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SWHG PRIVACY POLICY

SWHG PRIVACY POLICY

Introduction

StayWell Holdings Pty Limited (ACN 620 184 661) and its related companies and affiliates including third party owners and operators of hotels operating under a StayWell Brand (StayWell Group) are subject to privacy laws in each of the countries that they operate which set standards for the collection, handling and storage of personal information. We are committed to protecting the privacy, accuracy and reliability of personal information provided to us by our customers.

For the purposes of this Privacy Policy, StayWell Brand means StayWell, The Prince Akatoki, Policy, Park Regis, Leisure Inn Plus or Leisure Inn.

This Privacy Policy does not cover personal information collected or held by us about our employees and is to be read subject to any overriding provisions of law or contract.

This Privacy Policy is designed to inform you when StayWell Group will collect your personal information, how StayWell Group collects that information, the types of personal information that StayWell Group collects and how that personal information will be used, disclosed, transferred and stored when you access the StayWell Group website or provide your personal information to us.  This policy aims to answer common questions and address specific issues associated with StayWell Group’s commitment to protecting your privacy within the on-line environment and in your dealings with StayWell Group.

When will we collect your personal information

StayWell Group will collect, store and deal with your personal information where the collection, storage or dealing with your personal information is reasonably necessary for us to undertake our business activities and functions, where it is required by law or where it is permitted by law.

We may collect your personal information in order to:

  • Process a booking or reservation you make;
  • Provide goods or services to you;
  • Respond to your queries;
  • Conduct surveys, direct/email marketing, promotions or competitions;
  • Conduct our business operations;
  • Comply with legal requirements; and
  • Analyse customer feedback relate to our goods and services.

How do we collect your personal information

We collect information in a variety of ways including:

  • When you make a booking directly with us either online, by phone, by email, by fax or in person;
  • When you make a booking through a third party (eg an online travel agent);
  • By joining our loyalty program – Stay Well Rewards;
  • By subscribing to our e-newsletter;
  • By acquiring property in one of the mixed use or hotel strata complexes which we operate; or
  • By using our hotel Wi-Fi.

We may also collect additional personal information from you if you access our website or any of our mobile applications.

We also require guests to provide photo identification and credit card pre-authorisation on check-in at our properties for guest verification purposes, payment security purposes and to meet legal obligations.  All information and documentation collected for these purposes will be dealt with in accordance with this privacy policy and StayWell Group terms and conditions.  This information is stored in accordance with StayWell Group terms and conditions.

What personal information do we collect

StayWell Group’s services may require the use of personal details and preferences of our customers to enhance our relationship with you. This may include information regarding your name, gender, email address, phone number, mailing address, date of birth, information about likes and dislikes, credit card information or other information needed to complete a reservation with us or to book services with us.  On check-in we will also take a copy of photo identification for security purposes (passport or drivers licence).  We do not generally collect sensitive information from you; however, if you provide such information to us, we will only collect that information with your express consent and only where such information is reasonably required in order for us to provide our products or services to you (such as special access or assistance requirement due to a health condition). We shall not disclose sensitive information to any other party without your consent.

The additional personal information we may collect if you access our website or any of our mobile applications may include:

  • server address / IP address;
  • date and time of visit;
  • pages visited;
  • documents downloaded;
  • the site you visited prior to visiting our website;
  • the browser and device that you are using to access our website;
  • if you have visited our website before;
  • tracking user preferences; and
  • demographic data.

StayWell Group will not collect identifiable personal information from users of the StayWell Group website (other than the additional items listed in these bullet points) except where users specifically and knowingly submit personal details.  You may visit the StayWell Group website without telling us who you are.

The StayWell Group website offers a number of interactive facilities and tools.  Some of them can be utilised without the need to submit personal information details.  Others need these details to be submitted in order for you to utilise them.

Cookies and Other Data

We may also collect “Other Data” that generally do not reveal your specific identity or do not directly relate to an individual. To the extent Other Data reveal your specific identity or relate to an individual, we will treat Other Data as Personal Data. Other Data includes:

Your browser or device
We collect certain data through your browser or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, internet browser type and version and the name and version of the Online Services (such as the Apps) you are using. We use this data to ensure that the Online Services function properly.

Your use of Apps
We collect certain data when you download and use an App, such as App usage data, the date and time the App on your device accesses our servers, and what data and files have been downloaded to the App based on your device number. We use this data to ensure that the Online Services function properly. Our Apps may contain software development kits (SDKs) from third parties which may collect and transmit Other Data to enable various features in the App. We may also collect mobile device advertising identifiers to enhance and personalise your experience and deliver relevant products, content or ads to show you on our Website, Apps or external advertising.

