By providing personal information to us (or allowing another person to do so on your behalf), you agree that this Policy 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 Policy. If you do not agree with any part of this Policy, you must not provide your personal information to us and this may affect the services we can provide to you.
In this Policy, where we say “disclose”, this includes to transfer, share, send, or otherwise make available or accessible your personal information to another person or entity.
What is personal information?
Personal information is 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.
How do we collect personal information?
Where practical, we will collect personal information directly from you. Generally, this collection will occur when you deal with us either in person, by telephone, letter, facsimile, email or when you visit our website. We may collect personal information about you when you purchase or make enquiries about travel arrangements or other products and services, when you create a profile and enter information about yourself, when you enter competitions, when you register for promotions, when you subscribe to receive marketing from us (e.g. e-newsletters) or when you request brochures or other information from us. We may also collect your personal 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. Where this occurs, we will assume you have consented to your personal information being collected by us and to us handling it in accordance with this Policy. 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.
Without limiting the above, we may also require information about you to distribute prepaid payment cards to you through our distributor network and, in connection with these services, we may obtain personal information about you from financial institutions (including Heritage Bank Limited (ABN 32 087 652 024 AFSL 240 984), the issuer of the Key to the World prepaid currency card), distributors, credit reporting agencies, our business partners that sell you related products or services and other service providers.
What personal information do we collect?
Generally, the type of personal information we collect about you is the information that is needed to respond to your queries about our products and services and/or provide requested products or services to you. For example, we may collect details such as your name, residential address, mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), passport details and other details relevant to your order, receipt, or use of a product or service from us. 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 form you have sent to us. We also collect information that is required for use in the business activities of Flight Centre and our related entities, including for example, financial details necessary in order to process various transactions, and any other relevant personal information you may elect to provide to us.
In some circumstances, we may collect personal information from you which is regarded as sensitive information. Sensitive information includes types of personal information such as your racial or ethnic origin, religious beliefs or affiliations, criminal record and health information. We will only collect sensitive information about you with your consent and where reasonably necessary for, or directly related to, one or more of our functions or activities. Where you provide sensitive information to us, you consent to us using that sensitive information for the purpose for which it was collected.
When we act as agent
When we book and otherwise arrange products and services for you, we usually do so as agent. This means that we usually collect personal information about you both for our internal purposes (e.g. to process the transaction requested by you), and on behalf of the parties for whom we act as agent, for their internal purposes (e.g. to provide the services you requested). Accordingly, the consent you provide under this Policy to the collection and use of personal information by us, applies equally to the parties whose products and services we sell. For example, if you purchase a Key to the World prepaid currency card (“Card”) from us, then under this Policy you will have consented to your personal information being provided to MasterCard Prepaid Management Services Australia Pty Ltd to enable your Card to be activated.
Our company group acts as agent for or on behalf of many thousands of service providers, so it is not possible for us to set out in this Policy all of the service providers for whom we act nor exactly how each of these service providers will use your personal information. If you wish to contact us for further information, please refer to the “Feedback / Complaints / Contact” section below.
How do we use personal information?
Where you contact us in relation to products or services, the primary purpose for which we collect your personal information is generally to provide you with the products and services or information about such products and services. However, the purpose for collection may differ depending on the particular circumstances as disclosed in this Policy.
By providing us, or otherwise allowing us to collect, your personal information, you consent to us using and disclosing your personal information for the purposes for which it was collected, and for related or ancillary purposes, such as any one or more of the following purposes:
- identification of fraud or error;
- regulatory reporting and compliance;
- developing, improving and marketing our products and services and those of our related entities;
- servicing our relationship with you by, among other things, providing updates on promotions and services we think may interest you;
- involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you;
- to facilitate your participation in loyalty programs;
- to analyse trends in sales and travel destinations;
- for marketing activities including but not limited to mail-outs, emails, e-newsletters, SMS notifications, alerts and telephone calls;
- internal accounting and administration; and
- other purposes as permitted or required by law (e.g. to prevent a threat to life, health or safety).
We are only allowed to store your personal information for as long as necessary having regard to the purpose for which it was collected or a related or ancillary purpose. We may therefore delete your personal information after a reasonable period of time and, if you have not used our services for some time, you may have to re-enter or re-supply your personal information to us.
Is personal information disclosed to third parties?
1. You also consent to the personal information about you which we collect or receive being processed, transferred and/or disclosed by us in the following circumstances:
- in each of the circumstances set out in the previous section “How do we use personal information?”;
- as permitted or required by law;
- to various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes;
- to third party suppliers of IT based solutions that assist us in providing products and services to you;
- to our related entities and brands (including companies based overseas);
- to our affiliates, financial institutions that issue payment cards or process payment card transactions, entities that assist with payment card fraud prevention and distributors;
- to comply with our legal obligations and any applicable customs/immigration requirements relating to the products and services provided to you;
- to comply with a request from a qualified government department if we are satisfied that they have the authority to make such request;
- 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;
- to third parties who may involve you in market research for the purpose of servicing our relationship with you and improving the services we provide; and
- to third parties for the purpose of analysing trends in sales and travel destinations.
The third parties to whom we disclose your personal information may also be taken to have collected your personal information in their own right, for their internal use. For more information in relation to collection by service providers, see the heading above titled "When we act as agent".
Where we engage service providers to perform services for us, those service providers may be required to handle your personal information. Where we disclose your personal information to such service providers, your personal information will be governed by their privacy policies. We encourage you to review the privacy policies of any travel service provider whose services we arrange on your behalf.
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 or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), disclosure is authorised or required by law or disclosure is otherwise permitted by applicable privacy laws.
