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Privacy Policy

Updated

Purpose and nature

This Privacy Policy explains how your personal information will be collected, stored, used, disclosed, protected and otherwise handled when you access and use the Bonza Holidays Platform, having regard to the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (Privacy Act). Awai Pty Ltd (ACN 651 053 940) trading as "AWAI" (AWAI) will collect your personal information when you access the Bonza Holidays Platform, and it recognises the importance of your privacy.

As the exclusive flights provider for the Bonza Holidays Platform, all personal information that you provide to AWAI when accessing or using the Bonza Holidays Platform will be accessed by Bonza Aviation Pty Ltd (ACN 653 309 909) (Bonza). In accordance with this policy, you consent to AWAI disclosing your personal information to Bonza. Bonza will collect, store, use and disclose your personal information in accordance with its privacy policy and we recommend you review the terms of its policy in addition to the terms of this privacy policy.

This Privacy Policy does not constitute a contractual representation, promise, guarantee or warranty by AWAI or Bonza to you as to the manner in which AWAI or Bonza will or may collect, store, use, disclose, protect or otherwise handle your personal information. This Privacy Policy applies to AWAI and its related entities, such as its subsidiaries (whether in existence now or in the future), and their employees. These related entities comply with the same obligations that AWAI has to protect your personal information under this Privacy Policy.

This Privacy Policy does not cover the privacy practices of third parties that we do not own or control, such as the service providers who provide the travel products and services available to book on the Bonza Holidays Platform (Suppliers).

These Suppliers include hotel and insurance providers. They also include Bonza, which will provide you with Bonza flights when you make a booking through the Bonza Holidays Platform. For the avoidance of doubt, despite the use of the word 'Bonza' on the Bonza Holidays Platform and in this privacy policy, Bonza and AWAI are not Related Entities.

When you book or purchase travel products through the Bonza Holidays Platform, your information will be collected by AWAI in accordance with this privacy policy and processed by the relevant Suppliers and other third parties, including Bonza, third-party aggregators and insurance providers from whom we may source travel products and services, in accordance with their own privacy policies and terms and conditions.

We encourage you to review the policies of our other Suppliers before submitting personal information to them.

What is personal information?

Personal information is information or an opinion about you, whether true or not and whether recorded in a material form or not, from which you can be reasonably identified.

Why does AWAI collect personal information?

AWAI collects personal information for the primary purpose of providing its travel booking service on the Bonza Holidays Platform. AWAI may also use personal information for secondary and other closely related purposes including in connection with providing, administering, improving and personalising the travel booking services available on the Bonza Holidays Platform, marketing and to support its business functions.

If AWAI does not collect your personal information, it may not be able to provide you with its services. As part of providing the Bonza Holidays Platform, AWAI must provide your personal information to Suppliers. including Bonza, and if it does not do so, neither AWAI nor Bonza will be able to provide you with their services.

What personal information does AWAI collect?

Personal Information

The types of personal information collected by AWAI include:

  • names;
  • contact details (including address, email address, telephone number(s) and other contact details);
  • dates of birth;
  • payment details (including credit card details and bank details);
  • passport and visa information;
  • gender;
  • copies of identification documents;
  • usernames;
  • passwords; and
  • health information such as dietary requirements and other details you provide when requesting special assistance; and
  • other information you provide to us.

Sensitive Information

The personal information collected by AWAI may include sensitive information, which is defined in the Privacy Act as information or an opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information. AWAI will only use sensitive information:

  • for the primary purpose for which it was obtained;
  • for a secondary purpose that is directly related to the primary purpose;
  • with your consent; or
  • where required or authorised by law.

How does AWAI collect your personal information?

AWAI will collect personal information only by lawful and fair means and not in an unreasonably intrusive manner. When you provide AWAI with personal information through use of the Bonza Holidays Platform you consent to the use, disclosure and handling of your personal information in accordance with this Privacy Policy and any subsequent amendments (see clause 13).