Cookies
We collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect browser type, time spent on the Online Services, pages visited, referring URL, language preferences and other aggregated traffic data. We use functional cookies to obtain the data for security purposes, to facilitate navigation, to display content more effectively, to collect statistical data, to personalise your experience while using the Online Services and to recognise your computer to assist your use of the Online Services. We also gather statistical cookie data about use of the Online Services to continually improve design and functionality, understand how they are used and assist us with resolving questions. Advertising cookies further allow us to select which advertisements or offers are most likely to appeal to you and display them while you are using the Online Services. We also use them to send marketing emails and to track responses to online advertisements and marketing emails. You can learn more about cookies here

Opt Out of Cookies
You can choose whether to accept cookies by changing the settings on your browser or by managing your tracking preferences by clicking on “Tracking Preferences” located at the bottom of our website. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Online Services. For example, you will not receive advertising or other offers from us that are relevant to your interests and needs.

Third Party Advertising
We may use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Online Services, other websites, or online services. To serve such advertisements, these companies place or recognize a unique cookie on your browser (including through use of pixel tags). If you would like more information about this practice, and to learn about your choices in connection with it, please click here

Pixel Tags and other similar technologies
We collect data from pixel tags (also known as web beacons and clear GIFs), which are used with some Online Services to, among other things, track the actions of users of the Online Services (including email recipients), measure the success of our marketing campaigns and compile statistics about usage of the Online Services.

Analytics
We collect data through Google Analytics, which use cookies and technologies to collect and analyze data about use of the Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by visiting their site here and you can opt out by downloading the Google Analytics opt out browser add-on, available here.

Your IP Address
We collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with the time of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.

Aggregated And Segmented Data
We may aggregate data that we collected and this aggregated data will not personally identify you or any other user. We may also use both Personal Data and Other Data to divide customers into segments, or groups, in order to provide more relevant advertising.

Location-Based Services
We may collect the precise physical location of your device by using satellite, cell phone tower, Wi-Fi signals, or other technologies. We will collect this data if you opt-in through the App or other program (either during your initial login or later) to improve special offers and to enable location-driven capabilities on your mobile device. If you have opted-in to share your location, the App or other program will continue to collect location data based on how you chose to share the data.

Location Opt-Out
The user can specify via the device’s operating system to always share location, only when the App is in use, or never. If you choose only when the App is in use, we will have access to the data until you log off or close the application.

How do we use your personal information

We may use your personal information to:

  • Provide goods or services to you (including trying to meet your preferences and managing your stay) or arrange for our business partners to provide goods and services to you;
  • Provide services to strata corporations which we provide caretaking and letting services to;
  • Conduct credit checks and bill you for your stay or for services provided to you;
  • Undertake marketing and promotions to you (unless you opt out of our database – see below, or unless relevant laws applicable to you require you to opt into our database and you do not do so);
  • Provide offers to you;
  • Undertake surveys seeking to improve the delivery of our services (unless you opt out of our database – see below, or unless relevant laws applicable to you require you to opt into our database and you do not do so); or
  • Comply with our legal obligations or improve our policies and procedures.

StayWell Group may also use your information to allow us to enhance our relationship with you.  Any personal information collected by StayWell Group may be used in marketing campaigns or product and strategy development to ensure our services are tailored to suit your needs.  This information is fundamental in ensuring our marketing programs are meaningful to you.  If you have subscribed via email, these may include product and service news or deals.  If you have provided your postal address, you may receive periodic mailings of information on new products and services, or upcoming events.  Our offers will be based upon your information provided, including history as a customer.

We will not usually disclose your personal information to a third party except for the purposes set out above (which may include providing your information to third parties who are our business partners or contractors who assist us to provide goods and services to you or business partners whose goods and services have been packaged with our goods and services).

We may disclose personal information to relevant government authorities in accordance with applicable legal requirements eg if we reasonably believe that there is a threat to an individual’s life, health or safety, or public health or safety.  If we have reason to suspect that unlawful activity has been, is being or may be engaged in, personal information may be used or disclosed as a necessary part of any investigation and reporting to relevant persons or government authorities.

We may also disclose your personal information to professional advisers if we consider it is necessary to obtain advice.  We may also disclose your personal information to our insurer or insurance broker if an incident occurs during your stay.

