Australia and New Zealand Privacy Policy

Last Updated: 22 April 2024

 

Minor Hotels respects your privacy and is committed to protecting your personal information. Minor Hotels is an international group which has hotels in a number of locations internationally, including in Europe, Australia and New Zealand.  Minor Hotels must comply with privacy requirements across these locations.  How Minor Hotels complies with its privacy obligations is detailed in the Global Privacy Policy (Group Policy) and also other privacy documents which are specific to individual locations.

This is the Australian and New Zealand Privacy Policy for the Minor Group, covering Oaks Hotels and Resorts Limited and its affiliates and subsidiaries (details of which are listed here) (collectively, "we", "us", "Minor Hotels"). This Privacy Policy outlines specific requirements under Australian or New Zealand privacy law that apply in addition to the overarching obligations under the Group Policy. You should read this document in conjunction with the Group Policy as directed in this Policy.

We comply with all applicable privacy requirements including the Privacy Act 1988 (Cth) in Australia and the Privacy Act 2020 (NZ) in New Zealand (each a "Privacy Act") and the Australian Privacy Principles (“APP”) and the New Zealand Information Privacy Principles, which regulate how we may collect, use, disclose, store and protect your information. This Privacy Policy is intended to keep you informed and help you to understand your rights (and our obligations) under the applicable Privacy requirements in Australia and New Zealand.  By using any of our products or services and/or by agreeing to this Privacy Policy, e.g. in the context of registering for any of our products or services, you understand and acknowledge that we will collect and use personal information as described in this Privacy Policy.

WHAT IS 'PERSONAL INFORMATION'?

Personal information under this Policy can generally be considered as being information related to an identified or identifiable individual or information or an opinion about an identifiable individual, whether true or not, which identifies an individual from others or from which your identity can be reasonably obtained.

HOW IS YOUR PERSONAL INFORMATION COLLECTED?

Please refer to section 4 of the Group Policy.

TYPES OF PERSONAL INFORMATION WE COLLECT

Please refer to section 6 of the Group Policy.

PURPOSES FOR HANDLING YOUR PERSONAL INFORMATION

We use personal information to provide you with Services, to develop new products and services, and to protect Minor Hotels and our guests as detailed below.

We will use this information for the following purposes:

  • Performing our customer service obligations, such as the creation and management of reservations and your stay in our properties, payment, catering to your requests, monitoring use of services (telephone, bar, pay TV, etc.), in response to a contractual relationship between you and us, such as a hotel booking or service request;
  • Improvement of our services, such as assessment of our services in hotels, restaurants and other outlets, improvement in the operation of our business as part of the contracted relationship between you and us;
  • Personalisation of our services and communications, for example to personalise content and tailor our digital customer experience and offerings, understand customers’ requirements to develop targeted marketing programs, newsletters and promotions. We will always seek and record your permission to opt in and participate in any of our marketing campaigns. Use of your information for marketing is presented in more detail under the Marketing section below. Personalisation of our website based on your preferences is covered in the Cookie Policy;
  • Administration of loyalty programs in partnership or alliance with GHA Discovery and other frequent flyer program partners;
  • Compliance with legal obligations in accordance with applicable laws, such as local privacy laws, GDPR, prevention of fraud or money laundering, police investigations, as required by a court or other laws to be disclosed and tourism regulations; and
  • Safety and security to maintain the safety, health and wellbeing of customers, and protecting Minor Hotels’ assets, assets owned by third parties in buildings Minor Hotels occupies and manages, and employees.
  • Membership programs: To administer and operate voluntary membership program such as the GHA DISCOVERY program and frequent flyer program. The personal information may be used to record stay and transactional data, earning and redeeming rewards, points or credit in connection with the program.
  • Direct marketing communications: sending you promotional offers and event details, subscribing and unsubscribing you, when you request it. The lawful grounds for these processes are the performance of the contract and user consent.
  • Management of general and hotel enquiries: To manage communications, provide information and respond to general requests from users through the channels available for this purpose on the website or other Contact Us functions. To manage booking or services requests related to reservations at the hotels. To receive feedback about products and services provided. The lawful grounds for these processes are user consent, the performance of the contract and legitimate interest.

