Our privacy policy sets out how we process personal data relating to individuals who are:

• booking or enquiring about booking travel services with or through us; or
• the recipients of any travel services booked with or through us (e.g. you are the passenger for a booking or booking enquiry made by someone else for you); or
• customers or potential customers or recipients of travel services that can be booked with or through us.

We understand personal data as any information relating to an identified or identifiable individual, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, services obtained or considered, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.

We include in this privacy policy personal data we process relating to:

1. individuals who are making any enquiry or booking with us or through us, and individuals in respect of whom any enquiry or booking is made (such as friends, family members, tour group members, officers and employees of businesses and organisations booking with or through us);
2. individuals in respect of whom any enquiry or booking is made with us by an agent;
3. where our customer is a business or organisation, employees or individuals who are acting as representatives of that business or other organisation, and individuals connected to that business or other organisation, such as owners, partners, shareholders, and directors;
4. individuals whose personal data is obtained from other companies in our group (such as where you have consented to your personal data being disclosed to other group companies for marketing purposes).

Please however note that this privacy policy does not apply where we are processing personal data strictly as a sub-contractor or data processor on behalf of a third party, and not on our own account. In this case, you should look to that third party and its privacy policy, who will be answerable for how we process that personal data on their instructions.

When we refer to "you" and "your" in this privacy policy, we refer to you, and any such individual whose personal data we process from time to time.

When we refer to "processing" of your personal data, this includes obtaining, recording, storing or holding your personal data, and anything we do with it, such as organising, adapting or altering it, retrieving, consulting or using it, disclosing it or otherwise making it available to others, combining it with other data, and blocking, erasing or destroying it.

When we refer to "travel services" this covers all products and services which may be booked with or through us, such as bespoke holidays, package holidays, accommodation, tours, transport and transfers (whether by air, coach, bus, train, ferry, taxi or other means), car hire, cruises, and charters, and it includes both:

1. all such products and services which we supply or operate ourselves (including where we sub-contract); and
2. any such products and services provide by a third party which we book for you (acting as agent for you or that third party). Travel services also includes any services we or a third party provide in association with travel, such as obtaining visas, foreign exchange, and providing local representatives and support.

We may collect the following:

• name,
• age,
• gender,
• address,
• telephone,
• mobile,
• fax,
• e-mail,
• Social networking contact details, your social posts about any of our trips and travel experiences.
• photographs,
• proofs of identity and address, copies of passports, driving licences, and utility bills,
• card and other payment details, and financial information,
• health information relevant to your planned travel and travel insurances held,
• results of searches carried out against you (such as to verify your identity, address, and credit status),
• your preferences,
• Frequent flyer or travel partner programme affiliation and member number.

You will be free to withdraw your consent to this at any time, by contacting us as detailed in this privacy policy or as detailed in any direct marketing that you receive. In any e-mail you send we would ask you to insert "unsubscribe" as the subject heading.

If you are an individual associated with a business or other organisation that is our customer, then your personal data may include the following information that we link to you:

• business or organisation details (such as name, address, telephone numbers, payment arrangements, financial information, etc.),
• your relationship with that business or organisation (such as owner, partner, director, shareholder, employee, or agent), and
• your contact details within that business (such as work address, work telephone and mobile numbers, work fax number, and work e-mail address).

Information concerning enquiries and bookings made with or through us for travel services, including where you are making the enquiry or booking or are the recipient of the travel services to which the enquiry or booking relates. This information may include:

• records of enquiries and searches for holiday and travel products made by or on your behalf,
• details of your personal interests,
• needs and other data relevant to your enquiry;
• details of results, quotes, proposals, estimates and other information given in response to enquiries;
• details of the holiday, accommodation, travel, car hire, and other travel services booked or enquired about;
• details of the passengers / holidaymakers travelling;
• details of the provider of the travel services (e.g. tour operator);
• dates and times of travel;
• price;
• payment details (including card details);
• passport information and visa information;
• foreign exchange requirements and arrangements; and
• Sensitive information such as health, medical, dietary, mobility, disability, or other requirements relevant to the service you are enquiring about or your contract with us.

