ciloyalty is part of one of the world's largest travel agency groups. We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our customers. We are firmly committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
By providing personal information to us (either directly or allowing another person to do so on your behalf), you agree that this Policy will apply to how we handle your personal information and you consent to us collecting, using and disclosing your personal information as detailed in this Policy. If you do not agree with any part of this Policy, you must not provide your personal information to us. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Policy, this may affect our ability to provide services to you or negatively impact the services we can provide to you. For example, most travel bookings must be made under the traveller's full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.
There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Policy. Where this occurs we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.
2. What personal information do we collect?
Personal information has the meaning given under your local data protection law. Personal information generally means information which relates to a living individual who can be identified from that information, or from that information and other information in a person’s possession, including any expression of opinion, whether true or not, and whether recorded in material form or not, about an identified or reasonably identifiable individual, and any indication of intention in respect of an individual.
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf. For example, we may collect details such as your name, residential/mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), passport details, loyalty program / frequent flyer details, information about your dietary requirements and health issues (if any), and other details relevant to your travel arrangements or required by the relevant travel service provider(s) (e.g. airlines and accommodation or tour providers). When you make contact with us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us. We also collect information that is required for use in the business activities of ciloyalty and our related entities, including for example, financial details necessary in order to process various transactions, video surveillance footage used for security purposes, and other relevant personal information you may elect to provide to us.
In some circumstances, we may collect personal information from you which may be regarded as sensitive information under your local data protection laws. Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, criminal record and the alleged commission of an offence, membership of political, professional or trade associations, biometric and genetic information, passwords and financial information and health information, and (in the USA) any personal information relating to a child under the age of 13. We will only collect sensitive information in compliance with your local data protection laws, with your consent and/or where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorised to do so by law. To the extent permitted or required under your local data protection laws, you consent to us using and disclosing your sensitive information for the purpose for which it was collected, unless we subsequently receive your consent to use it for another purpose. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages, in which case you consent to us using and disclosing that information in connection with facilitating your request. We will not use sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.
3. How do we collect personal information?
We will collect personal information directly from you unless it is unreasonable or impracticable to do so. Generally, this collection will occur when you deal with us either in person, by telephone, letter, facsimile, email, when you visit any of our websites or when you connect with us via social media. We may collect personal information about you when you purchase or make enquiries about travel arrangements or other products and services; when you enter competitions or register for promotions; when you subscribe to receive marketing from us (e.g. e-newsletters); when you request brochures or other information from us; or when you provide information, or use our services, on social media. Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback.
In some circumstances, it may be necessary for us to collect personal information about you from a third party. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking. By providing your personal information to us, either directly or through a family member, employer or other agent or representative in connection with a travel booking or related service, you will be deemed to have consented to your personal information being collected by us and used and disclosed in accordance with this Policy.
Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree you have obtained the consent of the other person for ciloyalty to collect, use and disclose the other person's personal information in accordance with this Policy and that you have otherwise made the other person aware of this Policy.
You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person's personal information to us.
4. When we act as agent for a travel service provider
We act as agent for or on behalf of many thousands of travel service providers around the world, so it is not possible for us to set out in this Policy all of the travel service providers for whom we act or their locations. For more information about the disclosure of personal information to travel service providers located overseas, please refer to section 7 (Is personal information transferred overseas).
If you have any concerns regarding the transfer of your personal information to a travel service provider, or you wish to contact us for further information, please refer to the “Feedback / Complaints / Contact” section below.
5. How do we use and disclose your personal information?
Where you contact us in relation to a travel booking or query, the primary purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Policy (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc).
By continuing to use our services and/or by providing us with personal information (or allowing another person to do so on your behalf), you consent to us using and disclosing your personal information for the purpose for which it was collected, and, where permitted by your local data protection laws, for any related secondary purpose which we believe you would reasonably expect.
The purposes for which we collect personal information, and those secondary purposes which we consider to be directly related, include:
Where permitted by local data protection laws, we may use your personal information to send you targeted marketing activities relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information. These may include, but are not limited to, mail outs, electronic marketing (including online targeted marketing) and notifications as described below, and telephone calls). We will only use your personal information to send electronic marketing materials to you (including e-newsletters, email, SMS, MSM and iM) if you have opted-in to receive them. You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of our consultants to do so for you.
Should you no longer wish to receive promotional/marketing material from us, participate in market research or receive other types of communication from us, please refer to the “Feedback / Complaints / Contact” section below. You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MSM, iM or other form of electronic marketing.