Additionally, we may also handle your personal information for the following purposes, particularly if you interact with our website. Please refer to section 5 of the Group Policy.

DISCLOSURE OF PERSONAL INFORMATION

Please refer to section 7 of the Group Policy.

PROTECTION OF YOUR PERSONAL INFORMATION

Minor Hotels stores information in both physical and electronic form including using third party IT providers. We maintain appropriate physical, procedural and technical security for our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure, or modification of personal information.  This also applies to disposal of personal information.

We will destroy or de-identify personal information once it is no longer needed for a valid purpose or required to be kept by law.

DIRECT MARKETING 

Please refer to section 11 of the Group Policy.

Please also see the Australian and New Zealand contact details at the bottom of this Privacy Policy.

OVERSEAS TRANSFER OF PERSONAL INFORMATION

Please refer to section 8 of the Group Policy.

When we share personal information, it may be transferred to, and processed in, countries other than the country you live in – such as to the United States, Singapore or where our data hosting provider’s servers are located. These countries may have laws different to what you’re used to.  Where we disclose personal information to a third party in another country, we put safeguards in place to ensure your personal information remains protected.

For individuals in the European Economic Area (EEA), this means that your data may be transferred outside of the EEA. Where your personal data is transferred outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where we have approved transfer mechanisms in place to protect your personal data, for example, by entering into the European Commission’s Standard Contractual Clauses.

By providing your personal information to us, you consent to us disclosing your personal information to any such overseas recipients for the purposes described in this privacy Policy and agree that APP 8.1 will not apply to such disclosures and acknowledge that such overseas recipients may not be subject to laws that require them to protect your personal information in a way that is comparable to the safeguards in the applicable Privacy Act.  For the avoidance of doubt, in the event that an overseas recipient breaches the Australian Privacy Principles, that entity will not be bound by, and you will not be able seek redress under, the Privacy Act.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal information.

YOUR RIGHTS

Please refer to section 10 of the Group Policy. In addition to the rights listed in the Group Policy, you also may have the right to not be subject to automatic decision making.

CONTACT US

Please contact Minor Hotels using the details below if you have any questions, concerns or complaints regarding this Privacy Policy or our handling of your personal information.

Minor Hotels
Email: [email protected]; or
Post: PO Box 473, Cotton Tree, QLD 4558, Australia

Minor Hotels takes all complaints seriously and will respond to your complaint within a reasonable period.

COMPLAINTS FOR THOSE SUBJECT TO AUSTRALIAN AND NEW ZEALAND PRIVACY LAWS

Should you believe that we have not fulfilled our obligations under the relevant Privacy Act, have not complied with the terms of this Policy, or would like to appeal a decision made by us relating to your personal information, you can make a complaint in writing to our Privacy Officer using the details set out in this Privacy Policy. We will respond to you within a reasonable period of time to acknowledge your complaint and inform you of the next steps we will take in dealing with your complaint.

In the event that you are dissatisfied with a response you have received, and if the relevant Privacy Act is applicable, you have the option of referring your complaint to the Office of the Australian Information Commissioner (OAIC) for Australian related matters or to the Office of the Privacy Commissioner (OPC) in New Zealand for New Zealand related matters.

The OAIC and OPC contact information may be found below: 

Australia:

OAIC - listed on their website: https://www.oaic.gov.au/ 

At the date of this policy, the OIAC’s details are:

Office of the Australian Information Commissioner
Post: GPO Box 5218, Sydney  NSW  2001
Telephone: 1300 363 992
Email: [email protected]

New Zealand:

OPC - listed on their website: https://privacy.org.nz/ 

At the date of this policy, the OPC’s details are:

Office of the Privacy Commissioner (Te Mana Mātāpono Matatapu)
Post: PO Box 10 094,Wellington 6143
Telephone: 0800 803 909
Email: [email protected]

CHANGES TO THIS PRIVACY POLICY

We reserve the right to change the terms of this privacy policy from time to time, without notice to you. An up-to-date copy of this privacy policy is available on our website.