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 identified 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 enquires about travel arrangements or other products and services, 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. This includes where a person makes a travel booking on your behalf which includes travel arrangements to be used by you (e.g. a family or group booking). 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.
What personal information do we collect?
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel-related services and products on your behalf. 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, frequent flyer details, information about your dietary requirements and health issues (if any), and other details relevant to your travel arrangements or required by the relevant travel service providers (e.g. airlines, accommodation or tour providers). 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 The Working Holiday Club 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 (e.g. to make travel arrangements on your behalf). Where you provide sensitive information to us, you consent to us using that sensitive information for the purpose for which it was collected. For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf.
When we book products and services for you, we usually do so as agent for or on behalf of travel service providers. This means that we usually collect personal information about you both for our internal purposes (e.g. to process your booking), and on behalf of the parties for whom we act as agent, for their internal purposes (e.g. to provide the booked services). 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 flight from us, then under this Policy you will have consented to your personal information being provided to the airline to enable your flight to be booked.
We act as agent for or on behalf of many thousands of travel service providers, so it is not possible for us to set out in this Policy all of the travel service providers for whom we act nor exactly how each of these travel 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 a travel booking or query, the primary purpose for which we collect your personal information is generally to provide you with travel advice and/or to assist you with booking travel and/or travel related 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 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 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.
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?
Yes. 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 travel service providers such as travel wholesalers, tour operators, airlines,
- hotels, car rental companies and other service providers for the purpose for which the information was collected or for a related purpose (for example to facilitate and process your travel arrangements);
- to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
- 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 travel service providers, see the heading above titled “When we act as agent”.
Where we engage travel service providers to perform services for us, those travel service providers may be required to handle your personal information. Where we disclose your personal information to such travel service providers, you agree that we will not be required to ensure their compliance with applicable privacy laws or otherwise be liable or accountable for how they handle your personal information.
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.
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.
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 agree that we will not be required to ensure the recipient’s compliance with Australian privacy laws or otherwise be liable or accountable for how the recipient handles your personal information. 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 travel service providers. For instance, where you request travel to be booked with an overseas travel service provider, we will usually need to disclose your personal information to that provider for the purposes of arranging your booking with them. These travel service providers will in most cases receive your personal information in the country in which they will provide the services to you or in which their business is based.
We may also disclose your personal information to our overseas related entities and to travel service providers 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 your travel booking 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
The Working Holiday Club 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.The Working Holiday Club regularly reviews security and encryption technologies and will strive to protect your personal information as fully as we protect our own confidential information.
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.
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 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 16 January 2014.
What We Collect and How We Use It
In the course of providing the Services, we collect and receive various types of information. Certain categories of information collected by The Working Holiday Club Pty Ltd (TWHC) are necessary to use our Services. In order to deliver, personalize, and improve our Services, we combine and use the information we have about you (including information we receive on and off our Services) to understand how you use and interact with our Services and the people or things you’re connected to and interested in. We describe these types of information and their uses in more detail below.
We mainly rely on three separate bases to lawfully collect and use your information.
- Second, where you have given us consent to use your information in certain ways, we will rely on your consent (which you may revoke at any time).
- Third, as described in more detail below, in certain cases we may process your information where necessary to further legitimate interests, whether ours or those of visitors, users or partners, where those legitimate interests are not overridden by your rights or interests.
Occasionally, TWHC may rely on other legal bases to process your information, such as to protect your vital interests or those of others (such as where there is a risk of imminent harm), where necessary in the public interest, or to comply with a legal obligation, a court order, or to exercise and defend legal claims.
Account Information: When you create an account on the Services (an ” Account“), we’ll ask you for information such as your username, password, age, and email address (“ Account Information”) in order to provide you with the Services. We may also use Account Information, alone or together with other information, to enhance and improve the Services, such as by personalization. We use your age to verify that you can lawfully use the Services. We use your email address to verify your Account and to communicate with you, as described in more detail below.
Email Communications with Us: As part of the Services, you may occasionally receive email and other communications from us. Administrative communications relating to your profile are considered part of the Services and your profile, which you may be able to opt-out from receiving. We also may send you other kinds of emails, which you can opt-out of by replying “unsubscribe”.
Information Obtained from Third Party Services: In some cases, we partner with Third Party Services that may provide information about you. Such information could include, for example, your gender, if you have disclosed that information to that third party and made it available for TWHC to access or receive it. To the extent we obtain such information, we may use it to develop new Services or to improve or enhance the Services.
When you connect other services to your TWHC account, those services might share information about you with us. What gets shown to us is determined by their privacy policies, which are long and boring, but which you should probably read if you have questions or concerns.