Collecting information from you

If it is reasonable and practical to do so, AWAI will collect personal information directly from you.
Depending on how you choose to interact with AWAI, AWAI may collect your personal information when you contact, or are contacted by, AWAI or its service providers by telephone, by email, through AWAI's website, apps, social media and other digital services or when you complete a form or document and provide it to AWAI.

Bonza may provide certain customer support services including customer support in relation to the provision of your Bonza flight, complaint handling or assistance with using the Bonza Holidays Platform. Depending on which digital application you choose to interact with Bonza on, Bonza may collect, store, use and disclose personal information in addition to what you have provided to AWAI and Bonza will do so in accordance with its privacy policy.

Collecting information from third parties

AWAI may also collect information about you from other people (eg a third party administrator) or independent sources. For example, AWAI may collect personal information about you from its services providers, including from Bonza and other Suppliers. However, AWAI will only do so where it is not reasonable and practicable to collect the information from you directly. Where AWAI has collected your information from a third party, such personal information will be held, used and disclosed by AWAI in accordance with this Privacy Policy.

Collecting information from visits to the Bonza Holidays Platform

AWAI may collect information about how you use and visit the Bonza Holidays Platform, including through the use of Google Analytics (described further below at 5.4). For example, we record your server address, the date and time of your visit, the pages you visited, any documents you downloaded, the previous site you visited and the type of device, browser and operating system you used.

We use and disclose this information in anonymous, aggregated form only for purposes including statistical analysis and to assist us to improve the functionality and usability of our website. You are not individually identified, however we reserve the right to use or disclose this information to try to locate an individual where we reasonably believe that the individual may have engaged in any unlawful or inappropriate activity in connection with the Bonza Holidays Platform, or where we are otherwise required or authorised by law to do so.

AWAI may also collect information based on how you use its website, including through 'cookies', web beacons and other similar technologies.

Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable AWAI's systems to recognise your browser and record non-personal information such as the date, time or duration of your visit and the pages accessed, for website administration, statistical and maintenance purposes (Cookie Information).

We use cookies to provide you with a more consistent experience across our services. No attempt is made by AWAI to use Cookie Information to personally identify you. However, if Cookie Information is linked with personal information as set out above, this Cookie Information becomes personal information and will be treated in the same manner as the personal information to which it has been linked.

You can remove or reject cookies by adjusting the settings on your web browser. Please note that some parts of AWAI's website may not function fully for users that disable cookies.

Google Analytics information

We use Google Analytics and the Cookie Information it collects to better understand the behaviour of our customers and provide targeted advertising to suit customers’ interests and preferences. We also use this information to help measure and research the helpfulness of website features and offers and serve relevant ads to our users.

We have implemented a range of Google Analytics Advertising Features on our website and may include additional Google Analytics Advertising Features in the future. You can opt out of the Google Analytics Advertising Features through our website. You may also download the Google Analytics Opt-out Browser Add-on as a method of opting out.

Unsolicited information

If AWAI receives personal information that it has not requested and determines that the personal information received is not reasonably necessary to provide its services, AWAI will take all lawful and reasonable steps (if any) to de-identify or destroy that personal information.

How does AWAI hold your personal information?

AWAI stores your personal information with third parties with whom AWAI has contracted to support AWAI's business operations (such as data storage providers). These third parties may access your personal data but do not use your personal data other than for storage and retrieval. The security of your personal information is important to AWAI. Accordingly, AWAI takes reasonable steps to protect your personal information from misuse, loss and unauthorised access, modification or disclosure. These steps include the implementation of the following safeguards:
1 password protected databases;
2 staff training;
3 system firewalls; and
4 internal information security policies.

AWAI will take reasonable steps to permanently de-identify or responsibly destroy personal information if it is no longer needed for the purpose for which the information was used or disclosed.

Any personal information provided to Bonza, in accordance with this privacy policy or as a result of your use of the Bonza Holiday Platform, will be stored by Bonza in accordance with its privacy policy.

