1. Introduction

The Branksome Residence Pty. Ltd., trading as The Branksome Hotel & Residences (TBHR) is committed to protecting the privacy of your personal information. Your personal information is any information that identifies you and could include your bio data, your actions and decisions (such as your travel pattern) or even your opinion. This Privacy Policy spells out how we manage your personal information and how to contact us if you have any privacy concerns.

This Privacy Policy applies to all personal information collected, held and used by TBHR from our guests, visitors to the TBHR website www.thebranksome.com.au or that of any of its subsidiaries (Group), subscribers to the distribution list, followers on social media, purchasers of our services and products and any other individual who interacts with us.

Please read these terms prior to purchasing any services or products from us or using our websites, or when you are directed to do so during your online transactions with the TBHR.

This Privacy Policy also confirms our obligations under the Privacy Act 1988 (Cth), including the Australian Privacy Principles, or APPS.

2. Collecting Personal Information

The type of personal information TBHR collects from you will be dependent on the circumstances and/or on the type of service that you may have requested. It may include details such as (but not limited to):

• your name;
• gender;
• date of birth;
• contact details;
• passport details;
• driver’s license details;
• details from any photo identification produced;
• loyalty program details;
• credit card number;
• health issues & dietary requirements relevant to your travel and stay; and
• your preferences with regards to accommodation configuration.

This personal information is collected from you so that we are able to:

• respond to your enquiries;
• provide you with services & products that you may have requested;
• verify your identity ;
• comply with our legal & regulatory obligations;
• respond appropriately in times of emergencies or accidents; and
• conduct marketing activities for our products & services or products that you may be interested in.

We will collect different types of personal information from you depending on how you interact with us and how we can help you.

The types of personal information that we may collect are set out below:

• When you book a stay with us online, over the phone or through one of our travel or booking agents, the personal information we collect are your name, address, phone number, email address, credit card details, passport details, membership number and information about your travel plans. If it is relevant to you and your stay with us, we may also collect information about your dietary requirements and health issues, and any preferences or assistance required during your stay with us.
• At check-in, we will already hold some of your personal information and we may also collect your passport or drivers' licence number, for identification purposes. Please refer to ‘Government Related Identifiers’ in this Privacy Policy.
• When you subscribe to an email distribution list, we may collect your name, email address, postcode, membership number and employer's contact details (where you have specified a business address). In addition we may also collect your travel history, sporting & lifestyle interests and your membership of other loyalty programs.
• We use cookies and other web-tracking tools on our website. These tools collect and use your personal information.
• If you give us feedback about our services or products, then we will collect the personal information that you provide.
• If you use social media to interact with us, we may collect your user name and any information that you allow the social media site to share with us; such as your profile picture, posts, friends list and contact details.
• If you are applying for employment with us, your personal information may be collected during the recruitment process.
• If you call our Reservations team or elsewhere, we may record the calls and we will collect any personal information you provide during the call.
• We will collect any personal information that you provide in forms that you complete for us; such as claim forms, lost object forms etc. These forms may be paper, or electronic on our websites.
• If you enter one of our competitions, we will collect the information specified in the Registration  form.
• If you are a shareholder we (or our agent) will collect certain details about you for registration purposes, such as your name, address, number of shares held, tax file number and bank account details. We are required to maintain a register of shareholders under the Corporations Act 2001 (Cth).

We may collect personal information from the following sources:

• Our hotel/airline partners.
• Our travel agents and booking agents and websites, where you book (or make enquiries to book) your booking through them.
• Our corporate partners, such as car rental providers, accommodation partners, airport transfer and parking providers, and travel insurance providers.
• If your reservation is provided through your employer's corporate travel agreement with the TBHR, we will collect your personal information from the corporate account holder or the relevant travel management company.
• We collect personal information contained in CCTV footage from the Hotel during your stay including footages from other Group premises.
• We collect personal information from immigration, customs, border security and other regulatory authorities.
• We may collect personal information from third parties who provide services; such as call centres, catering, etc.
• We collect personal information from third parties that run competitions and other promotions for us or for which TBHR is the sponsor.
• We collect personal information from you when you provide feedback or make an enquiry.

We will notify you when we collect personal information from you or about you from someone else. Depending on how you have interacted with us, we may provide a link to this Privacy Policy or advise you verbally or by email.

