PGL ADVENTURE CAMPS PTY LTD is committed to complying with the Australian Privacy Principles and we want you to feel confident in the measures we are taking to uphold your data privacy rights.
Who are PGL ADVENTURE CAMPS PTY LTD?
PGL ADVENTURE CAMPS PTY LTD is owned by PGL Travel – part of HB Education Limited which also operates NST, European Study Tours and StudyLink.
For simplicity throughout this notice, ‘we’ and ‘us’ means HB Education and its brands.
‘You’ and ‘your group’ means you and your party members or anyone for whom you are making a booking.
What personal information does PGL ADVENTURE CAMPS PTY LTD collect and hold?
Your personal data may include for example your name, your contact details, information relating to your itinerary (such as your booking reference number) or information on how you use our website or how you interact with us. It should be noted that where information is given by a guardian on behalf of a child that this information is treated as if it had been received from that child and the privacy of the information provided is therefore protected in the same way as for an individual.
Generally, the kinds of personal information we collect are:
contact and identification information such as name, address, telephone number, email address and date of birth;
- emergency contact details and next of kin;
- banking and credit card details;
- sensitive information (e.g. information about health, dietary requirements, injuries, medical history, specific conditions, criminal record) which will only be collected with the consent of the individual;
- where it concerns an application for a position with us, information about an individual’s education and work history, qualifications and skills, and the opinions of others about work performance; and
- other information required for our functions and activities.
In some circumstances we may also hold other personal information provided by an individual.
How does PGL ADVENTURE CAMPS PTY LTD collect personal information?
Personal information will be collected directly when an individual:
- completes an online or hard copy form in relation to our services;
- fills an application for a position with us, or submits a resume, either online or in hard copy, and/or attends an interview; and
- otherwise provide us with personal information in person or via telephone, email, sms, fax, post or other means, whether at our request or through an individual’s own initiative.
Personal information may also be collected from a source other than directly from an individual, such as from:
- educational organisations, e.g. a school or from a child’s school;
- family members and relatives (e.g. parents);
- community groups, sporting groups and religious organisations;
- an individual’s employer or the organisation that an individual works with;
- via online services which tell us technical information about your internet connection, browser, location, the web pages viewed during your visit, the advertisements you clicked on, the site referring you and any search terms you entered.
- external recruitment agencies and background screening providers;
- for recruitment purposes, from any of former or current employers and work colleagues, professional associations, registration bodies and educational institutions; and
- agencies that undertake criminal history checks and working with children checks.
Generally, we will only collect personal information from sources other than an individual if it is unreasonable or impracticable to collect the personal information from that individual.
Why does PGL ADVENTURE CAMPS PTY LTD need personal information?
We want to give you a great customer experience.
One way to achieve that is to get a picture of who you are by combining the data we have about you. We then use this to offer you promotions, products and services that are most likely to interest you.
We collect, hold use and disclose personal information where it is reasonably necessary for the purposes of carrying out its functions and activities, including:
To manage your booking and make arrangements for you
When you book a trip with us, we use your information to provide services to you and fulfil our contractual obligations, for example to confirm accommodation, and itinerary arrangements.
To communicate with you & manage our relationship
We will need to contact you by email for administrative or operational reasons, for example to send you confirmation of your booking and payments, to inform you about a specific aspect of the product you have enquired about or booked.
To improve our services, fulfil our administrative purposes and protect our business interests
We will use your information for the following business purposes which include accounting, billing and audit, credit or other payment card verification, safety, security and legal purposes, statistical and marketing analysis, customer feedback requests, systems testing, maintenance and development.
To comply with our legal obligations
To respond to your queries, refund requests and complaints
Handling the information you have sent to us enables us to respond. We may also keep a record of these communications to inform any other contact we have with you/your group and to demonstrate how we communicated throughout.
To develop, test and improve our systems
For example, we may record your browser’s Session ID to help us understand more when you leave us online feedback about any problems you’re having.
To send you survey and feedback requests to help improve our services
These messages will not include any promotional content and do not require prior consent when sent by email or text message. We have a legitimate interest to do so as this helps make our products or services more relevant to you.
An individual is under no obligation to provide personal information to us. However, without certain information from that individual, we may not be able to provide our services. (For example, failing to provide certain information may preclude participation in camps or activities organised and administered by us, or in a recruitment context, may limit our ability to consider that individual for employment.)