Security breach procedures

AWAI's data security practices have been adopted with a view to protecting the data held by AWAI. Notwithstanding this, individuals should be aware that there are inherent risks associated with the transmission of data over the internet and other mediums. Accordingly, AWAI cannot guarantee any transmission will be completely secure.

How does AWAI use your personal information?

AWAI may hold, use or disclose your personal information so that you can search, combine and book international travel deals including flights, hotel accommodation and holiday packages through the Bonza Holiday Platform.

AWAI may also hold, use or disclose your personal information to:

  • Bonza, in order for Bonza to provide you with flights you have booked, customer service and other general complaints handling, and to otherwise assist you in accessing and using the Bonza Holidays Platform;
  • provide you with the services and related products that AWAI offers through the Bonza Holidays Platform;
  • generate results in response to your search queries for the travel products on the Bonza Holidays Platform, for example by providing you with a list of the packages, flight or hotel options that best meet your requirements;
  • facilitate the completion of your booking or purchase of the travel products you have selected, which will involve AWAI collecting and transferring information to the relevant Supplier(s), third-party aggregators and insurance providers to enable the booking to be processed;
  • redirect you to AWAI's partner platforms with the information and data that is required to enable them to recognise you and the travel option you had selected on the Bonza Holidays Platform;
  • provide support services to you in order to respond to any questions you raise, requests for assistance, or issues you might encounter while using the Bonza Holidays Platform, including any requests to change or cancel any travel booking, and respond to communications you have sent to AWAI;
  • assist you with communicating with the Supplier(s) about your booking, including Bonza;
  • personalise your experience when using the travel booking services in order to ensure your experience on the Bonza Holidays Platform is as helpful, efficient and as relevant as possible;
  • ensure that the travel booking services are accessible and usable by you on your specific device, for example by altering the way we display information to you based on your device type;
  • consider any concern or complaint that you raise against AWAI or to manage any legal action between you and AWAI;
  • request your participation in surveys run by AWAI;
  • invite you to participate in competitions or offers run by AWAI from time to time;
  • prevent or investigate any actual or suspected fraud, unlawful activity or misconduct;
  • where you have created an Account, maintain and administer your access and ensure that it is kept up-to-date; or
  • comply with any relevant laws, regulations, codes of practice and court orders.

Any personal information provided to Bonza, in accordance with this privacy policy or as a result of your use of the Bonza Holiday Platform, may be used by Bonza for the purposes set out in Bonza's privacy policy including without limitation for customer research and analysis, attribution and analytics purposes.

Direct Marketing

The personal information you provide to AWAI when accessing or using the Bonza Holidays Platform will be used by Bonza to also identify and promote products or services that may be of interest to you from Bonza. Bonza will send you promotional communications and other notifications, including regular updates, special offers or other information as requested by you. Bonza will send this to you in accordance with its privacy policy. At any time, you may opt out of receiving direct marketing communications from Bonza. To do so, you may click on the opt out link within an email you have received from Bonza, or by contacting Bonza at the details in its privacy policy.

Please note that if you opt-out of receiving promotional or marketing communications from AWAI or Bonza, you may continue to receive emails and notifications relating to the services that are necessary to fulfil your travel booking made through the Bonza Holidays Platform.

AWAI may also use your personal information to identify and promote products or services that may be of interest to you. We may send you regular updates, special offers or other information as requested by you.

At any time you may opt out of receiving direct marketing communications from AWAI. To do so, you may click on the opt out link within an email you have received from AWAI, or by contacting the person in clause 11. Unless and until you opt out, your consent to receive direct marketing communications from AWAI and to the handling of your personal information for this purpose will continue.

How is personal information disclosed to others?

AWAI does not sell, rent or trade personal information to, or with third parties other than to perform its services.