Where we collect your personal information from someone other than you, it is generally because you have made a booking through one of our agents or partners, or we are required to by law. If we collect information from you because we are required to or authorised by an Australian law or court or tribunal order to do so, we will tell you and we will include the details of the law, court or tribunal order.

As TBHR is required by law to obtain your consent to the collection of ‘sensitive information’ relevant to your booking, we will assume that you have consented to the collection of all information (including sensitive information) which is provided to us for use in accordance with this Privacy Policy, unless you have informed us otherwise. We will only collect sensitive information (which is a category of personal information that includes information about things like your health, dietary information, sexual preferences and genetic or biometric information) from you with your consent and where it is reasonably necessary for us to provide you with our services or carry out our functions or activities.

If we cannot collect personal information (including sensitive information) from you, we may not be able to provide you with our services or products. For example, we will need your personal details in order to book a hotel stay. You cannot stay with us if you do not give us that information.

Another example would be if you have a health condition which means you will need some assistance during your stay; we will collect information about this from you, however you must give your consent first. If we need to use or disclose your personal information for a purpose that is not set out in this Privacy Policy, or that is otherwise unrelated to the purpose for which we collected your personal information, we will obtain your consent first.

There are some circumstances where we may not need your consent, and these are set out in the Privacy Act. This covers things like our dealings with Australian customs and other law enforcement bodies. You can read more about this here.

TBHR will, at all times, collect personal information in a fair and lawful manner.

2.1 Employment Process

When you apply for a job with us, we will collect personal information, including sensitive information, as part of the application process.

We may also obtain personal information about you from third parties, for example, from your previous employers or nominated referees. We collect personal information for the purpose of assessing and progressing your application. We will hold your personal information for future job opportunities with us, unless you tell us not to. We destroy hard copies of your personal information when we no longer require this information.

We may disclose your personal information to our related entities, your referees and also to third party suppliers that we use to help with our recruitment processes, such as recruitment agencies and organisations. We may also disclose your personal information to law enforcement agencies to verify whether you have a criminal record.

3. CCTV Policy

We operate CCTV cameras in the Hotel and around our workplaces. Generally all public access areas of the hotel like the lobby, corridors, lifts, restaurant, sports centre and all access points to the hotel. There will be no CCTV in any of the rooms. All places where CCTV is in operation will have signage that state CCTV in operation. We may collect personal information from you, if you are reasonably identifiable from the images captured by these cameras. We collect such personal information so that we can maintain security at our workplaces and meet our legal & regulatory obligations.

We use and disclose images captured by our CCTV cameras (which may include your personal information, if you are reasonably identifiable in the recording) for the purposes of:

• monitoring access to our premises, rooms and workplaces;
• identifying security threats or unusual behaviours;
• investigating accidents or incidents in connection with complaints, claims or other safety or security issues or investigations; and
• liaising with law enforcement agencies and regulators.

Our use or disclosure for any or all of the above purposes may also result in your personal information being disclosed to our related bodies, corporate and third parties who provide us with (or help us) operate and manage the CCTV cameras, including image recording and storage services and telecommunications services. We do not use or disclose the images captured by our CCTV cameras for any other purpose.

If you do not wish to be recorded by our CCTV cameras, then you will be unable to be at our hotel or workplaces. We are unable to switch on/off the CCTV cameras on an individual basis.

We are unlikely to disclose your personal information contained in CCTV recordings made by us to persons located overseas, unless we are required or authorised by law or court/tribunal order, or otherwise under the Privacy Act 1988 (Cth).

4. Anonymous or Use of a Pseudonym

You have the option to remain anonymous or use a name other than your own (a ‘pseudonym’). We will try to provide you with this option wherever we can. However, you won't be able to be anonymous or use a pseudonym if you would like to stay at our hotel, use any of our services or if you would like to work with us. We need to know who you are. If you write to us using a pseudonym, we may not necessarily respond to you.

