Cooinda Cobram Resort Pty Ltd (ACN 162 136 950) (“Willow Cobram Resort”) manages personal information in accordance with the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles as set out in Schedule 1 of the Privacy Act (“APP”).
This Policy is effective from March 2020.
Throughout this Policy we refer to “Personal Information” which is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.
“Sensitive Information” is a subset of Personal Information, and includes information or an opinion about a person’s racial or ethnic origin, political opinions, membership of a political association, religious beliefs or affiliations, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual orientation or practices, criminal record, or health, genetic or biometric information.
2. WHAT KINDS OF PERSONAL INFORMATION IS COLLECTED AND HELD?
Willow Cobram Resort collect and hold information about Willow Cobram Resort’s employees, contractors who provide us with a service, customers, website users, suppliers, job applicants and other people who may come into contact with us or our businesses from time to time.
Examples of Personal Information that may be collected and held by Willow Cobram Resort includes but is not limited to:
• Your first and last name
• Date of birth
• Company name and details
• Delivery Address
• Contact phone number
• Mobile phone number
• Email address
• Employment information
• Individual preferences
• Marketing information
Willow Cobram Resort may also combine your personal information with other information to provide and improve our products, services, content, and advertising.
You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have. You may be able to deal with Willow Cobram Resort without identifying yourself (for example anonymously or by using a pseudonym) in certain circumstances. Please be aware that this may not be possible for example where Willow Cobram Resort needs to identify you for legal purposes or if it is impracticable to do so.
Willow Cobram Resort collects only personal information that is reasonably necessary for, or directly related to, its functions or activities. The nature and extent of personal information Willow Cobram Resort collects and holds will vary depending on a person’s particular relationship and interaction with Willow Cobram Resort.
Willow Cobram Resort will not collect Sensitive Information unless the person to whom it relates consents to the collection of that information, and the information is reasonably necessary for one or more of Willow Cobram Resort’s functions or activities, except where the collection is required or authorised by law, is necessary to prevent or lessen a serious and imminent threat to the person’s (or another person’s) life or health, or is necessary in relation to legal proceedings (current, anticipated or potential), or another permitted exception in the Privacy Act applies.
3. HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?
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.
- 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.
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 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.
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.
4. THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL INFORMATION
Willow Cobram Resort collects Personal Information in various ways in the course of conducting its business, to provide and improve our products, services, content, and advertising including for the purposes of:
- Contacting persons interested or enquiring about the products and services at Willow Cobram Resort
- Providing our products and services to customers
- Providing newsletters to customers via e-mail
- Contacting persons via email with updates including without limitation to property updates, upcoming events, member log-in information or otherwise.
- Responding to customer queries in relation to our products and services
- Interaction with customers who utilise our Website
- To better understand your needs, enabling us to improve our products and services
- To make improvements to the Websites to enhance the user experience
- Promotional and marketing activities
- Monitor the effectiveness of our advertising
- To customise our Websites according to your interests
- Direct Marketing and Behavioural Advertising
5. HOW CAN YOU CONTROL YOUR PERSONAL INFORMATION?
Accessibility and correction of your information
A person may request to access Personal Information about them held by Willow Cobram Resort. Such a request must be made in writing via our contact details below.
Willow Cobram Resort will take reasonable steps to ensure the accuracy and completeness of the Personal Information we hold. However, if a person believes that any Personal Information that we hold about them is inaccurate, out of date or needs correction in anyway, then they should contact Willow Cobram Resort in writing via our contact details below.
Willow Cobram Resort will grant a person access and/or make any corrections to their Personal Information that may be necessary from time to time as soon as possible, subject to the circumstances of the request.
Verification of identity is required with a request to access (or update) Personal Information so that we can ensure your Personal Information is disclosed only to you.
An individual can contact Willow Cobram Resort in relation to lodging a complaint about a breach of the APP or a binding registered APP code, via our contact details below.
Willow Cobram Resort will make an assessment of the complaint and will respond to you within a reasonable timeframe. Any further action following this initial response will vary depending on the nature of the complaint. If necessary, the complaint may be taken to the Office of the Australian Information Commissioner or to another review body if an external review is required.
There may be options for you to use online services or browser settings to manage behavioural based digital advertising that allow you to opt-out or install blocking programs for example through Google.
You may also opt out of our direct marketing emails by clicking on the link contained in any such emails or by writing to Willow Cobram Resort at firstname.lastname@example.org
Freedom of Information Act 1982 (Cth)
An individual also has the right under the Freedom of Information Act 1982 (Cth) to request access to documents that we hold and ask for information that we hold about that person to be changed or annotated if it is incomplete, incorrect, out-of-date or misleading.
6. DISCLOSURE OF PERSONAL INFORMATION
Where we receive your personal information and we did not solicit the information we will do our best to notify you of our receipt of your personal information within a reasonable time. If we determine that we could not have received the information under the APP we will use our best endeavours to destroy the information. We may use or disclose the information to make such a determination.
We do not sell, publish or give away your information to any other party where the information could be linked to you without your prior consent. As set out above, when you use some Willow Cobram Resort products, services, Applications or post on a social networking service such as Instagram, Facebook, Twitter or Trip Advisor, 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.
We do not disclose your personal information to overseas recipients.
Willow Cobram Resort does not disclose personal health information to any other person, including next of kin, unless the individual about whom the information relates has given express consent, or the disclosure is required or authorised by or under Australian law, or would otherwise be consistent with the APPs.
7. WILLOW COBRAM RESORT CONTACT DETAILS
Postal Address: Privacy Officer
Willow Cobram Resort
8 Chapel Street
Cremorne VIC 3121
Phone: 1300 200 240