Privacy Notice
Background
This Privacy Notice (“Notice”) sets out how Pineapple Tours Pty Ltd, a company incorporated in Australia, and its associated bodies corporate and franchisees worldwide (collectively referred to in this document as “Pineapple Tours”, “we” “our” or “us”) protects the privacy of your personal information.

Pineapple Tours is 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.

For the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) we will be either 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.

For the provision of retail travel services by Pineapple Tours, we will be the data controller and this Notice shall apply. Likewise, for the purpose of all our marketing activities (both business travel/event management and retail travel services) we will be the data controller and this Notice shall apply.

By providing personal information to us, you agree that this Notice 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 Notice. If you do not agree with any part of this Notice, 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 Notice, 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 Notice. Where this occurs we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.

What personal information do we collect?
Personal information has the meaning given under your local data protection law, and, where the GDPR applies, the meaning of personal data given under the GDPR. 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.

We therefore typically process the following types of personal information about you:

contact information (such as name, residential/mailing address, telephone number, email address);
payment account information (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 providers (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 Pineapple Tours 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 explicit consent and 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.

How do we collect personal information?
We will only collect personal information in compliance with your local data protection laws. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this 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, 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.

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 Pineapple Tours to collect, use and disclose the other person’s personal information in accordance with this Notice and that you have otherwise made the other person aware of this Notice.

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.

We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all of your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information relating to you (see section 13 below). We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you, or a person acting on your behalf, provide to us.

How do we use your personal information?
We will only process your information, where:

you have given your consent to such processing (which you may withdraw at any time, as detailed at section 8 below);
the processing is necessary to provide our services to you;
the processing is necessary for compliance with our legal obligations; and/or
the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information (as detailed in sections 5 and 6 below).
In detail: Where you contact us in relation to a travel booking or query, the 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 Notice (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc.).

When you book or otherwise arrange travel related products and services through us, we usually act as an agent for the relevant travel service providers (e.g. for a hotel). In this case, we process your personal information as necessary so as to provide the services you requested from us. This usually includes collecting personal information about you both for our internal purposes as described in this Notice and for the travel service provider for whom we act as agent (e.g. to provide you with the booked services). For example, if you book a flight through us, then we use your personal information to enable your flight to be booked and disclose it to the airline to enable the airline to provide the flight service to you.

We may therefore share your information with our travel service providers such as hotel, airline, car rental, or other providers, who fulfill your travel bookings. Please note that these travel service providers also may use your personal information as described in their respective privacy policy and may contact you as necessary to obtain additional information about you, facilitate your travel reservation, or provide you with your requested services. We encourage you to review the privacy policies of any third-party travel service providers whose products you purchase through us. We will provide you with copies of all relevant travel service provider terms, conditions and privacy policies on request.

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 Notice 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 6 below.

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 (section 13).

The purposes for which we collect personal information further include:

providing you with services and tools you choose to use (for example, saving travel preferences on our websites to a wishlist or saving personal information to allow for pre-population of online forms);
identification of fraud or error;
regulatory reporting and compliance;
developing and improving our products and services and those of our related entities;
servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences;
involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided;
to facilitate your participation in loyalty programs;
for research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and travel destinations and use of our websites;
internal accounting and administration;
to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel; and
other purposes as authorised or required by law (e.g. to prevent a threat to life, health or safety, or to enforce our legal rights).
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 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, MMS 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 (section 13). You can unsubscribe from receiving electronic marketing materials by following the unsubscribe prompt in your email, SMS, MMS, iM or other form of electronic marketing. Please also see the “Your rights” section of this Notice to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes (section 8 below).

Is personal information disclosed to third parties?
We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Notice and, in particular, as set out below, and in accordance with your local data protection laws. Note that, in this Notice, 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:

our contractors, suppliers and service providers, including without limitation:
in each of the circumstances set out in section 4 (“How do we use your personal information?”);
suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting providers we may use);
publishers, printers and distributors of marketing material;
event and expo organisers;
marketing, market research, research and analysis and communications agencies;
mailing houses, freight services, courier services; and
external business advisers (such as lawyers, accountants, auditors and recruitment consultants);
our related entities and brands;
travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
any third party to whom we assign or novate any of our rights or obligations;
a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);
your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;
a person who can verify to us that they have a relationship with you (e.g. a family member) where you are not contactable, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
as required or authorised by applicable law, and to comply with our legal obligations;
customs and immigration to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
government agencies and public authorities to comply with a valid and authorised request, including a court order or other valid legal process;
various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
enforcement agencies where we suspect that unlawful activity has been or may be engaged in and the personal information is a necessary part of our investigation or reporting of the matter.
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 suc