Introduction

The schoolholidayprograms.com.au website (SHP) and incursionprograms.com.au (IP) website, and any mobile application of the website (the “Site”) is owned and operated by School Holiday Programs Australia and Incursion Programs Australia (“SHP”, “IP”, “we”, “us” or “our”).  SHP / IP is a subsidiary of Mason & Kelly Pty Ltd.

This Privacy Policy applies to the collection, use, disclosure and handling of personal information by SHP /IP and its associated entities. SHP /IP is committed to protecting the privacy of individuals and is bound by the Australian Privacy Principles set out in the Privacy Act 1988 (Commonwealth) (the “Act”). We will only collect, use or disclose personal information in accordance with the Act and this Privacy Policy.

By providing information to us when subscribing, sending enquiries or otherwise using the Site, you expressly agree to this Privacy Policy.

What types of information do we collect?

Personal Information

The type of personal information that we collect and hold about you depends on the type of dealings that you have with us.

For example, in order to process a request or enquiry from you, we may need to know all or some of the following: your full name, address, telephone number, e-mail address, your current location, and, in the case of a Program Provider (PP) listing, a method of payment.

We may also gather information from cookies or web beacons. You can find out more about how they operate in the relevant section of this policy below.

We also collect IP addresses, mobile device identifier details, your location, navigation and click-stream data, the time of accessing the Site, Programs you viewed, what you searched for, the duration of your visit, and other details of your activity on the Site.

If you ask us to connect with other sites (for example if you ask us to connect with your Facebook account) we may get information that way too.

Information that we collect from third parties, such as credit information which we use to prevent and detect fraud, information from your mobile provider if you are accessing the Site over a mobile device or information from a third party such as a social media or travel opinions site where you have asked us to share your data with them.

Information other than personal information (“non-personal information”)

When you visit the Site, some of the information that is collected about your visit is not personal information, because it does not reveal your identity. We use this information to help us improve our services. We may aggregate this information for our own statistical purposes. Provided that it remains anonymous, we may disclose that aggregated information to third parties for marketing or other business related purposes.

Cookies

A “cookie” is a small file placed on your hard drive by certain of our web pages. We or third parties under contract with us may use cookies to help us analyze our web page flow, customize our services, content and advertising, measure promotional effectiveness and promote trust and safety. Cookies are commonly used at most major transactional websites in much the same way we use them here at our Site.

You may delete and block all cookies from this site, but parts of the site will not work. We want to be open about our cookie use. Even if you are only browsing the Site certain information (including computer and connection information, browser type and version, operating system and platform details and the time of accessing the Site) is automatically collected about you. This information will be collected every time you access the Site and it will be used for the purposes outlined in this Privacy Policy.

Methods of collection

We will collect personal information by lawful and fair means as required by the Privacy Act. We will also collect personal information directly from you where this is reasonable and practicable.

We collect personal information in a number of ways, including:

• Directly from you in person, by email, over the telephone, through written communications (such as letters and faxes) or by you completing forms or submitting information on the Site;
• From third parties,
  • including: direct marketing database providers,our related companies,
  • public sources, such as telephone directories,
  • membership lists of business, professional and trade associations,
  • ASIC searches;
• From our own records of your use of our services.

Why do we collect, hold, use and disclose your personal information?

General

The main purposes for which we collect, hold, use and disclose personal information are:

• To identify you and verify your identity;
• To communicate with you about our services;
• To contact you from time to time with critical user or service updates;
• To customize, measure and improve our services, content and advertising;
• To compare information for accuracy, and verify it with third parties;
• To prevent activity we determine to be potentially illegal, unlawful or harmful and to enforce our Privacy Policy and/or our Terms or any other purpose referenced herein or therein. We collate statistics about site traffic, sales and other commercial information which we pass onto third parties to assist us in improving the services we provide to you. We also use demographic information to tailor the Site and we share that information with third parties so that they can build up a better picture of our customer base and general consumer trends; and
• for any other purposes that you have consented to.

Direct marketing

Where we have your express or implied consent, or where we are otherwise permitted by law, we may contact you with information about our products and the services on the Site, or those of our Mason and Kelly and/or our affiliates. You can opt out of receiving these communications at any time, by either contacting us, or by using the unsubscribe facility that we include in our commercial electronic messages (i.e., email) to opt out of receiving those messages.

To whom do we disclose your personal information?

We may disclose your personal data to enforce our policies, or where we are permitted to do so by applicable law, such as in response to a valid, legally-compliant request by a law enforcement or governmental authority, or in connection with actual or proposed litigation, or to protect our property, people and other rights or interests.

We may also share your personal data with:

• One of our partners if you’ve requested their services or if you’ve requested to be provided with information by them;
• Another member if you have done business with them;
• Companies in the Mason and Kelly group and/or affiliates;
• Other companies we work with to feature all or part of our PP listings or otherwise provide promotional or other services related to our or Mason and Kelly group’s business. This might include featuring your listings and photographs on other websites;
• Any third party you have asked us to share your personal data with – such as Facebook if you have asked us to connect with your Facebook account; or
• Our contracted services providers, including:
  • Information technology service providers (including cloud services providers);
  • Marketing, communications and research agencies;
  • Mailing houses, postal, freight and courier service providers;
  • Printers and distributors of direct marketing materials;
  • External business advisers (such as recruitment advisers, auditors and lawyers).
  • If you choose to send an enquiry to a member on a Site, your personal information, including your email address and any other information you supply (unless the Site specifies otherwise), will be visible to the relevant member so that they can reply directly to you. Enquiries sent using the SHP / IP system are also available for review to a limited number of customer service employees, who may be asked by a member or others for their past enquiry information.

In the case of these contracted service providers, 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 products or services.

We may de-identify and aggregate the personal information of you and others for our own statistical purposes. Provided that it remains permanently de-identified, we may disclose that aggregated information to third parties or publish it for marketing or research purposes.

If you post comments or otherwise communicate publicly with other users via our Site, any information about yourself that you include in the communication may be stored on the Site and accessed by other users. For this reason, we encourage you to use discretion when deciding whether to post any information that can be used to identify you.

In the unlikely event that SHP / IP or any part of the Mason and Kelly group is sold, or some of its assets transferred to a third party, your personal information, as a valuable asset, may also be transferred. Potential purchasers and their advisors may have access to data as part of the sale process. However, use of your personal information will remain subject to this Privacy Policy. Similarly, your personal information may be passed on to a successor in interest in the unlikely event of a liquidation, bankruptcy or administration. Our customer database could be sold separately from the rest of the business, in whole or in a number of parts. It could be that the purchaser’s business is different from ours also.

Changes to this Policy

We may amend this Privacy Policy from time to time to reflect regulatory requirements; advances in technology, Site updates and changes in our information collection and disclosure practices.

Any new policy will automatically be effective when it is published on the Site and a copy may be obtained by contacting us. You should therefore return here regularly to view our most up to date Privacy Policy.

ABN 27 607 469 134