6. Is personal information disclosed to third parties?
We may disclose your personal information to third parties, as set out below, and in accordance with your local data protection laws. By continuing to use our services and/or by providing us with your personal information (or allowing another person to do so on your behalf), you consent to that personal information being processed, transferred and/or disclosed by us for the purpose for which it was collected and, where permitted by your local data protection laws, for any related secondary purpose which we believe you would reasonably expect. Note that, in this Policy, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.
Your personal information may be disclosed to the following types of third parties:
For more information in relation to collection by travel service providers and their privacy practices and policies, see the section above titled, "When we act as agent".
Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including applicable privacy / data protection laws).
7. Is personal information transferred overseas?
We may disclose your personal information to certain overseas recipients, as set out below, which we will do in accordance with your local data protection laws.
It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) located in a jurisdiction where you will not be able to seek redress under your local data protection laws and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by your local data protection laws, we will not be liable for how these overseas recipients handle, store and process your personal information. By providing your personal information to us for the purpose of booking and otherwise arranging travel related products and services for you, you consent to our disclosure of your personal information to these overseas recipients for that purpose.
(a) Our overseas related entities
ciloyalty and its related entities operate a global business, including operations in Australia, New Zealand, Canada, United States, United Kingdom, South Africa, Hong Kong, India, China, Singapore, the United Arab Emirates, Ireland, the Netherlands and Mexico. Your personal information may be disclosed to our overseas related entities in connection with facilitation of your travel booking and/or to enable the performance of administrative, advisory and technical services, including the storage and processing of such information.
(b) Travel service providers located overseas
In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers. We deal with many different travel service providers all over the world, so the location of a travel service provider relevant to your personal information will depend on the travel services being provided. The relevant travel service providers will in most cases receive your personal information in the country in which they will provide the services to you or in which their business or management is based.
Please refer to section 5 (“when we act as agent”) for more information about when we act as agent for travel service providers and their privacy practices and policies.
(c) Our third party service providers located overseas
We may also disclose your personal information to third parties located overseas for the purpose of performing services for us, including the storage and processing of such information. Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of your travel booking and/or to enable the performance of administrative and technical services by them on our behalf.
We use key service providers located in India, Hong Kong, USA, United Kingdom, Spain and Australia. We also deal with many different service providers all over the world, so it is not possible for us to set out in this Policy all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please refer to the “Feedback / Complaints / Contact” section below.
8. Security of information
ciloyalty has implemented various physical, electronic and managerial security procedures in order to protect the personal information it holds from loss and misuse, and from unauthorized access, modification, disclosure and interference. ciloyalty regularly reviews security technologies and will strive to protect your personal information as fully as we protect our own confidential information. ciloyalty is not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.
We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.
9. Access to and correction of personal information
You are entitled to access any personal information we may hold about you in accordance with your local data protection laws. Where personal information we hold about you is not accurate, complete or up-to-date or the information is irrelevant or misleading, you may ask us to correct that personal information, and we will respond to your request within a reasonable time. We reserve the right to confirm the identity of the person seeking access or correction to personal information before complying with such a request. We reserve the right to deny you access for any reason permitted under applicable law. If we deny access or correction, we will provide you with written reasons for such denial unless it is unreasonable to do so and, where required by local data protection laws, will note your request and the denial of same in our records. If you wish to access or seek correction of any personal information we hold about you, please refer to the “Feedback / Complaints / Contact” section below.
You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct, unless we subsequently become aware that it is not correct.
10. Social Media Integrations
Our websites and mobile applications may use social media features and widgets (such as “Like” and “Share” buttons/widgets) (“SM Features”). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.
If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them. Similarly, your interactions with the SM Features may be recorded by the third party. In addition, the third party company may send us information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to you via the third party social media platform. You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third party social media platform.
11. IP addresses
When you access our website, use any of our mobile applications or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet. Alone, IP addresses are not personal information, as any one computer or device may be used by multiple people (i.e. it is not possible to ascertain the identity of a user simply from the computer or device being used).
We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (e.g. to better tailor our marketing and advertising materials, provided you have opted in to receive electronic marketing).
12. Tracking Technologies / Cookies
13. Linked Sites
14. Feedback / Complaints / Contact
If you have any enquiries, comments or complaints about this Policy or our handling of your personal information, please contact your consultant or contact us at:
Attention: Customer Liaison Team
Address: 275 Grey Street, South Brisbane, Queensland 4101
Telephone: +61 7 3199 5250
We will respond to any enquiries or complaints received as soon as practicable.
15. Changes to our Policy
We may amend this Policy from time to time. If we make a change to the Policy, the revised version will be posted on our website at Ciloyalty.com. It is your responsibility, and we encourage you, to check the website from time to time in order to determine whether there have been any changes.
Last updated 29 November 2016.