5. Usage and Disclosure

We will only use and disclose your personal information that we hold about you for the primary and related purposes for which we collected it, and for any other purpose you consent to. We may use your personal information to:

• Process your booking and hotel stay.
• Keep sales records.
• Facilitate participation in any competitions.
• Distribute newsletters and other communications either by ourselves or with assistance of third party services providers.
• Communicate with you about your booking, provide other related services and validate your identity at check-in. We may also communicate with you after your stay, including requesting your feedback about your experience with us.
• Communicate with our other corporate partners about your booking or your loyalty programs, for partner recognition and benefits.
• Communicate with our corporate partners to process your booking and travel arrangements and, if applicable, to arrange complimentary partner membership and other benefits for you.
• Communicate with our travel and booking agents and website providers, about your booking and your experience with us, including any feedback we receive from you about your experience.
• Share personal information with our related entities, including to enable us to send you marketing materials based on your membership activities and other online behaviours. Communicate with third parties who provide prizes for promotions or competitions, including your contact details and other information you provide when entering a competition.
• Receive services from our third party service providers, including but not limited to those providing catering, airport transfers, airport lounge, technology & related support services, call centre services, marketing and advertising services, payment fulfilment & fraud protection services and data analysts, as part of our activities and operations.
• Communicate with a travel agency about your booking and reservation arrangements (if your  booking is made through a travel agency) including disclosing check-in or ‘no-show’ status.
• If your reservation is part of a group booking, communicate with the person who made the booking on your behalf and other persons included in the group booking about your reservation and travel arrangements. We will also communicate with frequent flight rewards programs, if your membership number has been included in the booking.
• If your reservation booking is made by another person on your behalf, communicate with that person who made the booking, about your reservation and travel arrangements.
• Communicate with our professional service providers and insurance companies, as part of our operations.
• Communicate with you about our offers, and those of our related entities and partners, and to identify products and services that may be of interest to you. We may also conduct customer satisfaction surveys and other market research. We could use and disclose personal information to our marketing service providers.
• Provide customer support including responding to feedback and complaints.
• Meet our audit, reporting and investigations requirements and for operational or regulatory compliance purposes.  This includes us communicating with law enforcement agencies and regulators, both in Australia and overseas.
• Help us continuously improve the services and products we offer our guests.
• Ensure the safety and security of all guests staying with us.
• Maintain records and comply with our legal obligations.

TBHR may disclose your personal information to others in connection with the provision of our Hotel services including insurance. We may also disclose your personal information if we are required by law to do so. If we need to use your personal information for any other purpose, we will obtain your consent first, unless:

• We are required by law to do so. This will often cover our dealings with Australian customs and other law enforcement authorities; or
• We are required or authorised under the Privacy Act. You can read more about this here.

6. Disclosure of Information Overseas

TBHR does not normally contract out services overseas that involve disclosing personal information, so personal information will not normally be disclosed to third parties overseas. If TBHR contract out services overseas where personal information may be disclosed to third parties who may be located overseas, we are required to take measures to ensure that your information will be protected. In addition to any local data privacy laws to which those entities are subjected to, we will have measures in place to ensure that those parties hold and use such information in accordance with the consent provided by the individual and in accordance with our obligations under the Privacy Act.

Please refer to exceptions and new circumstances here.

7. Using Personal Information for Marketing Purposes

Personal information may be used from time to time for marketing purposes. Please contact us to tell us your marketing preferences. We use personal information that we hold about you to identify services and products that may be of interest to you. If you have consented or if otherwise permitted by law, we may also contact you by email with marketing material that may interest you if you have provided us with your email address in connection with your enquiry. We may contact you by email, text message, and phone or by post to let you know about our special promotions or any new or existing products or services. We also use internet-based marketing including targeted online advertising and online behavioural marketing however, in all such cases, you will be given the option of not receiving further communications of that nature. We will not use your health information or other sensitive information that we hold about you for marketing purposes, without your consent.

You have the right to request not to receive direct marketing communications from us, or request us to provide our source of your personal information. You can let us know at any time if you no longer wish to receive marketing materials from us, our related entities or our partners. TBHR will comply with these requests within a reasonable period and free of charge.

We will assume that, unless you tell us otherwise, you consent to the collection of the information that you provide to us (either directly or indirectly) for the use and disclosure by us in accordance with this Privacy Policy.

8. Government Related Identifiers

Your passport or drivers’ licence number are known as ‘government related identifiers’. We only use these numbers to verify your identity when you are staying with us. We may need to disclose these details to law enforcement agencies or if we are otherwise required to do so by law or court order. You will not be uniquely identified in our systems by these identifiers.