Information collected or generated out of any surveys we conduct.

Information collected or generated out of any competitions or promotions we run.

Information concerning any accounts, registrations, or memberships with us, or participation in any loyalty program.

Correspondence, communications and messages, including between you and us, and between us and third parties, relating to any booking or booking enquiry, or performance of any contract.

We may collect information about your visits to, browsing of, and use of our website, unless your web browser blocks this. The range of data we collect will depend on how you interact with our website.

This information may include:

• your IP address (a unique identifier allocated to your computer for your connection to the internet);
• your computer device details (PC, tablet, smartphone, watch etc.);
• the make and version of web browser (e.g. Internet Explorer, Firefox, Safari, Opera, Chrome) you are using;
• your operating system (e.g. Windows, Windows Phone, OSX, iOS, Android, Linux etc);
• your time-zone;
• your browser plug-ins;
• any web-page you came from, identified as the referrer web page address by your web browser;
• cookies (as per our cookie policy https://www.aatkings.com/do-not-sell-my-personal-information);
• identifiers assigned to you by third-party advertising providers and web beacons you interact with;
• page response times;
• download error;
• pages and parts of pages you visit;
• usage you make of our website, including enquiries and searches undertaken, and registrations for accounts, forums etc.;
• services and products you viewed;
• length of visit to website and pages;
• page interaction information (such as scrolling, keys pressed, mouse clicks, touches, and mouse-overs).

This will normally be collected and used anonymously, and aggregated for analysis, with your name and any characteristics identifying you remaining anonymous, but our privacy policy will apply, and it will be treated as your personal data, if this information is in any way linked to you personally.

This information may also include:

• data inputted into forms and fields;
• registrations for any accounts,
• forum,
• feedback mechanism,
• social functionality,
• newsletters or other features of our site;
• usernames and passwords,
• log-in / out history, and settings;
• actions taken within any account or other registration, including view and update and changes to settings; and posts to any forum, feedback, review, or other social functionality on our website.

Such information will be treated as personal data and processed according to this privacy policy.

By visiting and using our website you or your computer may provide personal data. This includes: information which is automatically provided by your browser to our servers; information recorded on our web servers about your interaction with our website and pages viewed; information we capture or place on your computer or generate using cookies or other technologies on our website; and information you input into forms and fields on our website. This is more detailed in our cookie policy: https://www.aatkings.com/do-not-sell-my-personal-information

Your personal data will include data you provide (or later amend), whether:

• from correspondence with you;
• verbally to us over the phone or in person;
• by filing in any field or form on a website;
• by filling in any printed form we provide you with;
• by e-mail;
• from documents you provide us with; and
• from updates to any information you provide to us from time to time.

This includes when you:

• register or subscribe for any service, account, members, or loyalty program,
• make an enquiry or booking for a holiday or other travel services whether in person, by phone, through our website or otherwise;
• send us your comments or suggestions;
• subscribe to any newsletter or other publication;
• and request sales and advertising information, including brochures.

We may process, Information or content provided by you in relation to your feedback or experience on a past, current or future trip with us. We will only use such content and images you have submitted to our social media channels or websites, if you have given consent to let AAT Kings and TTC subsidiary companies to process this information in various initiatives. These could include any marketing activities such as:

• Print materials
• on our website
• email activities
• social posts
• images on our trips
• provide images to our trade partners to use on their websites, email marketing and other marketing initiatives
• make available in our content feeds
• We would share imagery in our content feeds, image repositories, via email and share with our trade partners via these methods
• Any other information provided to us by or in relation to you which concerns you as an individual.

We may obtain personal data concerning you from third parties, including from:

• providers of any holidays, accommodation, other travel services which are enquired about or booked, and their intermediaries;
• credit, fraud, identity and other searches we may undertake, including searches with public records and regulatory and private organisations;
• Any business or organisation you are associated with; from telephone numbers identified by the telephone system when you telephone us.

