Personal Information is any information or opinion (recorded in any form) about an identified individual or an individual who is reasonably identifiable, whether true or not.
Avia must by law comply with the privacy principles under thePrivacy Act 1988 (Cth) (as may be amended from time to time) (Privacy Act).
Each reference in this Policy toyou oryouris a reference to the relevant individual in respect of whom we receive or collect information. For the avoidance of doubt, this Policy does not apply to information about or relating to a company or other entity that is not an individual.
Collecting Personal Information
The information we collect
We only collect Personal Information about you that is necessary to perform our functions and activities.
The types of Personal Information which any Avia group company may collect and hold will depend on the type of products or services that it provides to you. We usually collect the following types of Personal Information:
- Contact information (including name, email address, mailing address, telephone and fax numbers)
- Information provided in connection with the purchase of any products or services supplied by an Avia group company (eg. billing and account information including payment card and bank account information, information contained on a pilot’s and/or driver’s licence and information about your health (see however the section below headed “Sensitive Information”)
- Information about transactions with us (eg. purchase history) and use of our products and services
- Information provided by you through Avia related communication channels such as social networking sites managed or owned by an Avia group company, telephone and/or email support, or customer service
- Information provided by you through customer surveys, prize draws, competitions, promotions, loyalty programs, special events or other offers
We also collect information about you when you use the website of any Avia group company. The only Personal Information we collect about you when you use such a website is what you tell us about yourself (eg. information you provide to us when you send us an email. We will record your email address if you send us an email).
When you visit the website of an Avia group company, the relevant server may cause a small data file called a “cookie” to be saved to your computer’s memory.
As is common on the internet, we track usage patterns on our websites. Your identity cannot reasonably be ascertained from this information. Each time you visit our websites, the relevant web server makes a record of your visit. Specifically, it records:
- Your internet provider
- Date and time of your visit
- Pages viewed
- Search items entered
- Referring URLs
How we collect information
We may collect personal information in a number of ways, including:
- Directly from you (eg. when you provide information online, by phone, in application forms or in agreements)
- From another Avia group company
- From our own records of how you use products and/or services supplied by an Avia group company
- When you visit our websites or other social networking sites managed or owned by an Avia group company
- From publicly available sources of information such as market research providers
- From third party companies such as credit reporting agencies and our business partners
If you do not provide the Personal Information requested, we may not be able to provide the products or services you require, or the level of service on which we pride ourselves.
Sensitive information is a specific type of personal information that includes health information and information about an individual’s race, ethnic origin, political opinions, membership of political, professional or trade associations, religious or philosophical beliefs, sexual preferences and criminal history.
The privacy principles under the Privacy Act impose greater obligations on us regarding any collection, use or disclosure we make of your sensitive information. We will only collect your sensitive information where it is reasonably necessary for or directly relates to our functions or activities and if:
- You have expressly consented to us doing so; or
- We are required to do so by law.
Use of Personal Information
Any Personal Information which we collect about you will be used for the purposes for which it was collected and for related purposes that would reasonably be expected by you. These purposes may include any one or more of the following:
- To provide you with the products or services you have requested
- To administer and manage those services (including collecting and processing payments and completing transactions)
- To carry out credit checks and obtain consumer credit reports
- To research and develop our products and services, and to gain an understanding of your needs in order for us to provide you with better products and services
- To maintain and develop our business systems and infrastructure
With your consent or on your request, we may also use your Personal Information to provide you with relevant advertisements and relevant information about promotions, as well as the products and services of one or more Avia group companies which we believe may be of interest to you.
When you provide us with information about yourself, you will usually be given the option to let us know that you do not want that information to be used for direct marketing purposes, whether by ourselves or by any third party. If you do not take up that option, you are deemed to have agreed to the use of your information for direct marketing. You can change your mind about your preferences in respect of direct marketing by contacting us using any of the contact details set out below. In addition, if you receive direct marketing from us, you will be reminded in that communication that you are able to request a change to your preferences and we will respect your request.
Disclosure of Personal Information
When we disclose your Personal Information
Personal Information is usually used or disclosed only after obtaining your consent. We will only disclose Personal Information for the purposes to which you have agreed or for related purposes that would reasonably be expected by you.
You consent to us disclosing your Personal Information:
- To another Avia group company;
- To our suppliers (including service and content providers), contractors, dealers, agents, and business partners who perform services for us;
- To credit reporting agencies for purposes permitted under the Privacy Act
- To our professional advisers including our accountants, auditors, lawyers and insurers;
- To anyone to whom our assets or business (or any part of them) is transferred; or
- As otherwise required or authorised by law.
We will only transfer your Personal Information overseas if:
- We reasonably believe that the recipient of the information is subject to a law or a contract which effectively upholds privacy principles substantially similar to the privacy principles set out in the Privacy Act;
- You have consented to the transfer; or
- We are otherwise required or authorised by law.
Access to Personal Information
How you can access your Personal Information
You have a right to access your Personal Information. If you would like to do so, please direct your request to the privacy officer by email, facsimile or post using the contact details below. We will respond to your request as soon as possible and no later than 30 days after receiving your request.
In certain situations prescribed by law, we may refuse to give you access or limit the access to your Personal Information. This may include where giving access would be unlawful or would have an unreasonable impact on the privacy of other individuals. If we refuse you access, we will provide you with reasons for our refusal.
We reserve the right to charge a fee for searching for and providing access to your Personal Information (but not for the request itself).
Accuracy of Personal Information
If you think that Personal Information which we hold about you is not accurate, complete and up-to-date, you may request us to correct that information and we will take all reasonable steps to correct the information. Please contact us if the details you have provided change.
Security of Personal Information
We understand the importance of protecting your Personal Information. We take all reasonable precautions to protect the Personal Information we hold about you from misuse and loss, and from unauthorised access, modification or disclosure.
We maintain physical security, such as locks and security systems, over our paper and electronic data stores and premises. We also maintain computer and network security, including firewalls, scanning software to detect and block malicious code and certain unsolicited commercial emails, and other security measures (such as identification codes and passwords) to control access to computer systems. We do not guarantee that our safeguards will always work.
Please be aware that our information security software may cause some email messages sent by you not to be received. We also remind you that if you send information to our websites or by other electronic means, the internet and other forms of electronic communication are not a secure environment and although all care is taken, we cannot guarantee the security of information you provide to us via electronic means.
Destruction of Personal Information
We will destroy Personal Information if it is no longer needed for the purposes for which we collected it or for the purposes of meeting legal requirements. We will properly dispose of all paper files, letters, correspondence and any other hardcopy documents that contain Personal Information that is no longer needed.
All Personal Information stored in electronic form that is no longer required will be deleted from our systems.
Contact us about our privacy and information handling practices
If you have any questions or would like further information about our privacy policies or practices, please contact us by contacting our privacy officer by any one of the following means:
- Email: firstname.lastname@example.org
- Telephone: (03) 8677 7760
- Fax: (03) 8677 6976
- Post: Privacy Officer, Avia Aviation, 21 First Avenue, Moorabbin Airport, Victoria 3194
If you wish to make a complaint about the way we have collected, used, held or disclosed your Personal Information, please contact us using the contact details above.
To assist us in helping you, please gather all supporting documents about the matter of complaint, think about the questions you want answered and decide on what you want us to do.
We will use the information you provide to investigate and respond to your privacy complaint. We aim to resolve all complaints as quickly as possible. Some complaints are resolved within weeks, but more complex complaints may take longer. Where the complaint is likely to take longer than 3 months to resolve, we will inform you of this and we will provide you with an estimated date of resolution. You may withdraw your complaint at any time.