AWAI may disclose your personal information to third parties to provide its products and services, including with:

  • Bonza, as explained in this privacy policy;
  • financial institutions for payment processing;
  • its contracted services providers or partners, including:
    • the Suppliers of flights, accommodation and other travel products (which may include third party aggregators and insurance providers);
    • data storage and archive service providers;
    • marketing and communications agencies;
    • research and statistical analysis providers;
    • delivery and shipping providers; and/or
  • business advisers (such as accountants, auditors and lawyers); and/or
  • government officials or other law enforcement or regulatory agencies for the purpose of complying with or aiding in security, customs, court, investigation or public health matters.

In each case, we may disclose personal information to the service provider and the service provider may in turn provide us with personal information collected from you in the course of providing the relevant services to you.

Third Party Links

The Bonza Holidays Platform may contain links to other websites including to links of Suppliers, partners or advertisers. Websites that are owned independently of AWAI should have their own privacy policies and AWAI is not responsible for the privacy practices applying in respect of those websites.

Cross-border disclosure

AWAI may transfer your personal information to an entity which is in a foreign country to assist AWAI in providing its travel booking services. We primarily store information in Australia. Your personal information may also be provided to and stored on servers located overseas by our third-party cloud storage providers or other Suppliers or third parties (including third-party aggregators and insurance providers). This may include parties located in the United States of America, Singapore, countries in the European Union and the Philippines. To provide our travel booking services, your personal information may be provided to Suppliers and third parties who are located overseas where the travel products you would like to book require the transfer of the information.

Where your personal information is transferred to an entity in a foreign country, AWAI will take such steps as are reasonable in the circumstances to ensure that the information that is transferred to third parties located outside of Australia will not be held, used or disclosed by the recipient of the information in a manner that is inconsistent with the APPs.

Change of control

If AWAI sells, assigns or otherwise transfers part or the whole of its business, your personal information, which was collected by AWAI through your use of our the Bonza Holidays Platform, may be among the items transferred or sold to the extent that it is relevant to the transfer of AWAI's business.

How you may access or correct your personal information

You may contact AWAI to request access to the personal information it holds about you at any time. You may also ask AWAI to correct information about you that you may believe is inaccurate, incomplete or out of date.

Please contact AWAI using the contact details set out in clause 12. AWAI will need to verify your identity before giving you access to, or correcting, your personal information. AWAI will respond to the request within a reasonable period after the request is made. There is no charge to make a request, however AWAI may charge a reasonable fee to cover the administrative costs of retrieving your personal information.

In certain circumstances, AWAI may refuse, or be unable, to correct or provide you with access to your personal information. In these circumstances, AWAI will write to you to explain the reasons why this is the case.

You may separately contact Bonza to request access to the personal information it holds about you from your access and use of the Bonza Holidays Platform. You can do so by contacting them through the details in the Bonza privacy policy, and Bonza will assist you in accordance with its policy.

How you may complain if you have concerns about how AWAI has managed your personal information

If you have a complaint related to how AWAI has managed your personal information, please contact AWAI using the contact details set out in clause 12. AWAI may ask you to place your concerns in writing so that its compliance staff can fully understand and investigate your complaint.

AWAI will provide you with an estimated response timeframe in relation to your complaint. In any event, AWAI will endeavour to respond to your complaint within 30 days.
If a complaint remains unresolved, you may contact the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au to have the complaint heard and determined.

If you have a complaint related to how Bonza has managed your personal information provided to it through your access and use of the Bonza Holidays Platform, you may separately contact Bonza in relation to your concerns. You can do so by contacting them through the details in the Bonza privacy policy, and Bonza will assist you in accordance with its policy.

How to contact us

If you have any questions about this Privacy Policy or AWAI's management of your personal information, please contact AWAI on:

Attention: Data Protection Officer
Email: privacy@awai.com.au
Mail: L13 664 Collins St Docklands VIC 3008

Changes to AWAI's privacy policy and information handling practices

This Privacy Policy is subject to change at any time so we encourage you to review this Privacy Policy at regular intervals. If AWAI changes this Privacy Policy an updated version will be posted on AWAI's website to notify you of this change. By continuing to use the Bonza Holidays Platform after that time you will be deemed to have accepted any changes to this Privacy Policy.

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