Adara Group Privacy Policy

This privacy policy applies to all websites operated by Adara Hotels Apartments under the domain names www.adara.com.au; www.adarahotelsapartments.com.au; www.adararichmond.com.au; www.adarafranklin.com.au; www.adarastkilda.com.au; www.adarabrunswick.com.au.

DEFINITIONS

In these terms and conditions:

• “Adara Group” means any of the Adara Hotels and Apartments
• “We”, “our”, “us” and “Adara Group” means the Adara Group of companies
• “You” and “your” means the person who is making the reservation.

Adara Hotels Apartments understands and appreciates that you, as an Adara Group customer or website visitor, are concerned about your privacy and about the confidentiality and security of information we may gather about you. Adara Group is committed to protecting your privacy. This privacy policy explains how your personal information will be treated as you interact with Adara Group.

As the Adara Group websites develop and as technology evolves, Adara Group will continue to strive to provide you with better and more customised services and with more effective websites. Adara Group encourages you to review this privacy policy periodically because it may change from time to time.

This privacy policy explains how Adara Group generally protects your privacy and confidentiality.

Your personal information is important to us

“Personal information” is information that identifies you or could identify you. The types of personal information we collect may include your name, address, contact phone number, email address, date of birth, passport and visa information, transaction information and financial details. We may also keep a record of products and services that you acquire from us.

Where the personal information requested includes an email address and/or mobile phone number, Adara Group will only contact you by email or SMS if you agree to being contacted in this manner.

Adara Group is committed to protecting your personal information and complying with the Australian Privacy Act 1988 (Cth) (APA) and the Australian Privacy Principles (APPs). We believe that our privacy policy is both fair and represents industry best practice. From time to time, you may be able to deal with us anonymously or by pseudonym, but in some instances if you do not provide us with certain information, we may not be able to provide you with the information or services you want.

The information we collect about you

Generally, only information you provide about yourself to Adara Group directly will be collected, such as through enquiring about, or using, Adara Group’s products & services or Adara Group’s website, making a booking on Adara Group’s websites or by phone or otherwise identifying yourself when requesting information to be sent to you. In certain circumstances, we may collect information about you from third parties. However, we will only do so if it is unreasonable or impracticable to collect the personal information directly from you and we will take reasonable steps to inform you if and when we do.

Adara Group only collects personal information which is reasonably necessary for, or directly related to, one or more of its functions or activities. For example, Adara Group collects personal information from you in order to provide and charge for the hotel accommodation and other goods and services you purchase. We may also collect personal information about you to better understand your requirements and preferences, improve our services and to provide offers that may be of interest or benefit to you. For example, when you fill out a contact form, we collect the details you enter to enable us to send information to you. When you answer questions about what you would like to see we keep this information so as to better serve you. If you do not provide the personal information we request from you for these purposes, we may not be able to carry on our business and provide our services to you.

There may be instances in which the personal information that you provide to us or that we collect is considered “sensitive information”. “Sensitive information” refers to personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious or philosophical beliefs, membership of a professional association or trade union, sexual preferences or practices, criminal record and health, biometric and genetic information. We will only collect and process sensitive information about you in accordance with, and to the extent permitted by, the Australian Privacy Principles (and any replacement or successor laws).

Adara Group’s use of “cookies”

Adara Group uses “cookies” to help enhance your experience on the websites. Cookies are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes. Most Web browsers are set to accept cookies as the default. However, if you do not wish to receive any cookies you may set your browser to refuse cookies. If you turn off cookies we cannot, for example, fill out forms automatically with details you have previously given us.

The use of cookies can enhance your experience on Adara Group’s websites, by remembering information that you have previously given to us. They can make it easier for you to fill out forms, book online and can ensure that information provided to you is most relevant to your interests. Cookies can also provide us with information on how our customers use our websites so that we can continually improve the design of the websites.

Cookies themselves do not contain personal information about you. They simply operate as a unique identifier which helps us to know what our customers find interesting and useful on our websites, almost like a continuing questionnaire. Adara Group does not store any personal information inside cookies, although the cookie may identify the user’s browser.

Using & disclosing your personal information

Adara Group will not use or disclose any specific personal information about you without your consent, other than for:

• the main reason for which you have provided personal information (primary purpose);
• a purpose which is related to the primary purpose and which you would reasonably expect us to use the information for;
• a purpose required, authorised or permitted by law;
• to provide our products and services to you;
• to reply to your queries or requests;
• to market our products and services including to communicate special offers or promotions and to provide you with information about us and our products and services;
• to compile and use statistical information regarding our customers; or
• to seek feedback from you and to monitor the quality of our products and services.