We may also share your personal information with credit reference agencies and fraud prevention agencies (i) to make enquiries when you ask for a currency card or any of our services or to assist us in managing the card; (ii) to share information about you and how you manage the card; and (iii) if you give us false or inaccurate information or we suspect fraud. These agencies keep a record of our enquiries (whether or not you proceed with your application, and whether or not your application is successful) and may record, use and give out information we give them to lenders, insurers and other organisations to make assessments on you and members of your household, and to assist with identity verification, for debt tracing and to prevent fraud and money laundering.
Companies to whom personal information is disclosed which are registered in the United States may be required to provide information under the USA PATRIOT Act H.R. 3162.
Trans-Border data flows
When you provide, or otherwise allow us to collect, your personal information, you consent to your personal information being disclosed to certain overseas recipients, as set out below. Where we disclose your personal information to an overseas recipient, you acknowledge that the recipient may be located in a country with laws that do not protect personal information as well as Australian privacy laws do. We will use reasonable efforts to ensure the recipient’s compliance with Australian privacy laws; however, you acknowledge that we cannot control the privacy practices of the recipient and therefore will not be liable or accountable for how the recipient handles your personal information. We encourage you to review the privacy policies of any third party service provider whose services we arrange on your behalf. If you have any objections to your personal information being disclosed to an overseas recipient, please let us know.
In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas service providers (e.g. where you request a money transfer to a recipient in another country). These service providers will in most cases receive your personal information in the country in which they will provide the services or in which their business is based.
We may also disclose your personal information to our overseas related entities and other third parties who perform services for us overseas. Generally, we will only disclose your personal information to these overseas recipients in connection with facilitation of the products and services provided to you and/or to enable the performance of administrative and technical services by them on our behalf.
We deal with many different service providers all over the world, so it is not possible for us to set out in this Policy all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please refer to the “Feedback / Complaints / Contact” section below.
Security of information
Flight Centre has implemented various physical, electronic and managerial security procedures in order to protect personal information from loss and misuse, and from unauthorized access, modification, disclosure and interference.
Flight Centre regularly reviews security and encryption technologies and will strive to protect your personal information as fully as we protect our own confidential information.
If you have a log-in account for this website, you are responsible for maintaining the confidentiality of your log-in details (including your password) and for all activities that occur using your log-in account. In order to ensure the security of your personal information, it is essential that you keep these log-in details confidential and comply with the requirements set out in the website terms and conditions with respect to the confidentiality and security of your log-in details.
Access to and correction of personal information
Subject to any exceptions set out in applicable privacy laws, we invite you to access any personal information we may hold about you. Where personal information we hold about you is not accurate, complete, up-to-date or relevant, you may ask us to correct that personal information, and we will respond to your request within a reasonable time. We reserve the right to confirm the identity of the person seeking access or correction to personal information before complying with such a request. If we deny access or correction, we will provide you with the reason for such denial. If you wish to access or seek correction of any personal information we hold about you, please refer to the “Feedback / Complaints / Contact” section below.
You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct.
You consent to receiving any information required to be given to you by law or any code, as well as non-marketing communications, by electronic communication, unless any law or code requires otherwise.
In the course of your use of Key to the World, We may need to communicate with you via email, SMS, mobile push notifications or other electronic means. You agree to receive these electronic messages and other notifications which are specific to you and required for the normal use of Key to the World, including welcome emails which help inform new users about various features of Key to the World and the products and services purchased.
We will only send e-newsletters or other promotional materials to you if you have opted in to receive them. You can subscribe to receive e-newsletters and other promotional materials by following the relevant links on our website. You can change your marketing preferences at any time.
If you have requested alerts via the website in connection with our services (e.g. exchange rate alerts, top-up alerts), you will continue to receive these alerts, as well as any service messages and other non-marketing communications, even if you unsubscribe/opt-out from receiving marketing materials from us. You can manage your alerts via the website, by logging on.
You understand and agree that any alerts provided to you through Key to the world may be delayed or prevented by a variety of factors. We cannot guarantee the accuracy or timely delivery of any alert or service message. You agree that we are not liable for any delays, failure to deliver, or misdirected delivery of any alert; for any errors in an alert; or for any actions taken or not taken by you or any third party in reliance on an alert.
Should you no longer wish to receive e-newsletters or other promotional material, participate in market research or receive other types of communication from us, please refer to the “Feedback / Complaints / Contact” section below.
Tracking Technologies / Cookies
We use both session ID cookies and persistent cookies. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. When the visitor revisits the website, we may recognize the visitor by the cookie and customise the visitor's experience accordingly. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file.
If you reject cookies, you may still have access to our website, but your experience will be less tailored and your ability to use some areas of our website, such as contests or surveys, will be limited.
You may choose to opt-out of Google Analytics using the Google Analytics Opt-out Browser Add-on which you may access at https://tools.google.com/dlpage/gaoptout/.
Web Beacons / Gifs
We employ a software technology called clear gifs (a.k.a. Web Beacons), that help us better manage content on our website by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We do not tie the information gathered by clear gifs to our customers’ personal identifiable information.
3rd Party Tracking
Behavioural Targeting / Re-Targeting
Feedback / Complaints / Contact
If you have any enquiries, comments or complaints about this Policy or our handling of your personal information, please contact your consultant or email us at firstname.lastname@example.org. We will respond to any complaints received as soon as practicable.
Changes to our Policy
From time to time it may be necessary for us to review and revise this Policy. We reserve the right to change our Policy at any time and for any reason. If we make a change to the Policy, the revised version will be posted on our website.
Last updated 15 April 2016.