1. We respect your privacy
1.1. TXA is an online tourism marketplace that is operated by Vcubed Pty Ltd. Vcubed Pty Ltd respects your right to privacy and is committed to safeguarding the privacy of our customers and visitors to our platform. We adhere to the Privacy Act 1988 and General Data Protection Regulation (Regulation (EU) 2016/679). This policy sets out how we collect and treat your personal data.
1.2. “Personal Data” has the meaning defined within the above regulations and is any information relating to an identifiable person.
2. Important information and who we are
This tourism marketplace is not intended for children, and we do not knowingly collect data relating to children.
2.3. Contact details
Full name of legal entity: Vcubed Pty Ltd
Email address: firstname.lastname@example.org
Postal address: 3/8 Alvan Street, Subiaco, Western Australia, 6008, Australia
You have the right to make a complaint at any time to Office of the Australian Information Commissioner (OAIC). We would, however, appreciate the chance to deal with your concerns before you approach the OAIC so please contact us in the first instance.
2.6. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
2.7. Third-party links
3. Collection of personal information
3.1. Vcubed Pty Ltd will, from time to time, receive and store personal information You enter onto our TXA Platform, provided to us directly or given to us in other forms.
3.2. You may provide basic information such as your name, phone number, address and email address to enable us to send information, provide updates and process your product or service booking. We may collect additional information at other times, including but not limited to, when you provide feedback, when you provide information about your personal or business affairs, change your content or email preference, respond to surveys and/or promotions, provide financial or credit card information, or communicate with our customer support.
3.3. Additionally, we may also collect any other information you provide while interacting with us.
3.4. If you do not wish your personal information to be handled in this way, you may cancel the booking process. In addition, when you choose to share personal information in order to receive services selected by Vcubed Pty Ltd you grant Vcubed Pty Ltd your permission to share the personal information, e.g., by selecting the appropriate setting in the booking process. If you accept the ‘I would like to opt-in to receive marketing from or in relation to this business’ option during the booking process, we may provide you with information by email or other means about the products and/or services. If you accept the ‘I would like to opt-in to receive marketing from related parties’ option in the booking process, you may also be notified of other goods and/or services offered by our strategic alliance businesses and your information may be used for databank compilation and administration, and databank sales to data processing companies including destination marketing organisations and operators of global distribution systems of travel and leisure products. If you prefer not to receive such offers or details, or if you do not wish your personal information to be handled in this way. please untick one or both these options in the booking process.
3.5. Your credit card details are not saved during the booking process nor are they in any way viewable nor accessible by us or any other parties.
4. How we collect your personal information
5. Use of your personal information
5.1. Vcubed Pty Ltd may use personal information collected from you to provide you with information, updates and to fulfil bookings you have made via our TXA platform. We may also make you aware of new and additional products, services and opportunities available to you. We may use your personal information to improve our products and services and better understand your needs.
5.2. Vcubed Pty Ltd may contact you by a variety of measures including, but not limited to telephone, email, sms or mail.
6. Disclosure of your personal information
6.1. We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers and participants in our TXA platform or subcontractors insofar as reasonably necessary for the purposes set out in this Policy.
6.2. We may from time to time need to disclose personal information to comply with a legal requirement, such as a law, regulation, court order, subpoena, warrant, in the course of a legal proceeding or in response to a law enforcement agency request.
6.3.We may also use your personal information to protect the copyright, trademarks, legal rights, property or safety of Territory Partner, TXA, its customers or third parties.
6.4. Information that we collect may from time to time be stored, processed or transferred between parties located in countries outside of Australia.
6.5. If there is a change of control in our business or a sale or transfer of business assets, we reserve the right to transfer to the extent permissible at law our user databases, together with any personal information and non-personal information contained in those databases. This information may be disclosed to a potential purchaser under an agreement to maintain confidentiality. We would seek to only disclose information in good faith and where required by any of the above circumstances.
7. International transfers
7.1. We share your personal data within the group of companies using the Open Booking Exchange Tourism Market technology. This may involve transferring your data outside Australia.
We ensure your personal data is protected by requesting all companies using the Open Booking Exchange Tourism Market technology to follow the same rules when processing your personal data. These rules are called “binding exchange rules”.
7.2. Many of our external third parties are based outside Australia so their processing of your personal data will involve a transfer of data outside Australia.
7.3. Whenever we transfer your personal data out of Australia, we ensure a similar degree of protection is afforded to it by ensuring the following safeguard is implemented: We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by Australia.
7.4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Australia.
8. Security of your personal information
8.1. Vcubed Pty Ltd is committed to ensuring that the information you provide to us is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, interference, loss and unauthorised access, modification and disclosure.
9. Access to your personal information
9.1. You may request details of personal information that we hold about you in accordance with the provisions of Privacy Act 1988. In rare circumstances a small administrative fee may be payable for the provision of information. If you would like a copy of the information, which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, please email our Customer Service at email@example.com
9.2. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in Privacy Act 1988.
10. Complaints about privacy
10.1. If you have any complaints about our privacy practices, please feel free to send in details of your complaints to Customer Service, firstname.lastname@example.org. We take complaints very seriously and will respond shortly after receiving written notice of your complaint.
12. TXA platform
12.1. When you come to our platform (TXA) we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc. This information is used in an aggregated manner to analyse how people use our site, such that we can improve our service.
12.3. Our site may from time to time have links to third party websites not owned or controlled by us. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. Please be aware that Vcubed Pty Ltd is not responsible for the privacy practices of other such websites. We encourage our users to be aware when they leave our website, to read the privacy statements of every website that collects personal information.
13. Data retention
13.1. How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Details of retention periods for different aspects of your personal data are available in our Retention Policy which you can request by contacting our Data Protection Officer (DPO).
14. Your Legal Rights
14.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please submit your DSAR form.
14.2. No fee usually required:
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
14.3. What we may need from you:
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
14.4. Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.