Elite Travel Service Limited complies with the New Zealand Privacy Act 2020 when dealing with personal information. It applies to personal information provided or collected through www.elitetravel.co.nz.
Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
This policy does not limit or exclude any of your rights under the New Zealand Privacy Act 2020. For further information on the New Zealand Privacy Act 2020, see www.privacy.org.nz.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed.
Changes to this Policy
We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 15 December 2020.
We collect personal information from or about children aged under 16 for the purposes of providing travel services. We rely on representations from customers that they have appropriate individual or parental consent for any children included in a booking with us.
What Personal Information do we Collect?
Directly from you
When you fill in a contact or enquiry form on our website, call us, meet us in person or otherwise contact us, we collect your name, email address, phone number and any other information you choose to provide to us.
When you refer another person to use our website or related services, we collect your name and email address, that other person’s name and email address and any other information you choose to include in the referral.
When you purchase services from us, we may collect your name, date of birth, passport details, email address, phone number, credit card information, purchase history and any other information you submit to us for billing and order fulfilment purposes.
We also collect the following sensitive or special categories of personal information: personal data revealing racial or ethnic origin and religious or philosophical beliefs (Sensitive Information). We collect Sensitive Information when you provided your meal preferences, confirm certain travel preferences, and/or provide us with your passport details.
Some of the personal information that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some of the information that we may request, this might mean that our services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our services to you. If you require further information about the consequences of not providing us with any information, please contact us.
Automatically when you use our website
When you access and use our website or related services we may automatically collect information about your device and usage of our website, products and services, including your IP address, operating system, browser type, time spent on certain pages of the website, pages visited, links clicked and language preferences.
From third party sources
Where possible, we collect personal information from you directly. However, sometimes we may collect:-
- personal information from third parties where you have authorised this
- personal information about you from our trusted advertising partners which may include demographic information, browsing history, location and online behavioural or profile information
- personal information included in User Data.
We may combine the personal information about you that we receive from third parties with the personal information we collect from you directly or with device and usage data we collect automatically when you visit our website.
How we use your Personal Information
We may use your personal information to:-
- verify your identity
- provide our website, third party products and other services to you
- provide with travel documentation
- market our third party products and our own services to you, including contacting you electronically (e.g. by text or email for this purpose)
- improve our website, products and services
- publish things on our website (e.g. comments on pages)
- run promotions (e.g. referral and loyalty programmes, surveys and contests)
- bill you and collect money that you owe us, including authorising and processing credit card transactions
- respond to communications from you, including enquiries and complaints
- conduct research and statistical analysis
- tailor content or advertisements on our website
- protect and/or enforce our legal rights and interests, including defending any claim
- respond to lawful requests by public authorities, including to comply with law enforcement requirements, or
- for any other purpose authorised by you or applicable law.
We may transfer your information in the case of a sale, merger, consolidation, liquidation, re-organisation or acquisition.
We may use Sensitive Information to deliver our services and meet third party obligations.
Disclosing your Personal Information
We may disclose your personal information to:-
- another company within our group in connection with any of the potential uses of your personal information identified above
- any business that supports (or delivers services you have requested in connection with) our website, products and services, including any person that hosts or maintains any underlying IT system or data centre that we use to provide our website, products or services or that we use to process payments
- a credit reference agency for the purpose of credit checking you
- third parties (for anonymised statistical information)
- professional advisers e.g. accountants, lawyers or auditors
- a person who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority)
- any other person with your consent
- any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition
- any other person authorised by applicable law.
International Transfers of Personal Information
A business that supports our website, products and services or delivers services that we sell as agent may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where you are located. Elite Travel Service acts as a travel agent on behalf of travel services suppliers (Principals). Relevant personal information that we collect at the time of booking/quote will need to be provided to the Principals (for example, Airlines) and other supporting entities (for example, Amadeus IT Groups, S.A.) in order to facilitate and process your booking/quote. Where Principals or other supporting entities that process your booking/quote are located outside of New Zealand, we cannot guarantee that your Personal Information will be protected to the same standards as apply in New Zealand. By proceeding with your booking/quote, you acknowledge and consent to this arrangement on behalf of all travellers.
For further information, please contact us.
Some of the personal information we collect is processed in New Zealand. New Zealand is recognised by the European Commission as a country that has an adequate level of data protection and we may rely on this decision in transferring personal information to New Zealand.
Protecting your Personal Information
As required by applicable law, we will take steps to keep your personal information safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information.
You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
Accessing and Correcting your Personal Information
Subject to certain grounds for refusal under applicable law, you have the right to access your personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal information, we will make the correction. In all other cases, we will take reasonable steps to make a note of the personal information that was the subject of your correction request.
If you want to exercise either of the above rights, contact us. Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
DATA Retention policy
The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.
The name and contact details of our Data Protection Officer is:
|Phone number||0800 767 320|
Lawful Basis for Processing Personal Information
Our lawful basis for processing your personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it.
Generally, we collect personal information from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms).
Where we process personal information based on your consent, you may withdraw your consent at any time.
Our lawful basis for processing Sensitive Information is your consent.
Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal information or need further information, please contact us.
Your rights in relation to your personal information include:
- right of access – if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information
- right to rectification – if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible
- right to erasure – when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information
- right to withdraw consent – if the basis of our processing of your personal information is consent, you can withdraw that consent at any time
- right to restrict processing – you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible
- right to object to processing – you may request that we stop processing your personal information at any time and we will do so to the extent required by applicable law
- rights related to automated decision-making, including profiling – you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making
- right to data portability – you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller
- the right to complain to a supervisory authority – you can report any concern you have about our privacy practices to your local data protection authority.
Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please contact us. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.