Elite Alpine Travel Pty Ltd Privacy Policy

This Privacy Policy sets out how Elite Alpine Travel Pty Ltd (ACN 660 121 997) trading as Top Snow Travel (referred to in this document as “Top Snow Travel”, “we”, “our”, or “us”) protects the privacy of your personal information.  

Please note that this Privacy Policy and all personal information collected and dealt with by Top Snow Travel is subject to the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APP”) contained in Schedule 1 of the Privacy Act, as amended from time to time.

This Policy also is subject to the General Data Protection Regulation 2016/679 (“GDPR”) if you are based in the European Union or UK during your interactions with us (other than when you are in the European Union or UK solely for travel purposes) (“EU Individual”).

  1. Scope

This Privacy Policy applies to the collection, holding, use and disclosures of personal and sensitive information provided about individuals to Top Snow Travel through the use of the website, www.topsnowtravel.com (“the website”), other applications related to Top Snow Travel and any services offered or provided by Top Snow Travel (“services”). In this Privacy Policy, we also explain how you can contact us if you have a query about any personal or sensitive information that we may be holding about you.

If you are an EU Individual, please refer to sections 17 and 18, which deals with matters specific to EU Individuals.

  1. Acknowledgement

By continuing to use the website and/or services or when you purchase services from Top Snow Travel, you acknowledge that you have had the opportunity to read this Privacy Policy. You also acknowledge and consent to Top Snow Travel collecting, holding, and disclosing personal information supplied by you and retaining and/or using your personal information. 

We may do so subject to the terms of this Privacy Policy, the website, any terms and conditions that apply to any goods or services that we provide to you, and any other applicable contracts.

If you provide us with personal and/or sensitive information of a third party individual, for example other people travelling with you, you will be responsible for informing the individual of the existence of this Privacy Policy and obtaining their consent for their personal or sensitive information to be provided to Top Snow Travel for the purposes indicated in this Privacy Policy or as otherwise indicated at the time of collection.

  1. Purpose

The purpose of this Privacy Policy is to:

  • clearly communicate the personal and sensitive information handling practices of Top Snow Travel;
  • enhance the transparency of Top Snow Travel’s information collection processes; and
  • to give individuals a better understanding of the sort of personal information that Top Snow Travel holds, and the way Top Snow Travel uses or discloses that information.
  1. Personal Information

In this Privacy Policy, “personal information” has the same meaning as defined by section 6 of the Privacy Act, as amended:

information or an opinion about an identified individual, or an individual who is reasonably identifiable:

  1. whether the information or opinion is true or not; and
  2. whether the information or opinion is recorded in material form or not.

Personal information may include your name, address (including previous addresses), information about you (including medical information), contact telephone number(s), e-mail addresses, bank account and credit card details, and details about flight, hotel, transfers and other related travel details and/or other information that is necessary for the delivery of our services to you.

  1. Sensitive Information

We will only collect your sensitive information with your consent and where information is reasonably necessary for one or more of our services.

We will only use and disclose your sensitive information for the primary purpose for which it was collected or a purpose that is directly related to this primary purpose and is reasonably expected. You consent to the use and disclosure on this basis. If for example we have collected information about any medical conditions you are suffering, then you consent to us disclosing this information to our service providers (for example ground operators) if they reasonably have a need to know such information in order to safely supply services for your benefit.

We will not otherwise collect, use or disclose sensitive information about you unless required to do so by law.

In this Privacy Policy, “sensitive information” has the same meaning as defined by section 6 of the Privacy Act. Sensitive information may include information or an opinion about your health information.

  1. Collection of personal information

In the course of regular business activity and in order to use the website and/or our services, Top Snow Travel will from time to time collect, require and otherwise deal with your personal and/or sensitive information.

If you do not want any of your personal and/or sensitive information collected, you can stop using the website and/or our services at any time (subject to applicable contracts), however we may not be able to provide our services to you.

