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Privacy Policy
 

In this document, “Dingo's Fraser Island Tours”, “we”, “our”, or “us”refers to Australian Adventure Group Holdings Pty Ltd (ACN 661 075 163) trading as Dingo's Fraser Island Tours and we are responsible for your personal data – our relevant contact details are at the end of this notice.

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Dingo's Fraser Island Tours (Dingo's) takes your privacy seriously and is committed to responsible privacy practices.  
Dingo's seeks to comply with relevant laws, including the Privacy Act 1988 (Cth) (Privacy Act).  


This policy describes how Dingo's manages your personal information including details of what types of personal information Dingo's collects, how Dingo's collects your personal information, the purposes for which Dingo's uses your personal information and to whom your personal information is disclosed.


1.    What is personal information?


In this policy “personal information” has the meaning set out in the Privacy Act.  Essentially, personal information is information or an opinion about an individual who is reasonably identifiable.  

   
2.    What types of personal information do we collect?


The types of personal information Dingo's collects about you will depend on the purpose for which the information is collected.  Dingo's may collect the following types of personal information from each customer participating on a tour:

 

  • full name, date of birth and gender;

  • place of residence (ordinary and temporary);

  • contact details such as postal address, email address and telephone number;

  • government-issued identifiers, including passport details or driver's licence details;

  • bank account details, credit card details or other payment account details; and

  • if you are an individual contractor to Dingo's or are seeking employment by Dingo's, Dingo's may collect information relevant to your engagement including qualifications, resume, pay rate and salary, bank details, feedback from referees and training records.

 

In certain circumstances, Dingo's may also collect sensitive information such as health information, including details of a disability, medical condition, allergies or other specific health requirements.

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Dingo's also collects general analytics and other technical information (such as your IP address, device type, unique device identification numbers, browser types, Internet Service Provider details, geolocation data, browsing preferences, searches, and usage of Dingo's websites or products) arising from your use of Dingo's websites or products. 

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In addition to the types of personal information identified above, Dingo's may collect personal information as otherwise permitted or required by law.


3.    How do we collect personal information?


Often Dingo's will collect your personal information directly from you, including when you:

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  • use Dingo's websites, products or services;

  • apply to work with Dingo's or are engaged by Dingo's as a contractor;

  • communicate with Dingo's by email, by telephone, in person, via a website or otherwise.

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As Dingo's business is to provide products and services to groups and third it may also collect personal information from:

 

  • its related companies;

  • publicly available sources;

  • entities with which Dingo's conducts business; and

  • other third parties (for example, from referees if you apply for a position as an employee or contractor with us or an agent or other person who makes a booking on your behalf).


THIRD-PARTY COOKIES AND TRACKING TECHNOLOGIES

Dingo's uses the services of third-party vendors, who may implement one or more persistent “Tracking Technologies” (such as cookies, eTags, pixels, local storage, or other identifiers on your device and browser settings) in order to recognise you and your device each time you visit our website.  We use these technologies for a number of purposes to enhance your online experience, such as preference settings, analytics, conversion attribution and fraud reduction. We use both session and persistent tracking technologies.
Advertisements or other services on the website may be provided by third-party agencies.  These advertisements may also include tracking technologies. The collection, use, and disclosure of information, including personal data, collected by such third-party tracking technologies are subject to the privacy and data protection policies of the third-party vendors and are not under our control.  For more information on third-party advertising-related cookies and how to opt-out of them, please visit Your Online Choices http://www.youronlinechoices.com.au/.


You may reject first-party and third-party tracking technologies through the settings on your browser.  Note that this may result in the loss of website functionality, restrict your use of the website, or delay or affect the way in which the website operates.  
We may use third-party service providers to monitor and analyse the use of our website.  The primary service providers we use are:

Google Analytics and Google Optimize

 

Dingo's uses certain Google Analytics functions.  Please see this link https://policies.google.com/technologies/partner-sites for how your data is collected and this link https://developers.google.com/analytics/devguides/collection/analyticsjs/user-opt-out  for instructions on how to opt-out of any Google Analytics data tracking.
 

Dingo's may use Google Analytics features based on Display Advertising, including but not restricted to the following: Google Optimize, Remarketing, Google Display Network Impression Reporting, and Google Analytics Demographics and Interest Reporting.  Using the Google Ads Settings, you can opt-out of Google Analytics for Display Advertising and Google Optimize and customise Google Display Network ads.

