obligations
detailed in this Privacy Policy. This
Privacy Policy will be accessible by you either through our website or through
the Travello App.
Personal Information You Provide Us
We do not generally collect Personal Data about
you except when you provide that information voluntarily and in accordance with
our various application forms that are available on this web site or through
the Travello App.
Once you have provided Personal Data it will only be used for purposes
of registration so that we can forward to you the information that you have
requested via the Travello App. In other words, all collected Personal Data
about you will be used solely for the purpose to which you have consented. Such information will not be transferred to
other parties unless you are fully informed prior to such transference and you
have agreed to such transference, unless we are required by law to transfer the
information to an authorised organisation.
The above only relates to your Personal Data and
does not relate to any aggregated or other information that may be developed or
created internally by us, provided this other information cannot later be used
or combined with other information to identify you in any way whatsoever and
therefore maintains our privacy commitment to you.
The information we may collect which we
collectively call Personal data is:
●
Basic user information, such as your name, username, gender,
birth date, email address, mailing address, billing address, and phone number;
●
Messages and interactive post information from the Travello App feed, such as messages to other users and
information you provide in connection with those activities and events;
●
Other background, contact and demographic information, such
other interests and self-descriptions you choose to provide;
●
Debit and Credit card information which may be processed by a
third party engaged by us to validate such credit and debit card
information. We do not store such
information as that information is passed through to our debit and credit card
validator.
●
Travello has a legitimate reason to add your email address to Travello’s email marketing database at the time of account
creation in Travello so that Travello
can send you the Welcome Email which has instructions & tips for using the
app for the first time. However as a subscriber you
have always had and always will have the opportunity to unsubscribe at any time
from the unsubscribe link at the bottom of all our emails. You are also able to
update your email marketing preferences from that same footer link of all our
emails now too.
●
Information We May
Collect Automatically
When you access or use our Services, we may also automatically
collect information about you, including:
●
Usage
Information. We collect information about your activity through our services.
For example, we may collect information about:
●
how you interact with our services, such as which posts you
like, which hashtags you search on the feed, what type of groups or interests
you use.
●
how you communicate with other users, such as their names, the
time and date of your communications, the number of messages you exchange with
your friends, which friends you exchange messages with the most, and your
interactions with messages;
●
Content
Information. We collect content you create on our services, such as posts,
meetups etc. and information about the content you create or provide, such as
if recipients have viewed the content.
We also collect the metadata that is associated with the content.
●
Device
Phonebook. Because the Service is all about communicating with friends,
we may—with your permission—collect information from your device’s phonebook.
●
Camera
and Photos. Many of our services require us to collect images and other
information from your device’s camera and photos. For example, you won’t be
able to post on the feed or upload photos from your camera roll unless we can
access your camera or photos.
●
Location
Information: We may collect information about your
location when you access our mobile application or website, or
otherwise consent to the collection of this information. With your
permission, we may also collect information about your precise location using
methods that include GPS, wireless networks, cell towers, Wi-Fi access points.
●
Device
Information: We may collect device-specific information when you access our
Services, including your hardware model, operating system and version, unique
device identifiers, mobile network information and information about the
device’s interaction with our Services, browser type, language and time zone,
information about your wireless and mobile network connections, such as mobile
phone number, service provider, and signal strength
●
Log
Information: We may collect log information about how you access or use our
Services, including your access times, browser type and language, Internet
Service Provider and Internet Protocol (“IP”) address.
●
Information
Collected by Cookies and other Tracking Technologies: We
may automatically collect information using cookies, web beacons (also known as
“tracking gifs,” “pixel tags” and “tracking pixels”) and other tracking
technologies to, among other things, improve our Services and your experience,
monitor user activity, count visits, understand usage and campaign
effectiveness, and tell if an email has been opened and acted upon. Most
web browsers are set to accept cookies by default. If you prefer, you can
usually remove or reject browser cookies through the settings on your browser
or device. Keep in mind, though, that removing or rejecting cookies could
affect the availability and functionality of our services. .
Information We Collect from
Third Parties
We may collect information that other users provide about you
when they use our services. For example, if another user allows us to collect
information from their device phonebook—and you’re one of that user’s
contacts—we may combine the information we collect from that user’s phonebook
with other information we have collected about you.
We may also obtain information from third parties. Here are a
few examples:
●
If you create or log into your Travello
account through a third-party social networking site, we will have access to
certain information from that site, such as your name, profile picture,
connections and other account information in accordance with the authorization
procedures determined by such third-party social networking site.
●
Advertisers may let us know you installed the Travello App so we can determine whether we showed you an
ad for it.
If you interact with one of our advertisers, they may share
information with us to help target or measure the performance of ads.
Use & Disclosure of Personal Data
Unless you have advised us not to do so, your
Personal Data may be shared:
●
With
other Travello users. We may share
the following information with other Travello users:
o information
about you, such as your username or name, and nationality.
o information
about how you have interacted with our services, such as your Travello followers, the names of other users you are
friends with, and other information that will help Travello
users understand your connections with others using our services. For example,
because it may not be clear whether a new friend request comes from someone you
actually know, we may share whether you and the requestor have Travello friends in common.
o any
additional information you have directed us to share.
o content
you post or send. How widely your content is shared depends on your personal
settings and the type of service you are using.
●
With
all Travello users our business partners, and the
general public. We may share the following information with all users as well
as with our business partners and the general public:
o public
information like your name, username and profile pictures.
●
With
third parties. We may share your information with the following third parties:
o With service providers. We may share
information about you with service providers who perform services on our
behalf.
o With business partners. We may share
information about you with business partners that provide services and
functionality.
o With third parties for legal reasons. We may share
information about you if we reasonably believe that disclosing the information
is needed to:
▪
comply with any valid legal process, governmental request, or
applicable law, rule, or regulation.