Disclosure of personal information
PGL ADVENTURE CAMPS PTY LTD discloses personal information for the purpose for which we collect it. Generally, we will only disclose personal information for a purpose set out above. This may include disclosing personal information to:
- third parties engaged to perform administrative or other business management functions;
- our subcontractors, including activity specialists, venue owners, catering contractors, IT contractors and database designers;
- doctors, hospital and/or police in the event of an emergency incident involving an individual;
- our professional advisors and consultants;
- insurance providers;
- where an individual is applying for a position with us, referees, former employers and colleagues, and relevant bodies that conduct background checks;
- any other entity with the individuals consent, or to whom disclosure is required or authorised by law.
PGL ADVENTURE CAMPS PTY LTD’s disclosures of personal information to third parties are made on a confidential basis or otherwise in accordance with law. PGL ADVENTURE CAMPS PTY LTD may also disclose personal information with an individual’s consent or if disclosure is required or authorised by law. As PGL ADVENTURE CAMPS PTY LTD is committed to protecting the privacy of individuals, we will view unauthorised disclosure or access to personal information by our employees, contractors or agents as a serious breach of this policy. Appropriate action (which may include disciplinary or legal action) will be taken in such cases.
PGL ADVENTURE CAMPS PTY LTD may disclose personal information to overseas recipients in order to provide its services and for administrative, data storage (e.g. cloud service providers), recruitment activities or other business management purposes. Recipients of such disclosures may be located in the United Kingdom or the United States, but may also be located in other countries. Overseas recipients may have different privacy and data protection standards. However, before disclosing any personal information to an overseas recipient, PGL ADVENTURE CAMPS PTY LTD will take reasonable steps to ensure the overseas recipient complies with the Australian Privacy Principles or is bound by a substantially similar privacy scheme, unless an individual consents to the overseas disclosure or it is otherwise required or permitted by law.
We may use and disclose personal information in order to inform an individual of services that may be of interest. In the event an individual does not wish to receive such communications, that individual can opt-out by contacting PGL ADVENTURE CAMPS PTY LTD via the contact details set out below or through any opt-out mechanism contained in a marketing communication.
Security of personal information
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How to access and correct an individual’s personal information
We take reasonable steps to ensure personal information we hold is accurate, up-to-date, complete, relevant and not misleading. An individual has a right to access and seek correction of that individual’s personal information that is collected and held by us. If at any time an individual would like to access or correct the personal information that PGL ADVENTURE CAMPS PTY LTD holds about that individual or more information on our approach to privacy is sought, please contact PGL ADVENTURE CAMPS PTY LTD’s Privacy Compliance Officer on the details set out below.
We will grant access to the extent required or authorised by the Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access to an individual’s personal information:
- That individual will need to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected; and
- We request that the individual is reasonably specific about the information required.
If we refuse a request to access or correct personal information, we will provide written reasons for the refusal and details of complaint mechanisms. We will also take steps reasonable in the circumstance to provide access in a manner that meets the individual’s needs and the needs of PGL ADVENTURE CAMPS PTY LTD. We will endeavor to respond to requests to access or correct personal information within 30 days from the date of the request.
How to contact us
For further information or enquiries regarding personal information, or if an individual would like to opt-out of receiving any promotional or marketing communications, please contact:
Privacy Compliance Officer
Name: Carl Stanforth
Address: PGL Campaspe Downs, 1302 Kyneton -Trentham Road, Tylden, VIC 3444
Telephone: 1300 859 895
Please direct all privacy complaints to our Privacy Compliance Officer. At all times, privacy complaints:
- will be treated seriously;
- will be dealt with promptly;
- will be dealt with in a confidential manner; and
- will not affect existing obligations or affect the commercial arrangements between an individual and PGL ADVENTURE CAMPS PTY LTD.
Our Privacy Compliance Officer will commence an investigation into each complaint. The individual concerned will be informed of the outcome of the complaint following completion of the investigation. In the event that an individual is dissatisfied with the outcome of the complaint, it can be referred to the Office of the Australian Information Commissioner.
Review of Policy
This policy may be amended from time to time at the discretion of PGL ADVENTURE CAMPS PTY LTD.
Last amended: 19 Sept 2018