Adara Group and its affiliates recognise the trust you place in us when you give us personal information. For example, Adara Group may ask you questions to get a better understanding of what facilities and services would help you with your accommodation needs. We will use this information to recommend accommodation and services which we believe will be of benefit to you and your business. However, we will not disclose specific information about you and your business to any other company (except those entities specified below) without your explicit consent.

Adara Group may from time to time outsource the processing of certain functions or information to third parties. We may also provide your information to our related entities and partners. Any personal information disclosed to our agents, related entities, partners, contractors and third party service providers is only to the extent necessary for them to perform their agreed tasks and they are required to maintain the privacy of your information and keep such information confidential.

Transfer overseas

Pursuant to the Australian Privacy Principles (APPs) and Information Privacy Principles (IPPs), we may transfer personal information we have collected about you to someone other than you in a foreign country, but only in accordance with and to the extent permitted by the APPs and IPPs. We will not disclose your personal information to overseas recipients without your consent.

Business transfers

As we continue to develop our business, we may sell hotels and other assets, or cease being the manager of a hotel that is currently part of our portfolio. In those circumstances, we may include the personal information collected about you, or control of that personal information, as a business asset in any such transfer. Also, in the unlikely event that we, or substantially all of our assets, are acquired, personal information collected from you, or control of such information, may be one of the transferred assets.

Information & promotional emails

From time to time we will send you relevant information emails regarding products and services which you have previously registered your interest in. If you are receiving promotional information from the Adara Group and do not wish to receive this information any longer, you may unsubscribe at any time. All electronic communications we send to you for direct marketing purposes will include an “unsubscribe” link which enables you to opt out of receiving any future direct marketing correspondence.

Storage & security of your details

Adara Group will store personal information [electronically and in paper form].

Adara Group will take such steps as are reasonable to protect your personal information from unauthorised access or use, misuses, loss, modification or authorised disclosure, and to ensure that the personal information we hold about you is accurate, complete and up to date. Adara Group also maintain computer and network security, for example we use firewalls and other systems such as user identifiers and passwords to control access to computer systems. In addition, Adara Group’s employees are obliged to respect the confidentiality of any personal information held by the Adara Group. Personal information will be de-identified or destroyed when no longer required by us. However, to the extent permitted by law, Adara Group will not be held responsible for events arising from unauthorised access to your personal information. We encourage you to play an important role in keeping your personal information secure.

Accessing, changing & deleting information we keep about you

Your trust in the Adara Group is very important to us. If at any time you want to know exactly what personal information we are holding about you or update any information at any particular time, please email us at reservations@adara.com.auand we will respond to your request within a reasonable period. We will allow you access unless we consider that there is a sound reason under the APA or other relevant law to withhold the information. If we refuse to provide you with access or correct the personal information we hold about you, we will provide reasons for such refusal. In addition, you may request that the personal information Adara Group holds about you be corrected by emailing us at reservations@adara.com.au. If Adara Group and you disagree on whether the information is accurate, complete and up-to-date, you can make a statement about the requested changes and we will attach this statement to our records.

Adara Group & links to other websites

Adara Group provides links to websites outside of the Adara Group’s portal. These linked sites are not under the control of Adara Group, and we are not responsible for the conduct of companies linked to our websites. Before disclosing your personal information on any other website, we advise you to examine the privacy policies for those sites. Should you be concerned with the conduct of a site which you accessed via a link from the Adara Group websites, please help us to help you, by emailing us at reservations@adara.com.au.

How we handle email

We will preserve the content of any e-mail that you send us, if we believe that we have a legal requirement to do so. Your e-mail message content may be monitored by Adara Group’s employees for security issues including where e-mail abuse is suspected; our response to you may be monitored for quality assurance issues.

Complaints

If you have a complaint regarding the way in which your personal information is being handled by Adara Group, please contact us in the first instance. If you are not satisfied with the response that you receive, you may choose to escalate your concern to the Australian Information Commissioner. If you would like to obtain further information about privacy issues in Australia, please visit the Australian Information Commissioner’s website: http://www.privacy.gov.au/

You acknowledge and accept that your use of Adara Group’s websites and services or entering our premises indicates your acceptance of the Adara Group’s Website Terms and Conditions and this privacy policy.

This is the current Adara Group’s privacy policy. Adara Group may at any time amend this privacy policy by publishing the changes on the Adara Group’s websites.

How to contact us

If you wish to access your personal information, correct your personal information, have a complaint regarding Adara Group’s handling of your personal information or have a query about this privacy policy, please contact the Adara Group’s privacy representative at reservations@adara.com.au.