9. Holding and Keeping Personal Information Safe

TBHR mostly holds personal information electronically (including telephone recordings and emails) in our IT systems and databases. TBHR will take reasonable steps to protect information that we hold about you from misuse, interference and loss, and from unauthorised access, modification or disclosure. We do this by having physical and electronic security systems and by limiting who can access your personal information. We also have online and network security systems in place for our websites, so that the information you provide us online is protected and secure.

The following is a description of the website security we deploy. TBHR website and its subsidiary Company websites use Secure Sockets Layer (‘SSL’) encryption technology which can help prevent unauthorised third parties intercepting information passing between the TBHR website and your browser. If encrypted transmission is indicated, TBHR currently uses 256 bit SSL encryption. Your browser should indicate whether the information you are sending TBHR is encrypted or unencrypted.

SSL enabled web pages can be identified by their URL: they begin with 'https://'. In contrast, standard pages generally begin with 'http://'.

Due to the nature of the internet, no one, including TBHR, can guarantee that data passing over the Internet cannot be intercepted or used by unauthorised third parties. Accordingly, although TBHR works hard to protect that information, it cannot ensure or warrant the security of any information you transmit to it and will not be responsible for any events arising from unauthorised access to the information you provide. Once TBHR receives information that you have transmitted to it, TBHR will take reasonable steps to preserve the security of that information in its own systems. Please contact us if you become aware of any breach of security.

In the event we receive information that TBHR did not intend to collect, or if TBHR determines that we no longer need that information, it would be destroyed or de-identified if it is not contained in a Commonwealth record and if no longer needed for a lawful purpose under the APPs.

10. Accessing and Updating Personal Information

We try to ensure the information that we hold about you is accurate, complete, relevant and up-to-date. We do this by regularly reviewing our customer databases and updating or removing out-of-date, misleading or incorrect data. Please help us to do this by letting us know if your details change or we send you an email or letter that contains incorrect details. You have a right to request access and correct the personal information that we hold about you. If you would like to check that the information we hold about you is correct, find out about what information we hold about you, or make a correction, please contact us, either by calling Reservations or making an online request. TBHR, upon request, will provide you with access to your personal information, or if the personal information it holds about you is inaccurate, incomplete or out-of-date, it will update or correct it upon you contacting us. TBHR may require personal identification so that we can respond to your request. We cannot give you information about other people. Please click here to read about exceptions.

Sometimes we will be able to respond to your query over the phone, but sometimes we may need your request in writing and we might need some time to gather the requested information and get back to you. The more complex requests will take approximately 30 days for a response. We might need to send a copy of the information to you by post or we might ask you to come and see us to have a look at the information.

Making a request is free, but depending on what information you request access to, we may recover from you reasonable costs of supplying you with access to the information. The charges will not be excessive and we will let you know if a charge is applicable before we proceed with giving you access. There is no charge for updating or correcting your personal information.

There may be reasons that we cannot provide you with access to the personal information, or we refuse to correct your personal information. If this is the case, we will provide you with reasons for the refusal in writing, and inform you of any exceptions relied upon under the Privacy Act 1988 (Cth), including the APPs. If TBHR refuses to correct your personal information that we hold, you can ask us to associate with that information a statement that the information is inaccurate, out-of-date, irrelevant or misleading. We will take reasonable steps to associate this statement with your personal information that we hold so that users of the information are aware of it; or if we refuse you access to your personal information, you can make a complaint about this by following the complaint procedures in this Privacy Policy.

If we update information that we hold about you, and we have given this information to a third party, then we will take reasonable steps to ask that third party to also update the information that it holds about you.

11. Cookies and Web-tracking Tools

Like many other websites, our Site may use "Cookies" or "Other Technologies" (such as "pixel tags," "web beacons," "clear GIFs", links in emails, JavaScript, device IDs assigned by Google or Apple, or similar technologies). Cookies and Other Technologies allow us and third parties to obtain information about your visits to the Site, including to analyse your visiting patterns. We use this information to process your reservations or requests and to deliver online and mobile advertisements, messages and content for us and others that are specific to your interests.

Cookies may be used on the Site in order to improve your experience . Some cookies support the function of services that you need from www.thebranksome.com.au

• Remember your user name and password for future visits so that log-in is easier and faster;
• Remember your language and other preferences;
• Ensure you obtain all requested information;
• Provide a safe and secure service for online transactions;
• Track your response to advertisements and website or app content for analysis and the number of times we send you the same advertisement;
• Measure how many people use the Site, and how they use it, so that we may keep it running quickly and efficiently; and
• Help us and others deliver communications and content to you that are relevant and responsive to your interests and location.

