|About This Security and Privacy Statement|
Your personal information is important to us
"Personal information" is information that identifies you or could identify you. The types of personal information we collect may include your name, address, contact phone number, email address, date of birth, passport and visa information, transaction information and financial details. We may also keep a record of products and services that you acquire from us.
Where the personal information requested includes an email address and/or mobile phone number, TFE Hotels will only contact you by email or SMS if you agree to being contacted in this manner.
The information we collect about you
Generally, only information you provide about yourself to TFE Hotels directly will be collected, such as through enquiring about, or using, TFE Hotels’ products & services or TFE Hotels’ website, making a booking on a TFE Hotels website or by phone or otherwise identifying yourself when requesting information to be sent to you. In certain circumstances, we may collect information about you from third parties. However, we will only do so if it is unreasonable or impracticable to collect the personal information directly from you and we will take reasonable steps to inform you if and when we do.
TFE Hotels only collects personal information which is reasonably necessary for, or directly related to, one or more of its functions or activities. For example, TFE Hotel collects personal information from you in order to provide and charge for the hotel accommodation and other goods and services you purchase. We may also collect personal information about you to better understand your requirements and preferences, improve our services and to provide offers that may be of interest or benefit to you. For example, when you fill out a contact form, we collect the details you enter to enable us to send information to you. When you answer questions about what you would like to see we keep this information so as to better serve you.
If you do not provide the personal information we request from you for these purposes, we may not be able to carry on our business and provide our services to you.
There may be instances in which the personal information that you provide to us or that we collect is considered "sensitive information" for the purposes of the APA. The APA defines "sensitive information" to mean personal information from which we can determine or infer an individual's racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a professional association or trade union, sexual preferences or practices, criminal record and health, biometric and genetic information. We will only collect and process sensitive information about you in accordance with, and to the extent permitted by, the APPs.
TFE Hotels' use of "cookies"
Cookies themselves do not contain personal information about you. They simply operate as a unique identifier which helps us to know what our customers find interesting and useful on our websites, almost like a continuing questionnaire. TFE Hotels does not store any personal information inside cookies, although the cookie may identify the user's browser.
Using & disclosing your personal information
TFE Hotels will not use or disclose any specific personal information about you without your consent, other than for:
• the main reason for which you have provided personal information (primary purpose);
• a purpose which is related to the primary purpose and which you would reasonably expect us to use the information for;
• a purpose required, authorised or permitted by law;
• to provide our products and services to you;
• to reply to your queries or requests;
• to market our products and services including to communicate special offers or promotions and to provide you with information about us and our products and services;
• to compile and use statistical information regarding our customers; or
• to seek feedback from you and to monitor the quality of our products and services.
TFE Hotels and its affiliates recognise the trust you place in us when you give us personal information. For example, TFE Hotels may ask you questions to get a better understanding of what facilities and services would help you with your accommodation needs. We will use this information to recommend accommodation and services which we believe will be of benefit to you and your business. However, we will not disclose specific information about you and your business to any other company (except those entities specified below) without your explicit consent.
TFE Hotels may from time to time outsource the processing of certain functions or information to third parties. We may also provide your information to our related entities and partners. Any personal information disclosed to our agents, related entities, partners, contractors and third party service providers is only to the extent necessary for them to perform their agreed tasks and they are required to maintain the privacy of your information and keep such information confidential.
Pursuant to the APPs and IPPs, we may transfer personal information we have collected about you to someone other than you in a foreign country, but only in accordance with and to the extent permitted by the APPs and IPPs. We will not disclose your personal information to overseas recipients without your consent.
As we continue to develop our business, we may sell hotels and other assets, or cease being the manager of a hotel that is currently part of our portfolio. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected from you, or control of such information, may be one of the transferred assets.
Information & promotional emails
From time to time we will send you relevant information emails regarding products and services which you have previously registered your interest in. If you are receiving promotional information from TFE Hotels and do not wish to receive this information any longer, you may unsubscribe at any time. All electronic communications we send to you for direct marketing purposes will include an “unsubscribe” link which enables you to opt out of receiving any future direct marketing correspondence.
Storage & security of your details
TFE Hotels will store personal information [electronically and in paper form].
TFE Hotels will take such steps as are reasonable to protect your personal information from unauthorised access or use, misuses, loss, modification or authorised disclosure, and to ensure that the personal information we hold about you is accurate, complete and up to date. TFE Hotels also maintain computer and network security, for example we use firewalls and other systems such as user identifiers and passwords to control access to computer systems. In addition, TFE Hotels’ employees are obliged to respect the confidentiality of any personal information held by TFE Hotels. Personal information will be de-identified or destroyed when no longer required by us. However, to the extent permitted by law, TFE Hotels will not be held responsible for events arising from unauthorised access to your personal information. We encourage you to play an important role in keeping your personal information secure.
Accessing, changing & deleting information we keep about you
Your trust in TFE Hotels is very important to us. If at any time you want to know exactly what personal information we are holding about you or update any information at any particular time, please email us at email@example.com and we will respond to your request within a reasonable period. We will allow you access unless we consider that there is a sound reason under the APA or the NZPA (as applicable) or other relevant law to withhold the information. If we refuse to provide you with access or correct the personal information we hold about you, we will provide reasons for such refusal. In addition, you may request that the personal information TFE Hotels holds about you be corrected by emailing us at firstname.lastname@example.org. If TFE Hotels and you disagree on whether the information is accurate, complete and up-to-date, you can make a statement about the requested changes and we will attach this statement to our records.
TFE Hotels & links to other websites
TFE Hotels provides links to websites outside of the TFE Hotels portal. These linked sites are not under the control of TFE Hotels, and we are not responsible for the conduct of companies linked to our websites. Before disclosing your personal information on any other website, we advise you to examine the privacy policies for those sites. Should you be concerned with the conduct of a site which you accessed via a link from the TFE Hotels site, please help us to help you, by emailing us at email@example.com
How we handle email
We will preserve the content of any e-mail that you send us, if we believe that we have a legal requirement to do so. Your e-mail message content may be monitored by our TFE Hotels employees for security issues including where e-mail abuse is suspected; our response to you may be monitored for quality assurance issues.
If you have a complaint regarding the way in which your personal information is being handled by TFE Hotels, please contact us in the first instance. If you are not satisfied with the response that you receive, you may choose to escalate your concern to the Australian Information Commissioner or the New Zealand Privacy Commissioner. If you would like to obtain further information about privacy issues in Australia, please visit the Australian Information Commissioner's website: http://www.privacy.gov.au/. If you would like to obtain further information about privacy issues in New Zealand, please visit the New Zealand Privacy Commissioner's website: http://privacy.org.nz/.
How to contact us
We, at Adina Apartment Hotels, adhere to the relevant regulations relating to the collection of personal information of the countries where our hotels are located. All personal information collected from you is required to meet the requirements of legislation of those countries. We will not make this personal information available to any third party without your prior consent except where required by law or to enforce our collection of amounts owing by you. You must advise us if any personal details on any registration card or reservation given to you by us are incorrect. After you have stayed with us your personal information will be retained for the minimum length of time to comply with taxation and accounting requirements of the countries where our hotels are located (usually seven years). Any personal information is accessible only to authorised personnel of Adina Apartment Hotels. A charge may be levied if a copy of any registration card is required after six months from your departure. Copies of registration cards (other than electronic data) are not made available after two years. We will not knowingly permit any misuse of this personal data. Any requests for access to personal information held about you by us must be made in writing to the Chief Executive Officer, TFE Hotels, Level 5, 45 Jones Street, Ultimo, New South Wales 2007 Australia.