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Dingo's also uses Remarketing with Google Analytics to advertise online; third-party vendors, including Google, may show Dingo's ads on sites across the internet.  Dingo's and third-party vendors, including Google, use first-party tracking technologies (such as the Google Analytics cookie) and third-party tracking technologies (such as the DoubleClick cookie) together to inform, optimise, and serve ads based on visitors’ past visits to our website, as well as report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.


Facebook Analytics and Facebook Insights


Facebook Insights is a tool which tracks user interaction on our Facebook page, allowing page admins to track usage and improve page performance.  


Facebook Analytics is a behavioural analytics solution that helps to track, measure, better understand, and optimise products and customer experience and provides audience information and unifies analytics across devices and channels.  
Facebook’s Privacy Policy can be seen here: https://www.facebook.com/full_data_use_policy.  If you want to opt-out of seeing ads on Facebook based on information we’ve received from other websites and apps, you can control this in your ad preferences: https://facebook.com/ads/preferences.


4.    Why do we collect, use and disclose personal information?


In general Dingo's collects, uses and discloses your personal information for purposes connected with its business operations.
Dingo's will only collect, use, and disclose personal information about you if it has lawful basis to do so, for example: 

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  • where you have given Dingo's your consent; 

  • where processing of your personal information is necessary for the performance of the good or services that you have requested;

  • to meet Dingo's legal obligations; and 

  • to pursue Dingo's legitimate business interests.
     

Dingo's may use or disclose your personal information:

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  • for the purposes for which Dingo's collected it (and related purposes which would be reasonably expected by you);

  • for other purposes to which you have consented; and

  • as otherwise authorised or required by law.

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Some of the specific purposes for which Dingo's collects, uses and discloses personal information are as follows:

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  • to provide its products and services to customers participating on a tour;

  • to enable the proper operation and functionality of its products and services including the delivery of tour service and billing and payment functions;

  • to improve its products and services;

  • to verify your identity (for example, if you request access to the personal information Dingo's holds about you);

  • to consider you for a job at Dingo's(whether as an employee or contractor) or other relationships with Dingo's;

  • to provide goods or services to you or to receive goods or services from you;

  • to address any issues or complaints that Dingo's has, or you have, regarding our relationship;

  • to comply with its legal obligations;

  • to develop and improve the quality of its websites and products and customise its websites and products according to your preferences, tailor search results, and show relevant advertising;

  • for direct marketing purposes (see the "Direct marketing" section below); and

  • to contact you regarding the above, including via electronic messaging such as SMS and email, by mail, by phone or in any other lawful manner.


If Dingo's is unable to collect your personal information then Dingo's may not be able to provide you with the products, services and opportunities that depend on the collection of that information.


5.    To whom do we disclose personal information?
 

Dingo's may disclose your personal information to third parties in connection with the purposes described above.
This may include disclosing your personal information to the following types of third parties:

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  • its related companies;

  • any potential third party acquirer of Dingo's or its business or assets, and advisors to that third party;

  • its professional advisers (such as lawyers, accountants or auditors) and insurers;

  • its employees, contractors and third party service providers who assist Dingo's in performing its functions and activities e.g. catering operators and financial institutions, cloud service providers, data storage providers, telecommunications providers and IT support services providers;

  • organisations authorised by Dingo's to conduct promotional, research or marketing activities;

  • third parties to whom you have authorised Dingo's to disclose your information (e.g. referees); and

  • any other person as required or permitted by law.


If Dingo's discloses your personal information to third parties it will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose of disclosure and in a manner consistent with applicable laws, for example by (where commercially practical) including suitable privacy and confidentiality clauses in Dingo's agreement with a third party service provider to which Dingo's discloses your personal information.


6.    Does personal information leave Australia?
 

Dingo's stores personal information in servers located in Australia.  However, Dingo's may disclose your personal information to overseas recipients, such as to service providers located overseas, in order to provide its products and services and to obtain services.  Such overseas recipients may be located in a large number of different countries.  It is not practical for Dingo's to list every country where such overseas recipients may be located.  


