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Just Cruises Privacy Policy

Just Cruises is an Australian Fully Licensed Travel Agency License: 3298142 registered in Brisbane Australia. (ABN: 24630510758)

We are subject to the Australian Privacy Principles in the Privacy Act 1988. Your privacy is important to us and as such, please see the advice in this document how we manage your personal information.

We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.

By providing personal information to us (either directly or allowing another person to do so on your behalf), you agree that this Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Policy. This can be in person, over the phone, via email, letter, fax or via our website.

If you do not agree with any part of this Policy, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw consent that you have given under this Policy, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveler’s full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.

There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Policy. Where this occurs we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.

Collection and use of personal information: Personal information has the meaning given under your local data protection law. Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.

The type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf. For example, we may collect details such as your name, residential/mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), passport details, loyalty program / frequent flyer details, information about 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. cruise lines, airlines and accommodation or tour providers). When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us.

In some circumstances, we may collect personal information from you which may be regarded as sensitive information under your local data protection laws.  Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, criminal record and the alleged commission of an offence, passwords and financial information and health information.  We will only collect sensitive information in compliance with your local data protection laws, with your consent and/or where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorised to do so by law.  To the extent permitted or required under your local data protection laws, you consent to us using and disclosing your sensitive information for the purpose for which it was collected, unless we subsequently receive your consent to use it for another purpose. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages, in which case you consent to us using and disclosing that information in connection with facilitating your request. We will not use sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.

Just Cruises’, its employees’ and contractors’  primary course of business is the marketing and promotion of products and suppliers of travel and making and managing travel arrangements for you.

In the course of this business, we can collect personal information from you or from people nominated by you, which we use to make and manage travel arrangements on your behalf.  This can be in person, over the phone, via email, letter, fax or 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 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. You can opt out of these by contacting us or by clicking ‘unsubscribe’ on these newsletters. Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.

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. By providing your personal information to us, either directly or through a family member, employer or other agent or representative in connection with a travel booking or related service, you will be deemed to have consented to your personal information being collected by us and used and disclosed in accordance with this Policy.

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

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

When we act as agent for a travel service provider: When we book and otherwise arrange travel related products and services for you, we usually do so as agent for or on behalf of travel service providers. In this case, we usually collect personal information about you both for our internal purposes as described in this Policy, including the purpose of us processing your booking, and for the travel service provider for whom we act as agent for their internal purposes (e.g. to provide you with the booked services).  As an agent, all bookings are made on your behalf subject to the terms and conditions, including privacy policy, imposed by these travel service providers.  We will provide you with copies of all relevant travel service provider terms, conditions and privacy policies on request.

Accordingly, you are deemed to consent to the collection, use and disclosure of your personal information by us to the relevant travel service providers, and the use and disclosure of your personal information by the relevant travel service providers, for the purposes set out in this Policy and, to the extent permitted under your local data protection laws, for other purposes specified in their privacy policy. For example, if you book a cruise through us, then under this Policy you consent to us collecting your personal information and disclosing that information to the cruise line to enable your cruise to be booked and for the cruise line  to provide the cruise service to you, and, to the extent permitted under your local data protection laws, for other purposes specified in their privacy policy.

How do we use and disclose your personal information? We will only use your personal information for the purposes that it has been collected or where it is required by law. Your implied authority to disclose your information to a third party is accepted for the express purpose of providing  you with travel advice and/or to assist you with booking travel and/or travel related products and services.

By continuing to use our services and/or by providing us with personal information (or allowing another person to do so on your behalf), you consent to us using and disclosing your personal information for the purpose for which it was collected, and, where permitted by your local data protection laws, for any related secondary purpose which we believe you would reasonably expect.

The purposes for which we collect personal information, and those secondary purposes which we consider to be directly related, include: – developing and improving our products and services; – servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable us  to service you better or presenting options on our website we think may interest you based on your browsing and preferences; – 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 accounting and administration; – to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel; 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).

Promotional/marketing material: Where permitted by local 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 (including online targeted 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. 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 contact Just Cruises at admin@justcruises.com.au or call us 1800 284 112.  You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM or other form of electronic marketing.

We take all reasonable steps to protect your information including electronic password protection, a central server system for storage of your information and a secure 128 bit encryption connection for transmission of credit card information.

We take the security of your personal information very seriously and have appropriate physical, technical and administrative procedures in place to help protect your personal information from unauthorized access, use or disclosure as required by law in Australia. 

Is personal information disclosed to third parties? We may disclose your personal information to third parties, as set out below, and in accordance with your local data protection laws. By continuing to use our services and/or by providing us with your personal information (or allowing another person to do so on your behalf), you consent to that personal information being processed, transferred and/or disclosed by us for the purpose for which it was collected and, where permitted by your local data protection laws, for any related secondary purpose which we believe you would reasonably expect. 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 contractors, suppliers and service providers, including without limitation: – in each of the circumstances set out in the section titled “How do we use and disclose your personal information?”; – suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting provider(s) 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); – our related entities and brands; – travel service providers such as travel wholesalers, cruise lines, tour operators, airlines, hotels, car rental companies, transfer handlers and other related 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; – 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 authorized 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; and 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.

For more information in relation to collection by travel service providers and their privacy practices and policies, see the section above titled, “When we act as agent”.

Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including applicable privacy / data protection laws).

Social Media Integrations Our websites and mobile applications may use social media features and widgets (such as “Like” and “Share” buttons/widgets) (“SM Features”).  These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application.  SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.

If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them. Similarly, your interactions with the SM Features may be recorded by the third party.  In addition, the third party company may send us information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to you via the third party social media platform.  You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third party social media platform.

Your interactions with these SM Features are governed by the privacy policy of the third party company providing them.  For more information about the data practices of these third party companies, and to find out more about what data is collected about you and how the third party uses such data, please refer to their privacy policy directly.

Linked Sites Our websites 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.

Your rights You can request access to your personal information at any time.  Should a request for access be refused, we will advise you as soon as practicable.

We ensure your information we hold is accurate, complete and current.  If you believe any information we hold about you to be incorrect or incomplete, you can ask us to correct it and we will do so in a reasonable timeframe.

Feedback/Complaints/Contact If you have any enquiries, comments or complaints about this Policy or our handling of your personal information, please contact your consultant or contact us at:

Attention:        Administration Manager Address:          PO Box 1176, Mount Gravatt Queensland 4122 Telephone:      +61 7 34341400 Email:              admin@justcruises.com.au

We will respond to any enquiries or complaints received as soon as practicable.

Further information about this policy. 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 at http://justcruises.com.au/privacy_policy.htm 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.

For any further information regarding privacy in general, please contact the Office of the Australian Information Commissioner on 1300 363 992 or http://www.oaic.gov.au/

Last updated 31 May 2017