User Content: By default, all sharing through the Services is public. When you provide us with content, it is published so that anyone can view it. We do provide tools, like password-protected blogs, Asks, and Fan Mail, that let you publish content privately. Unless you have selected otherwise you should assume that anything you publish is publicly accessible. Also, please keep in mind that anything you share privately with another user, particularly through an Ask, Fan Mail, or submitted post, may be subsequently posted publicly by that user. Content published and shared publicly is accessible to everyone, including search engines, and this may affect the control you have regarding that content. In addition, information shared publicly may be copied and shared throughout the Internet, including through actions or features native to the Services, such as reblogging.
At its heart, TWHC is a public platform. Don’t be afraid to share amazing things, but do understand that it can be hard to completely remove things from the internet once they’ve been reblogged a few times.
Information About User Content: In some cases, we may collect information about content you provide to the Services. For example, when it’s included as part of your profile, we may collect information about your trip. This information allows us to improve the Services and provide additional features and functionality.
Financial Information: We will sometimes collect financial information, such as information related to your payment method (valid credit card number, type, expiration date or other financial information). We ask for this information when you decide to purchase a paid Service and request to make payment via credit or debit card. We do not, however, in any circumstances store that financial information in our system.
Information Related to Use of the Services: We collect information about how people use the Services, including those with a profile. This type of information may be collected in our log files each time you interact with (i.e., make a request to) the Services. We use internal tools and third party applications and services to collect and analyze this information. Some of this information may also be associated with the Internet Protocol Address (“IP Address”) used to access the Services; some may be connected with your profile; and some may only be collected and used in aggregate form (as a statistical measure that wouldn’t identify you or your profile). We also collect your IP Address when you make an enquiry.
We use information about how you interact with TWHC in order to personalize it for you, to keep both you and our community safe from harm, and to improve TWHC programs for everyone who uses them.
Location Information: In some cases we collect and store information about where you are located. We may also ask you to provide information about your location. We may use location information to improve and personalize the Services for you, for example by providing you with relevant travel and working holiday information.
Information Related to Your Mobile Device: We may collect and store information related to your mobile device. This will only ever be to the extend that if you provide us with a mobile number in your online enquiry, we may store this number to keep in contact with you.
With Whom Your Information Is Shared
Information Shared Between the Services: We may, if possible, aggregate information about your use of multiple Services and use that consolidated information to enhance and improve the Services, and to develop new Services.
Information Shared with Our Agents in Order to Operate and Improve the Services: In some cases, we share information that we store with third parties, such as service providers, consultants, and other agents (“Agents“), for the purposes of operating, enhancing, and improving the Services, and developing new products and services. For example, we may share information with service providers in order to fight spam, and third-party consultants may have access to information in the process of improving our processes and technology. Agents with whom we share such information for these reasons are generally bound by confidentiality obligations and, unless we tell you differently, our Agents do not have any right to use information we share with them beyond the scope and duration of what is necessary to assist us.
Information We Share with Your Consent or at Your Request: Without prejudice to your rights mentioned below where you are a user, if you ask us to release information that we have about your profile, we will do so if reasonable and not unduly burdensome.
Information Shared with Other Third Parties: We may share or disclose public, aggregate or depersonalized information with people and entities that we do business with.
Security and Retention of Your Information
Protecting our systems and our users’ information is paramount to ensuring TWHC users enjoy a secure user experience and maintaining our users’ trust.
Your Profile Information is protected by a password for your privacy and security.
We may also use your information for safety and security purposes, including the sharing of your information for such purposes and we do so as it is necessary to pursue our and your legitimate interests of ensuring the security of our Services, including enhancing users’ protection against harassment, IP infringement, spam and crime and security risks of all types.
You have the right to object to any of this processing and if you want to object please contact TWHC help.
Controls and Privacy Rights
If you are usually resident in Australia or New Zealand, TWHC is the data controller of your information. In accordance with Australian and New Zealand law, you have a number of rights and choices regarding the use of your information.
Rectify, Restrict, Limit, Delete. You can also rectify, restrict, limit or delete much of your information by contacting us directly. For more information on deleting your account or leaving TWHC, please contact ;
In certain circumstances, such as those described in the ‘Legitimate Interests’ section above, you also have the right to object to the processing of your information by us. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications, or by contacting us.
Revoke consent. You have the right to withdraw your consent to our processing of your information and your use of our Services at any time. Similar to the way in which you can give consent by interacting with our Services, you can also withdraw your consent through our Services. You can choose to delete your TWHC profile as described above.
Complain. Without prejudice to any other rights you may have, you also have the right to file a complaint against us with your local supervisory authority.
Because TWHC is an Australian company, your information will be collected and processed in Australia. Australia has different laws on data protection and rules in relation to government access to information, and may not have the same data protection safeguards as your home country. You can choose whether or not you want to use our Services. However, if you want to use our Services, you need to agree to our Terms & Conditions which set out the terms of the contract between us and you. To the extent that TWHC is deemed to transfer your information outside the Australia, TWHC relies on the fact that such a transfer is necessary in order to deliver our Services to you, in accordance with the contract between us.
Where to Direct Questions or Concerns
If you have any questions or concerns regarding privacy using the Services, please contact us on