We may also disclose your personal information to a third party if we are compelled by law to do so (eg if we receive a subpoena which requires the provision of that information).

Finally, we may disclose your personal information to a third party if you consent to us doing so.

Links to third party websites

The StayWell Group website contains various links to third party websites. These links are maintained to improve the service we offer and expand the information readily available to you.  Third party websites are NOT subject to StayWell Group’s Privacy Policies and, therefore, you should familiarise yourself with the privacy and security policies operating for such sites.  Third party website operators are responsible for their own privacy practices.

Please remember that when you use a link to go from the StayWell Group website to another website, the StayWell Group Privacy Policies are no longer in effect.  Your browsing and interaction on these third party websites are subject to the terms & conditions and privacy rules and policies applicable to those sites.

Failure to provide your personal information

If you fail to provide us with your personal information or the personal information you provide to us is inaccurate, it may affect our ability to provide you with our products and services.

Transfer of your personal information internationally

StayWell Group’s group central database is in Australia.  In addition, each hotel maintains a hotel database where that hotel is located.  Each country has different privacy and data laws and the data held in each country is held in accordance with the laws applicable to the country in which the database is located.  StayWell Group central database is administered in accordance with Australian law and also in accordance with EU legal requirements applicable to the holding of data for EU citizens.  StayWell Group operates hotels internationally.  By making a reservation with a StayWell Group hotel or otherwise providing your personal data to us as set out in this Privacy Policy, you consent to us transferring your personal data internationally for the reasons and purposes set out in this privacy policy.  StayWell Group will take reasonable steps to ensure the recipients of such data deal with it in accordance with the terms of this privacy policy.

Security of your personal information

The security of your personal information is important to us. We may store your personal information in different ways, including in paper form, electronic form, telephone recordings and utilising secure document retention services (including those located off-site).

We take reasonable measures to ensure that your personal information is stored safely to protect it from misuse, loss, unauthorised access, modification or disclosure, including electronic (firewalls and access controls) and physical security measures.

Notwithstanding these reasonable measures, the confidentiality of any communication or material transmitted to or from us via our website, apps or email, cannot be guaranteed.  Please contact our Privacy Officer (details below) if you believe that the confidentiality of your personal data or communications has been compromised.

Your Rights

By providing your personal information to us, you may receive promotional mailing and offers.  In countries where the law requires you to opt in before we send promotional mailing and offers to you, we will only send such material and offers to you if you opt in and consent to us sending such material and offers to you.

If you would prefer not to receive these communications, you have the right to unsubscribe from StayWell Group’s mailing list.  A choice to unsubscribe will be provided on these occasions.  Alternatively, you may write to StayWell Group to request that your information be removed from our marketing database at any time.  You may also request access to information which we hold regarding you at any time as well as having the right to request that we update your personal information.

You may request access to the personal information which we hold relating to you at any time by contacting our privacy officer (see below).  We will respond to any such request for access to personal information within a reasonable time frame and will provide you access to the personal information that we hold that belongs to you, unless we are permitted not to do so by law.  If we decline to provide you with access to your personal information, we will write to you and explain why we are declining to do so

Please contact us if:

  • You believe your personal information has been accessed without your consent;
  • You believe we have not honoured our obligations relating to your privacy rights;
  • You have any questions regarding our privacy policy; or
  • You would like to unsubscribe from our mailing list, you would like us to remove your personal information or you would like us to update your personal information.

Your request should be addressed to:

The Privacy Officer

StayWell Holdings Pty Limited

info@staywellgroup.com

Complaints

If you believe that we have not complied with our legal obligations in relation to your personal information or have not complied with the terms of our privacy policy, or you would like to appeal a decision made by us relating to your personal information, you can make a complaint in writing to our privacy officer using the details set out above. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

If you are still unhappy with our response then you may direct your complaint to the relevant regulatory authority with responsibility for privacy complaints in the applicable jurisdiction.  We will provide you with details of the relevant regulatory authority if you request them from us.  Please contact our privacy officer using the details above if you require such information.

Amendments to this privacy policy

By using our website you agree to this privacy policy. This privacy policy was last updated on 22 May 2018.

We may amend this privacy policy at any time. Amendments to this privacy policy will be posted on our websites and will be effective when posted.  By using our website after any changes go into effect, you agree to those changes to this privacy policy.  We encourage you to check our website regularly for any updates to this privacy policy.