Top Snow Travel collects personal and/or sensitive information from individuals in numerous ways, including for example when an individual:

  • visits or uses the website or social media channels;
  • contracts or corresponds with Top Snow Travel in person or via telephone, email, mail or directly through our website;
  • makes a purchase(s) from Top Snow Travel or enquires about travel arrangements with us;
  • makes payment of an invoice; or
  • provides us with personal and/or sensitive information, including for example allowing information on social media to be shared with us or signing up for a promotion or competition or when you subscribe to receive marking from us (e.g. a newsletter).

We may also collect personal and/or sensitive information about you from third parties or where Top Snow Travel is required to do so by law.

Top Snow Travel does not generally take steps to:

  • verify personal and/or sensitive information about any individual disclosed to it; or
  • seek additional personal and/or sensitive information about any individual on the basis of information disclosed to it,

except in circumstances where it is reasonably necessary for us to do so to deliver services or as may be required by law.

We note that in certain circumstances, if you do not consent to the use of your personal and/or sensitive information as outlined in this Privacy Policy or at the time of collection, you may not have access to our services and we might not be able to provide you with our services.

  1. Use of personal information

Any personal information collected by Top Snow Travel will be used for the purpose for which it was given to Top Snow Travel, for purposes which are directly related to those purposes, for purposes which you have otherwise consented to, or for other purposes in accordance with the Privacy Act, law or this Privacy Policy.

  1. Disclosure

We may disclose personal and/or sensitive information we hold to:

  • our directors, officers, employees and other associated companies or related entities or organisations;
  • our contracted service providers;
  • credit card providers, credit reporting and fraud checking agencies;
  • government, regulatory and law enforcement agencies where the disclosure is required or authorised by law;
  • our professional advisors, including our accountants, auditors and lawyers;
  • third party suppliers of products or services which you have selected (such as airlines, ground operators, hotels and insurance providers);
  • third party travel service providers who assist in fulfilling the booking you have made;
  • our online booking facility operator and host and others who assist in providing these services;
  • third party sponsors or co-sponsors of promotions on our website. Only information collected during a promotion will be disclosed to these parties;
  • third parties when we contract out some of our functions and activities, such as call centre operators. In these circumstances, we prohibit third parties from using your personal information, except for the specific purpose for which we supply it.

Where applicable, we may handle or disclose personal information relying on applicable exemptions under the Privacy Act, including but not limited to, the related bodies corporate exemption and the employee exemption.

  1. Overseas Disclosure

We may disclose personal and/or sensitive information to overseas recipients in order to provide services.

Generally, we will only disclose your personal information to these overseas recipients in connection with our services such as facilitation or fulfilment of your travel booking and/or to enable the performance of administrative and technical services by them on our behalf.

  1. Storage and Security

Top Snow Travel will take reasonable steps to protect the personal and/or sensitive information we hold from misuse, interference, loss and unauthorised access, modification or disclosure. Top Snow Travel may store personal information physically and/or electronically.

  1. Cookies

To ensure we are meeting the needs and requirements of our website users, and to continue to develop our online services, we may collect aggregated information through the use of cookies. We may use cookies to collect data about your visit and to allow you to navigate from page to page without having to reload each time.

You may control, refuse and/or delete cookies by using the appropriate setting on your browser as you wish, however, if you do so you may not be able to access portions of our website.

  1. Links – external websites

Please note that our website may contain links to other external websites. These links are provided as a convenience to you. Top Snow Travel is not affiliated with these sites and accordingly has no control over, and is not responsible for, their content, activities, privacy practice or other policies. Links to external websites are not covered by this Privacy Policy.

  1. Direct marketing communications

We may contact you using the contact details, which you provide to us in order to provide you with direct marketing communications about our services in accordance with the law.

You may opt out of receiving direct marketing communications from us at any time by contacting us using the details set out below or by functionality within such communications.

  1. Changes to Privacy Policy

This is our current Privacy Policy. Please note that we reserve the right to amend, modify, remove or vary this Privacy Policy at any time and without notice. You should check this page regularly to take notice of any changes we may have made to this Policy. We may notify you of changes to this Privacy Policy via the website.