We and any suppliers or sub-contractors working for us may generate personal data relating to you, including:

• in connection with responding to and dealing with any enquiry, booking or complaint; or
• in performing any booking or other contract with you; or
• through the analysis of your personal data; or
• data gained from your use of our website according to our cookie policy.

We may record telephone calls with you for training and quality purposes.

To operate and provide the search, booking, accounts, review, forums and other services, facilities, and functions of our websites. This includes managing any accounts or registrations you have with our websites and making changes to your settings and profile at your request.

To provide information to you about our website, systems, and services, including to respond to booking enquiries and searches for holidays and travel, and to keep you updated generally. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

To enable you to make bookings, and to fulfil, provide, perform, administer, manage, and enforce all bookings, orders, and other contracts which relate to you (including if you are a passenger in a booking made by someone else), and to process any transactions authorised or made with us which relate to you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

To collect and make payments due and administer our accounts. This is necessary for the preparation of any contract between us.

To communicate with you concerning any enquiries, bookings, travel services provided, problems and complaints, and to respond to any submissions, enquiries or requests from you. We process your data because you ask us to take the relevant steps in order to enter into a contract, or because we perform a service that you asked us to provide.

To keep internal records and maintain reasonable archives, including concerning as to enquiries, bookings, contracts, travel services, and complaints. This is done on the basis of our legitimate interests in ensuring our business is protected or run efficiently, or because we have the legal obligation to do so.

To analyse, audit, provide, operate, administer, maintain and improve our business, website, systems, and services;

• to carry out surveys and analyse the results;
• to run promotions and competitions;
• undertake product or customer research/development;
• to assist us in and help us to improve our sales;
• to carry out other business development and improvement activities;
• to provide training to our staff, sub-contractors and suppliers;
• editorial, advertising, and marketing processes, including sharing of photographs which you have voluntarily participated in during our Trips. Such photos may be shared across our social media channels such as Facebook, Instagram, Twitter or LinkedIn. These images will not be shared for any use other than to promote our Travel experiences. Please remove yourself from group photos organized by Trip Directors if you do not wish to be photographed;

For example, we may use your personal data to help us profile how our customers generally are using our websites and booking travel services with (or through) us. We may also use this information to ascertain interests so that we can better tailor our business offerings. This is done on the basis of our legitimate interests in ensuring our business runs efficiently.

To carry out direct marketing to you, in particular to identify you as a customer and to identify your product and service preferences and to provide personalized content and ads informing you of new or additional products, services, and/or promotions that may be of interest to you. We may engage in direct marketing via the following means depending on the details you have provided to us: text messages, phone calls, targeting you on social media platforms on your personal computer and mobile device, direct mail, post, web advertising, in third-party apps, in our apps. See section 10.1 for the types of products we may market to you this way.

To report aggregate information concerning usage of our websites to our advertisers. We normally create anonymous statistical data about browsing actions and patterns, and do not identify any individual.

For any purpose which we have obtained your consent to. We will do this only where you have a choice whether to consent or not, you have control over that data and you have had to take an affirmative step to give consent on an informed basis. We will ensure that you can withdraw your consent at any time by providing simple mechanisms if you would like to do so.

You are not obligated to provide your personal information, however, where the information is required for us to provide you with our services/deliver your products, we may not be able to offer some/all our services without it. Sometimes, providing your data to authorities when you travel is a legal obligation for us.

We will use your personal data to send you marketing information (including adverts and details of promotions) about travel services:

1. offered by us;
2. which can be booked with third parties through us;
3. which can be booked with other companies within our group (i.e. the Travel Corporation Group); and
4. offered by third parties selected by us. However, we will not pass any of your details to third parties without your prior and specific consent.

Where applicable we will only send you marketing information about the categories of travel services you have selected. Also, we will only contact you in the manner you agreed to (e.g. by email or SMS).