Below we explain the different types of Cookies that may be used on the Site

• Essential Cookies: Essential Cookies are necessary for the Site to work, and enable you to move around it and use its services and features. Disabling these Cookies may make the services and features unavailable.
• Functional Cookies: We use Functional Cookies to save your settings on the Site—settings such as your language preference, or booking information you have previously used when booking a hotel with us. We also use Functional Cookies to store such things as the last hotel you searched for, so that you can easily find it the next time you visit. Some Functional Cookies are essential to viewing maps or videos on our Site. We also use "Flash Cookies" for some of our animated content.
• Session Cookies: These types of Cookies are stored only temporarily during a browsing session, and are deleted from your device when you close the browser. We use Session Cookies to support the functionality of the Site and to understand your use of the Site—that is, which pages you visit, which links you use and how long you stay on each page.
• Persistent Cookies: These types of Cookies are not deleted when you close your browser, but are saved on your device for a fixed period of time or until you delete them. Each time you visit the Site, the server that set the Cookie will recognize the persistent Cookie saved on your device. We and others use persistent Cookies to store your preferences, so that they are available for your next visit, to keep a more accurate account of how often you visit the Site, how often you return, how your use of the Site may vary over time and the effectiveness of advertising efforts.
• Advertising Cookies: These types of cookies allow us and other advertisers to show you the most relevant products, offers, and advertisements on the Site and third-party sites, or through emails or other message platforms. For example, some Advertising Cookies help our service providers and other advertisers select advertisements that are based on your interests, including those expressed or inferred by visits to our websites or apps or across other websites, online services, and apps over time. Others help prevent the same advertisement from continuously reappearing for you. These types of Cookies also help us provide you with content on the Site that is tailored to your interests and needs.

As noted below, some Analytics Cookies and Other Technologies are used in part to facilitate advertising.

• Advertising Cookies also include Social Plug-In Cookies. Social Plug-In Cookies are used to share content from the Site with members and non-members of social media networks such as Facebook, Twitter, YouTube and Pinterest. These Cookies are usually set by the social networking provider, enabling such sharing to be smooth and seamless.
• Analytics Cookies collect information about your use of the Site, and enable us to improve the way it works. These Cookies give us aggregated information that we use to monitor site performance, count page visits, spot technical errors, see how users reach the Site, and measure the effectiveness of advertising (including emails we send to you).
• Other Technologies may be used for the same purposes as our Cookies, to allow us and third parties to know when you visit the Site, and to understand how you interact with emails or advertisements. Through Other Technologies, non-personal information (e.g., your operating system, your browser version, and the URL you came from) or aggregate information may be obtained and used to enhance your experience and understand traffic patterns

If you wish to continue using TBHR website you need to accept cookies. Please be aware that accepting cookies will result in cookies being set (subject to browser settings) and that any further use of this site will be taken as accepting their use.

Please be aware that if you decline the use of cookies set by TBHR on www.thebranksome.com.au you will be unable to use our website.

12. Availability and Changes to the TBHR Privacy Policy

TBHR Privacy Policy is available on our website www.thebranksome.com.au. TBHR may update this policy from time to time. Changes are effective upon posting on the website. By continuing to use our websites or otherwise continuing to deal with us, you accept this Privacy Policy as it applies from time to time.

If you would like us to send you a copy of our Privacy Policy by post, please call us at the Customer Contact Centre or make a request online and we will send you one for free.

13. Privacy Complaints or Concerns

If you have a concern about your privacy, or you have any queries in relation to this policy or its administration or if you have a privacy complaint, please contact us;

• by calling our Reservations team on 02 8338 3200
• or via email at enquiry@thebranksome.com.au

Once we have received your complaint, we will investigate and respond to you as soon as we can. We try to do this within 15 working days of receiving your complaint. If this is not possible, we will contact you and let you know when we will respond to your complaint.

We take any privacy complaint seriously and will deal with your complaint fairly and promptly. However if you are not satisfied with our response or how we handled your complaint, you may complain to the Office of the Australian Information Commissioner (in writing) at:

Office of the Australian Information Commissioner (OAIC)
GPO Box 5218
Sydney NSW 1042
Phone: 1300 363 992
TTY: 1800 620 241
email: privacy@privacy.gov.au