1.1 Make My Holidays Group of Companies

Make My Holidays and its subsidiaries operate a range of businesses including the operation of call centres, resorts, customer/travel service companies, administration and sales business(s).

Through these operations, Make My Holidays from time to time gathers information from Customers and other parties with whom we deal for a variety of reasons.

Make My Holidays understands individuals' concerns regarding confidentiality and takes seriously its obligations in respect of all information it gathers.

To safeguard that information, Make My Holidays has implemented a program to ensure compliance with the Privacy Act 1988 (Cth) and the National Privacy Principles ("NPPs"). This Privacy Policy outlines how Make My Holidays deals with Personal Information.

2.1 Nature of Information

The information Make My Holidays collects in most cases relates to Customers but can relate to suppliers and other parties we deal with (for the purpose of this Privacy Policy all such people are described as "Customers"). Information is gathered for a range of purposes, including the provision of ongoing Customer support and the compiling of Customer databases to enable us to more accurately market our goods and services. The type of information we collect includes such things as contact details, buying habits, opinions, product preferences and transactional details. Make My Holidays treats all such information which is collected and identifiable as relating to an individual as Personal Information. It is this Information which is described as "Personal Information" for the purposes of this Privacy Policy.

2.2 Collection of Information

In accordance with the NPPs, where practical, Customers of Make My Holidays may deal with Make My Holidays on an anonymous basis.

However, as a provider of a wide range of services, Make My Holidays frequently finds that it is necessary to collect Personal Information during the course of transactions.

Personal Information may be collected about Customers via the following means:

a) competition entry forms;
b) application forms;
c) email;
d) websites;
e) online transactions;
f) networking functions (eg: business cards);
g) over the phone;
h) credit card details via credit card purchases;
i) information collected from third parties; and
j) Customer surveys.

2.3 'sensitive information'

a) the Customer provides their consent;
b) the collection of that information is specifically authorised by law;
c) the collection is necessary to lessen a serious or imminent threat to the health or safety of a person; or
d) the collection of the information is necessary for the establishment, exercise or defence of a legal claim.

2.4 Customer consent

Wherever practical, Make My Holidays will obtain the express consent of Customers to the collection of Personal Information.

In some situations, Make My Holidays will interpret a Customer's actions as indicating that a Customer consents to the collection of Personal Information. This may occur where the Customer has provided Personal Information for a particular purpose and that purpose cannot be achieved without Make My Holidays making use of the Customer's Personal Information.

3.1 Who may view Personal Information

In general, only officers, employees or common equity partners of Make My Holidays may view Personal Information.
Make My Holidays will only grant access to parties other than Make My Holidays officers, employees and contractors to view Personal Information where Make My Holidays believes that access is necessary to achieve the purpose for which the Personal Information was collected.

Make My Holidays will only disclose Personal Information to parties other than Make My Holidays officers, employees and contractors if:

a) that disclosure is required to give effect to ongoing Customer support or marketing services which Make My Holidays may be of Benefit to the Customer;
b) the Customer has consent to that disclosure;
c) Make My Holidays believes that the disclosure may lessen a risk of harm to the health or safety of any person;
d) Make My Holidays believes an unlawful activity is being undertaken and the Personal Information is disclosed as part of Make My Holidays investigation into this activity;
e) Make My Holidays is required by law to disclose the Personal Information; or
f) The disclosure is required for the enforcement of a criminal law or a law imposing a pecuniary penalty or for the protection of public revenue.

3.2 Identification

Make My Holidays does not use any prohibited identifiers (such as a tax file number) to identify its Customers.

3.3 Storage and Security

Personal Information may be stored in either hard copy form or on computer or both. Hard copy Personal Information is wherever practical, kept under locked security. Personal Information stored on computer is wherever practical, password locked.

Where possible and practical, Make My Holidays will endeavour to comply with recognised Australian and international standards relating to information security.

Make My Holidays regularly deletes and de-identifies Personal information if the information is no longer needed by Make My Holidays.

3.4 Updating Personal Information

Make My Holidays regularly monitors the quality and accuracy of Personal Information that it maintains and where practical, updates that information on a regular basis.

Customers can update their Personal Information at any time by contacting the Make My Holidays Privacy Officer.

Make My Holidays has adopted the position proposed by the Privacy Commissioner that a young person is able to give their consent when he or she has a sufficient understanding and maturity to understand what is being proposed.
Where Make My Holidays is aware that it is gathering information from a minor, Make My Holidays will obtain consent from a legal guardian for the collection of the information. Where this is not possible, Make My Holidays staff will make a determination as to the minor's understanding of why the Personal Information is being collected, before deciding to collect that information.

Personal Information collected for direct marketing purposes will only be collected, used or disclosed with the consent of the relevant Customer as provided for in this Privacy Policy.

In circumstances where Make My Holidays cannot practically obtain the consent of a Customer, then Make My Holidays may still engage in direct marketing to that Customer, but will if requested:

a) allow the Customer to be taken off the mailing list at any time; and
b) display its contact details clearly in each direct marketing publication.

Customers may be taken off any mailing list be contacting Make My Holidays Privacy Officer.

Customers may access their Personal Information by contacting Make My Holidays Privacy Officer. Access is generally granted within 30 days of that request.

Make My Holidays may impose a reasonable charge for access.

7.1 When access can be withheld

Access to Personal Information may be withheld in a number of circumstances. These include where:

a) providing access would pose a serious and imminent threat to the life or health of a person;
b) providing access would have an unreasonable impact on the privacy of others;
c) the information is subject to confidentiality where the person who provided the information to Make My Holidays did so expressly on the condition that it remains confidential;
d) the request is vexatious or frivolous;
e) the information relates to current or anticipated legal proceedings between Make My Holidays and the person and the information would not be required to be discovered to a court;
f) Make My Holidays is in commercial negotiations with the person and the information would reveal Make My Holidays intentions;
g) Providing access would be unlawful or Make My Holidays is required by a law to withhold access; or
h) Providing access could prejudice the investigation or detection by Make My Holidays or by a government body of an unlawful activity or some serious or improper misconduct.
Where Make My Holidays does withhold Personal Information, Make My Holidays may instead choose to give the Customer a summary of that information.

7.2 Written reasons

If Make My Holidays does withhold Personal Information, Make My Holidays will provide written reasons.

7.3 Third party intermediary

If Make My Holidays withholds access to Personal Information, Make My Holidays will consider whether the provision of access to an independent third party will meet Make My Holidays and the relevant Customer's needs.

If you have any queries with respect to this Privacy Policy please contact our Privacy Officer at Make My Holidays, Level 7, 84 William St, Melbourne VIC 3000.

Make My Holidays may modify this Privacy Policy and the way it handles Personal Information at any time at its sole discretion.

Further information on privacy can be obtained from the Privacy Commissioner at www.privacy.gov.au