To obtain a current version of our privacy policy, please contact Top Snow Travel via the contact details below.

  1. Access to personal information

If you would like access to your personal and/or sensitive information, please contact our office directly via the contact details found below under “Contact”.

  1. Correction of personal information

In the event Top Snow Travel holds personal and/or sensitive information about you and you believe that any of the information we hold about you is inaccurate, out of date, incomplete, please make a request to our office for correction. Contact details can be found below.

  1. GDPR compliance

If you are a resident of the European Union (or following Brexit, you are a resident of the UK and the UK has laws equivalent to the GDPR in effect) you have certain rights and protections under the GDPR (or the UK equivalent) regarding the processing of your personal data. This section sets out the additional information that we are required to provide to you under the GDPR. Please note that references to the GDPR also includes references to any UK equivalent.

Where the GDPR applies, the meaning of “personal information” has the same meaning as “personal data” and the meaning of “sensitive information” will apply as information concerning the processing of special categories of personal information (“sensitive data”) under the GDPR.

For the purposes of the GDPR we will either be the “data processor” or “data controller” for any personal information you provide to us in connection with our relationship. The precise role we will be assuming is dependent on the context of our relationship with you and the purpose of the processing being undertaken.

Under the GDPR, use of personal information must be based on a legal basis and we are required to provide you with information about this use. We rely on lawful means of processing your personal data, including the following:

  • where it is necessary to fulfil a contract with you. This includes where we collect your personal data to enable us to send you our goods or provide you with our services;
  • where you have given us valid consent to use your personal data. We will rely on that consent and only use the personal data for the specific purpose for which you have given consent;
  • where it is to further our legitimate interests which could include usage statistics, analytics and internal analysis so we can improve our services to you.

We note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. If you need details about the specific legal ground Top Snow Travel is relying on to process your personal data, please contact Top Snow Travel.

  1. Your rights as an European Union of UK resident

Under certain circumstances or if you are a resident of the European Union or UK, you have various rights under the GDPR in relation to your personal information, including the:

  • right to be informed;
  • right of access;
  • right to rectification;
  • right to object/ withdraw consent;
  • right to restriction of processing;
  • right to erasure or to be forgotten;
  • right to data portability; and
  • right not to be subject to automated processing.

To exercise any of these rights please contact Top Snow Travel via the contact details set out below under “Contact”.

  1. Withdrawing your consent

You can withdraw your consent to our collection or processing of your personal data. You can do so by contacting us or by opting out of email newsletter communications by following the instructions in those emails or by clicking unsubscribe. If you withdraw your consent to the use of your personal data, you may not have access to our services and we might not be able to provide you with our services. In some circumstances, where we have a legal basis to do so, we may continue to process your information after you have withdrawn consent. For example, if it is necessary to comply with an independent legal obligation or if it is necessary to do so to protect our legitimate interest in keeping our services secure.

  1. Contact

If you have any questions or concerns about how we handle your personal or sensitive information or if you wish to access or amend personal and/or sensitive information we hold about you, please make a request in writing.

All correspondence should be directed to:

Post: PO Box 1175, Noosaville QLD 4566, Australia

Email: info@topsnowtravel.com

Phone: +61 7 5370 2086

If you decide to contact us for any of the reasons above, we request that you provide us with sufficient details regarding your reason for getting in touch with us.

We note that if necessary, we will ask you to provide us with a copy of your ID, passport or other valid identity document.

  1. Complaints

If you have any enquiries about this Privacy Policy or wish to make a complaint about a matter relating to privacy please contact us using the details set out above (refer to “Contact”).

We will investigate and consider any complaint received by us and a response will be provided to the complainant as soon as practicable.

If you are not satisfied with the way in which we handle your inquiry or complaint in regard to your personal information, if applicable, you may contact the Office of the Australian Information Commissioner (“OAIC”). Contact details for the OAIC can be found at www.oaic.gov.au.

Last Updated: 05/12/2023