▪
investigate, remedy, or enforce potential Terms of Service
violations.
▪
protect the rights, property, and safety of us, our users, or
others.
▪
detect and resolve any fraud or security concerns.
o With third parties as part of a merger or acquisition. If Travello gets involved in a merger, asset sale, financing,
liquidation or bankruptcy, or acquisition of all or some portion of our
business to another company, we may share your information with that company
before and after the transaction closes.
We may also share with third
parties—such as advertisers—aggregated, non-personally identifiable, or
de-identified information, which cannot reasonably be identified as you.
It is our goal to only use the information you
provide us in a manner that better provides our services to you such as:
●
develop, operate, improve, deliver, maintain, and protect our
products and services.
●
send you communications, including by email. For example, we may
use email to respond to support inquiries or to share information about our
products, services, and promotional offers that we think may interest you.
●
monitor and analyse trends and usage.
●
personalize our
services by, among other things,
suggesting friends or profile information, or customizing the content we show
you, including ads.
●
contextualize your experience by, among other things, tagging
post content using your precise location information (if, of course, you’ve
given us permission to collect that information) and applying other labels
based on the content.
●
provide and improve ad targeting and measurement, including
through the use of your precise location information (again, if you’ve given us
permission to collect that information), both on and off our services. See the Control Over
Your Information section below for more information and your
choices.
●
enhance the safety and security of our products and services.
●
verify your identity and reduce the risk of fraud or other
unauthorized or illegal activity.
●
use information we’ve collected from cookies and other
technology to enhance our services and your experience with them.
●
enforce our Terms of Service and other usage policies.
In addition we undertake
not to sell, rent or trade your Personal Data.
We will not disclose information about you unless the disclosure is:
Personal Data Quality
It is our goal to ensure that your Personal Data
is correct, accurate, relevant, timely and secure. For us to meet this goal would you please
ensure that if there is any change to any of the details you have provided to
us, you will promptly advise us so that we can continue to provide the services
that we have agreed. Further, if it
comes to your attention that we possess certain information about you that is
not correct, accurate, complete or up-to-date, then contact us and we will use
all reasonable efforts to correct the information we have about you. Such corrections may take time as we will
only correct such information once we have verified that the new information is
correct.
Personal Data
Security
We undertake to use our best endeavours to keep
secure your Personal Data and we further undertake to take all reasonable
precautions to protect that information against any unauthorised loss, misuse
or alteration.
Although we strive to employ reasonable
protections for your information that are appropriate to its sensitivity, we do
not guarantee or warrant the security of the information you share with us and
we are not responsible for the theft, destruction, loss or inadvertent
disclosure of your information or content. No system is 100% secure. The
Services uses industry standard Secure Sockets Layer (SSL) technology to allow
for the encryption of personal information and debit and credit card numbers
that is transmitted between you and us.
Access to Personal Information
If you request us to provide you with access to
personal information we hold about you, then we will provide such information
in a timely manner to you.
Unauthorised Access to Personal Data (Data Breach)
For
the purposes of this Privacy Policy a “Data Breach” is a breach of the security
concerning the protection of Personal Data which leads to the accidental or
unlawful destruction, loss, alteration, unauthorised disclosure or access to
your Personal Data transmitted, stored or otherwise processed by us.
If
you are:
●
a resident of a jurisdiction that is a member of the European
Union and the GDPR applies to your Personal Data then we will without undue
delay after we become aware of a Data Breach and where feasible within 72 hours
after becoming aware of the Data Breach notify the Office of the Australian
Information Commissioner (the Australian Supervisory Authority) in writing of
the Data Breach unless the Data Breach is unlikely to result in risk to your rights
and freedoms. Further we will attempt to
notify you within a reasonable time after becoming aware of the Data Breach if
the Data Breach involves your Personal Data.
●
not a resident of a jurisdiction that is a member of the European
Union and the GDPR does not apply to your Personal Data then we will without
undue delay after we become aware of a Data Breach notify the Office of the
Australian Information Commissioner if the Data Breach involves your Personal
Data and such breach is likely to result in serious harm to you. Further we will attempt to notify you within
a reasonable time after becoming aware of the Data Breach if the Data Breach
involves your Personal Data.
Right to be Forgotten
If you are a resident of a jurisdiction that is a
member of the European Union and the GDPR applies to your Personal Data, then:
●
you may by email to us advise us that your consent is withdrawn;
and
●
we will subject to the requirements of the GDPR and subject to any
binding laws upon us to the contrary and subject to validating your request use
all reasonable efforts to remove any Personal Data about you within a
reasonable time commencing on the date that you advise us that your consent
concerning the collection, storage and usage of your Personal Data is
withdrawn.
Nothing in this clause requires us to breach any
law in Australia that requires us to keep your Personal Data such as taxation
laws.
Most browsers are initially set to accept
cookies. If you'd prefer, you can set yours to refuse cookies or to alert you
when cookies are being sent. However, it is possible that some parts of the web
site and the services provided via this website, such as the member-only areas,
will not function properly if you do so.
Changes to this
Policy
We reserve the right to make changes to this privacy
policy from time to time for any reason.
We will accordingly make those changes and display those changes on this
website. This privacy statement was last
amended on 25 May 2018.
Contact us about privacy
If you would like to contact us as regards to
anything concerning this privacy policy, or if you think that we have breached
any aspect of this privacy policy, then please contact us by:
E-mail: marketing@travello.com.au
or
writing to:
Customer Relations &
Privacy Manager
Travello Pty Ltd
88 Brunswick Street
Fortitude Valley
Brisbane