Privacy Policy

3. HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?

Directly 

Directly from persons or members when you provide Personal Information. Examples may include when:

• Providing your information for the purpose of Willow Cobram Resort in any of its products and services including the entering into of any agreement as a resident or otherwise.
• Registering your interest in our products and services at Willow Cobram Resort via our Website or via phone call or email.
• When you interact and/or browse the Website or any Application associated with it application generally or for a specific purpose.
• Directly when you subscribe to any newsletter of Willow Cobram Resort. 
• When representatives of Willow Cobram Resort such as employees undertake certain business functions for Willow Cobram Resort in the provision of Willow Cobram Resort’s products and services.

Indirectly

• When a relative or friend makes an inquiry on your behalf or provides information to Willow Cobram Resort, however please note that Willow Cobram Resort will endeavour to notify you of such matter so that you are aware of this collected information.

Third party providers

Data is collected, processed and stored using third party analytics software, that is to the best of our knowledge secure and confidential. Analytical data is used to gain an understanding of user behaviour, perform system critical operations, and in extraordinary circumstances, for legal reasons. Anonymous user data is shared between third party services in order to gain insight as to aggregate user behaviour. 

Analytic data insights are also used to target users through remarketing, demographics, interests and website behaviour. Third party vendors, including but not limited to Google and Facebook may show our ads on sites across the internet. We and third party vendors, including but not limited to Google, make use of third party cookies together in order to inform, optimise and serve ads based on past visits to a website. We make use of demographic data (such as age, gender and interests) obtained through third party tools in order to, but not limited to influence marketing spend and communicate internally and externally the aggregate behaviour. 

Public sources 

When you use some Willow Cobram Resort products, services, or applications or post on a social networking service such as Instagram, Facebook, Twitter or Trip Advisor, the personal information and content you share is visible to other users and can be read, collected, or used by them and Willow Cobram Resort. For example, if your name, suburb or email address is contained in a public post or perhaps your personal preferences set out in a review of our products and services or in relation to Willow Cobram Resort, that information is then public and can be collected and disclosed by Willow Cobram Resort. 

Combining/linking Personal Information

Other than as referred to elsewhere in this Policy, we will not facilitate the merging of personally identifiable information with non-personally identifiable information without prior user consent to that merger to optimise our Website and Website marketing. For example, we may collate Personal Information data and aggregate data for the purpose of comparing marketing costs with revenue on a transactional basis. 

Passive collection of information – Direct Marketing and Behavioural Advertising

As you navigate through our Websites and access our Applications, certain information can be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, and clickstream data). 

For example, we may collect information about matters including but not limited to the date, time and duration of visits and which pages of a Website or Application are most commonly accessed. This information is generally not linked to the identity of visitors, except where a Website or Application is accessed via links in an email or another electronic message we have sent or where we are able to uniquely identify the device or user accessing a Website or Application, such as when you are logged into an account.

We may share hashed portions of your information with certain strategic partners to make our business more responsive to your interests and/or those of like-minded consumers. For example, we may aggregate your email address together with the email addresses of others who place enquiries on our Website, locally hash such data, and transmit the resulting hashed data to third parties including but not limited to Facebook/LinkedIn/Google for the purpose of creating “Custom Audiences” (where targeted ads are sent to people on Facebook who have already been on our Site), and “Lookalike Audiences” (where targeted ads are sent to people on Facebook/LinkedIn/Google who have similar characteristics to people on our Custom Audience list). 

Where we use Personal Information for promotional or direct marketing purposes, a person may at any time request Willow Cobram Resort to not use their Personal Information for sending direct marketing material to that person including if you wish to opt-out of the use of certain hashed portions of your Personal Information. Such a request can be made by contacting Willow Cobram Resort either in writing, by email or by telephone at the contact details below. There is no fee for making such a request.

DIRECT MARKETING can include for example: Displaying an advertisement on a social media site that an individual is logged into, using Personal Information, including data collected by cookies relating to websites the individual has viewed.  

Cookies & Web Beacons

We use cookies on our Websites. Cookies are text files placed in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personally identifiable information. However, once you choose to furnish the Websites with personally identifiable information, this information may be linked to the data stored in the cookie.

We may use web beacons on the Websites from time to time. Web beacons or clear .gifs are small pieces of code placed on a web page to monitor the behaviour and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.

How Willow Cobram Resort hold information 

We hold Personal Information electronically and may in hard copy form, both at our own premises and with the assistance of these service providers. Data may be collected, processed and stored using third software that is to the best of our knowledge secure and confidential. 

Willow Cobram Resort retains the information you provide to us including your contact details to enable us to verify transactions and customer details and to retain adequate records for legal and accounting purposes. This information is held on secure servers in controlled facilities.

Security 

We have systems in place to ensure that information is accessible by our staff on a need-to-know basis.

We act to safeguard the security and privacy of your information, whether you interact with us personally, by telephone, mail, over the internet or other electronic medium. We strive to take reasonable steps to protect the information we hold from misuse, interference, loss and unauthorised access modification or disclosure, however we cannot guarantee its absolute security. 

We may store information both in hard copy paper form and in soft copy electronic form. Where the information is of a sensitive nature, we will take particular steps to secure the information. 

In certain circumstances we use third party storage providers such as cloud storage and back-ups to hold information that is stored in soft copy electronic form.

When your personal information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information. However most personal information is stored in client files which will be kept for a minimum of seven years.