From time to time, we may disclose your contact details (i.e. your name, email address, postal address, telephone number, mobile number, fax number and preferences) to:

1. other companies within our The Travel Corporation, which are bound by the same requirements set in this privacy policy; and
2. other companies which offer services that may enhance your travel experience or be able to help you to finalise your travel arrangements (“third parties”). Such third parties may then contact you directly with marketing information about services and products offered by them. Such third parties are not part of The Travel Corporation and are not bound by this privacy policy. However, we ensure that our partners will only contact you in the manner you agreed to (e.g. email, text) when providing your consent.

You are free to stop receiving marketing information from us at any time by contacting us as detailed in this privacy notice or by following the instructions set out in our marketing communications. If you email us to withdraw your consent, it would be helpful if you could insert the word “Unsubscribe” as the subject heading.”

When you elect to stop receiving marketing information we will, from that point onwards, not share your information further with any other third parties.

You are also free, at any time, to notify any third party to whom we have previously passed your contact details to, that you no longer wish to receive marketing communications from them.

We may disclose your personal data to third parties (including intermediaries) as necessary to carry out any checks regarding your financial standing. The identities of these parties may change from time to time. They may include credit reference agencies and other companies for use in credit decisions, for fraud prevention and to pursue debtors.

We disclose your personal data to third parties (including intermediaries) as necessary to deal with any booking enquiry being made by or for you, to make any booking requested by or for you, to perform and administer any booking for you or other contract with or in respect of you. This may include;

• to apply for visas on your behalf,
• to collect payments to be made by you,
• to investigate and respond to complaints, and
• to enforce any booking or other contract with you.

Such third parties may include any suppliers or sub-contractors and their agents (e.g. airlines, coach, ferry or train companies, hoteliers, hire companies, cruise companies, tour operators etc.). The identities of these parties may change from time to time and are engaged so we can provide our services to you. We ensure that these third parties carry their tasks with the same level of protection on your personal data that you will expect from us.

We may disclose your personal data to any third party (e.g. supplier, contractor sub-contractor) we make any enquiries with concerning or engage or sub-contract to perform any booking or other contract, including to provide any travel, tour or other products or services we have agreed to provide to you in order to perform our contract with you.

We may disclose your personal data to any supplier with whom we make any enquiry concerning or book any travel or other products and services for you as agent (whether as agent for you, someone representing you, or the supplier), such as a tour operator. Details of any third party tour operators or other third parties who will be responsible for or supply you with the travel services booked or enquired about, may be obtained from us on request, and may be stated in any tour or other brochure provided by us.

If any application is made through us for any travel or other insurance to cover you, we will pass your personal data on to the insurer. Information provided by you may be put on to a register of claims and shared with other insurers to prevent fraudulent claims.

Where we use third parties to host, provide, operate or supply any part of our websites, databases, systems, business, or services, or carry out on our behalf any of our business functions or actions (including sending mail, processing payments, providing marketing assistance, providing customer and advertising analysis through third-party ad-tech vendors, and providing customer services), then we may provide your personal data to them as required for use for or processing as part of those purposes. We ensure that these third parties treat your personal data with the same level of care and duty as us.

Where any facility on our website is clearly designed to make certain of your personal data public (e.g. posts you make to any public forum or reviews facility), then any personal data you provide in relation to that forum or other facility, which is provided in circumstance where it is clear that it is intended to be published, will be disclosed to the public accordingly, subject to moderation by us and to the terms of this privacy policy.

We may supply personal data to a government authority or regulator where required to:

• comply with a legal requirement,
• for the administration of justice or when required by a public enforcement body, or
• for the purposes of customs, visas and immigration.

We may disclose your personal data where otherwise required by or permitted by law.

We may disclose your personal data to third parties to carry out direct marketing to you, where you have given your prior consent. Please refer to the direct marketing section above for more information.

If you are a business or organisation (“Business Customer”), and we are holding personal data of any authorised representative (such as an employee agent, employee, officer, owner, partner, or director), then we may disclose to them that personal data.

If a Business Customer is making a booking or booking enquiry on behalf of an individual, with that person’s authority, then we may disclose to our Business Customer that individual’s personal data as reasonably required in connection with such booking or enquiry, or the subsequent performance of or payment for any booking made.