Except where an exception applies under the Privacy Act or other relevant legislation, Dingo's will take reasonable steps to ensure that overseas recipients to whom Dingo's discloses personal information do not breach the Australian Privacy Principles stated in the Privacy Act, and any other relevant legislation relating to privacy and data security, in relation to such information.


7.    How do we protect your personal information?
 

Dingo's engages service providers to store your personal information.  Dingo's recommends that you review these companies' privacy policies to understand how they use and store your personal information. 
 

Dingo's will take reasonable steps to keep any personal information it holds about you secure.


However, you acknowledge that the security of personal information transmitted over the internet cannot be guaranteed. Dingo's cannot guarantee that any personal information you disclose to Dingo's will not become publicly available.  Except to the extent liability cannot be excluded due to the operation of statute, Dingo's excludes all liability (including in negligence) for the consequences of any unauthorised access to, disclosure of, misuse of or loss or corruption of your personal information.
Nothing in this policy restricts, excludes or modifies or purports to restrict, exclude or modify Dingo's obligations under the Privacy Act and any other applicable legislation or any statutory consumer rights you may have under any applicable law including the Competition and Consumer Act 2010 (Cth). 


Please notify Dingo's immediately if you become aware of any breach of security.


8.    Direct marketing
 

Dingo's may use and disclose your personal information for the purpose of direct marketing to you if:


•    you have consented to Dingo's doing so; or
•    it is otherwise permitted by law.


Direct marketing involves communicating directly with you for the purpose of promoting goods or services to you.  Direct marketing can be delivered by a range of methods including mail, telephone, email or SMS.  You can unsubscribe from Dingo's direct marketing, or change your contact preferences, by contacting Dingo's (see the "How to contact us" section below). 


9.    How long do we keep your personal information?


Generally, Dingo's will retain your personal information for the period necessary for the purposes for which your personal information was collected (as outlined in this policy) unless a longer retention period is required by law. 
Dingo's may retain your personal information for a longer period of time if it is reasonably necessary to comply with Dingo's legal obligations, resolve a dispute or maintain security. 


When personal information is no longer required, Dingo's will take reasonable steps to delete the personal information from Dingo's systems or de-identify the personal information. 


10.    Your rights


How you can seek to access and correct personal information we hold about you
You may seek access to personal information Dingo's holds about you by contacting Dingo's as described in the "How to contact us" section below.  

 

Dingo's will provide access to that information in accordance with applicable legal requirements, subject to certain exemptions which may apply.  Dingo's may require that the person requesting access provide suitable identification and where permitted by law Dingo's may charge a fee for giving access to your personal information.


If the personal information was provided to Dingo's by an agent, Dingo's may advise the relevant agent of your request and liaise with them about it.  


If you become aware that any personal information Dingo's holds about you is incorrect or if you wish to update your information, please contact Dingo's as described in the "How to contact us" section below.


How you can complain about a privacy issue


You may make a privacy complaint in relation to personal information Dingo's holds about you by contacting Dingo's as described in the "How to contact us" section below.  


If you make a privacy complaint, Dingo's Data Protection Officer or another suitable staff member of Dingo's will investigate the matter and attempt to resolve it as soon as reasonably possible.


If you consider your privacy concerns have not been resolved satisfactorily by Dingo's, or you wish to obtain more information on privacy requirements you can contact the Office of the Australian Information Commissioner on 1300 363 992 or visit their website at www.oaic.gov.au; and Dingo's may ask you to provide suitable identification when you seek to exercise any of these rights.


11.    Local exemptions and inconsistency with law


Where local laws allow for an exemption to compliance with certain legal obligations (for example, the employee records exemption in Australia), Dingo's may rely on such an exemption.
This policy will not apply to the extent that it is inconsistent with any applicable law.


12.    Changes to this policy
 

Dingo's may change this policy from time to time at its discretion.  This policy was last updated in September 2019.  If Dingo's makes further updates to this policy, Dingo's will post the amended policy on its websites.  Your continued dealings with Dingo's, for example use of its websites, products or services, will signify your agreement to this policy as amended.


13.    How to contact us


If you have a query, concern or complaint about the manner in which your personal information has been collected or handled by Dingo's or would like to request access to or correction of the personal information Dingo's holds about you please contact Dingo's Data Protection Officer via email to dataprotection@dingosfraser.com.

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