If our business is ever transferred to a third party, then your personal data will be transferred to the acquirer to enable them to continue our business. We will ensure that the acquirer is bound by terms similar to this privacy policy to protect your personal data.

In some cases, your personal data may be held and otherwise processed by others on our behalf. We have not included the names of our service partners as these will change over time. We will remain responsible for what they do with your personal data, and your personal data will only be held and processed by them in accordance with our instructions and this privacy policy. The sharing of your data is necessary for the performance of any contract with you and for the efficient provision of our services.

In other cases, your personal data may need to be provided to them to be held and processed by them in their own right and on their own account. In such case, they will have their own responsibility for your personal data, subject to their own privacy policy, and we will not be responsible for what they do with it following disclosure. This will only be done to perform the contract. When this happens, you will be informed by the third party and they will provide their privacy policy to you.

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

• only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
• using secured servers to store your information;
• verifying the identity of any individual who requests access to information prior to granting them access to the information
• using Secure Sockets Layer (SSL) and Transport Layer Security (TLS) software or other similar encryption technologies to encrypt your personal and payment transactions.

Unfortunately transmission of information over email is not secure, and if you submit any information to us over the internet by email we will do our best to protect your personal data and have contractual processes in place with our service providers to do this. Once we have received your information, we will use relevant procedures and adequate security measures to prevent unauthorised access.

You have the right to have your personal data amended if it is inaccurate or incomplete.

You have the right to object to the use of your personal information for direct marketing or where we use it on the basis that we say we have a legitimate interest in using it.

You have the right to have your personal information deleted or removed in the following circumstances:

• The data is no longer necessary for the purpose for which it was originally collected or otherwise processed;
• Where you withdraw your consent, where consent was used as the legal basis for processing;
• Personal data has been unlawfully processed;
• When you object to the processing and we have no overriding legitimate interest for continuing the processing;
• Erasure is required for compliance with a legal requirement; or
• Data has been collected in relation to the offering of online services to a child.

When a request for erasure is valid, we will take reasonable steps to inform third parties which are processing the personal data that you have requested us to delete.

We have the right to refuse to act on a request of erasure if the data is necessary for:

• Exercising the right of freedom of expression and information;
• Compliance with a legal obligation;
• The establishment, exercise or defence of legal claims;

You have the right to receive your personal data which you have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller, when:

• the processing is based on consent or on a contract; and
• the processing is carried out by automated means.

You have the right to obtain from us the restriction of processing of your personal data where one of the following applies:

• You contest the accuracy of the personal data, for a period enabling us to verify the accuracy of the personal data;
• The processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
• We no longer need the personal data for the purposes of the processing, but the data is necessary for you for the establishment, exercise or defence of legal claims;
• You have objected to processing pending the verification whether our legitimate grounds override yours.

Where the processing of your personal data is restricted, at the exception of storage, we will only process your personal data with your consent, for the establishment, exercise or defence of legal claims, for the protection of the rights of another individual or organisation, or because we are legally required to do so.

We will inform you before the restriction of processing is lifted.

You are free to withdraw your consent at any time, where we rely on your consent as a legal basis for processing. Please contact us using the details outlined in Section 16 of this policy. See also section 10.3 for details as to how to object to our direct marketing communications.

The laws we comply with are regulated by the Australian Information Commissioner GPO Box 5218 Sydney NSW 2001 or call 1300 363 992 and online at https://www.oaic.gov.au/privacy/privacy-complaints/ and for other member states, the independent supervisory authority responsible for monitoring the application of the regulation. In addition to your rights above, it is open to you, if you have a complaint or a concern, to seek assistance from this supervisory authority who has powers to compel us to comply with applicable laws and fine us for non-compliance. However, before you do so, we would hope that you will contact us first to discuss any complaint or concerns you have. You can contact us using the details provided in Section 16 of this our privacy notice.

We keep our privacy notice under regular review to make sure it is up to date and accurate. When we make any change, we will notify you by email of such change. You can check the top of the document to see the latest version in force.

Our privacy policy is subject to the law of Australia and disputes can be determined by the courts of Australia.