Mariner Travel Privacy Policy
1. Background
This Privacy Policy advises how Mariner Travel protects the privacy of our client’s personal information.
We need to collect, use and disclose personal information in order to perform our business functions and activities, including making and managing travel bookings on behalf of our clients. We are committed to protecting the privacy and confidentiality of personal information and to maintaining various physical, electronic and procedural safeguards to protect personal information in our care.
By providing personal information to us (either directly 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. If you do not provide us with your personal information, or if you withdraw a consent that you have given under this Policy, this may affect our ability to complete your travel booking.
For example, travel bookings must be made under the traveller’s full name and must include contact details and appropriate identification (e.g. passport details). We cannot make bookings for you without that information.
There may be instances where your local data protection laws impose more restrictive information handling practices than the practices set out in this Policy. Where this occurs we will adjust our information handling practices in your jurisdiction to comply with these local data protection laws.
2. What personal information do we collect?
Personal information generally means 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 identifiable individual, and any indication of intention in respect of an individual.
Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel bookings and to arrange travel related services and/or products on your behalf.
We may collect details such as your name, residential/mailing address, telephone number, email address, credit/debit card details (including card type, card number, security number and expiry date), passport details, loyalty program / 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 provider(s) (e.g. airlines and 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 for our monthly newsletter or competitions.
Sensitive information may include (without limitation) your racial or ethnic origin, philosophical or religious beliefs or affiliations, sexual preferences or practices, criminal record and the alleged commission of an offence, membership of political, professional or trade associations, biometric and genetic information, passwords and financial information and health information.
We will only collect sensitive information in compliance with your local data protection laws, with your consent if required to make your travel booking.
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.
We will not use sensitive information for purposes other than those for which it was collected, unless we subsequently receive your consent to use it for another purpose.
3. Collection of Personal Information?
We will collect personal information directly from you via email, phone or in person or when you connect with us via social media.
We may collect personal information about you when you purchase or make enquiries about travel arrangements or other products and services; when you enter competitions or when you subscribe to receive marketing from us (e.g. e-newsletters)
In circumstances where it is 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 or a travel booking made for you by your employer). Where this occurs, we will rely on the authority of the person making the travel booking to act on behalf of any other traveller on the booking.
By providing your personal information to us, either directly or through a family member, employer or other agent or representative in connection with a travel booking or related service, you will be deemed to have consented to your personal information being collected by us and used in accordance with this Policy.
Where you make a travel booking on behalf of another person (e.g. a family or group booking or a travel booking made for an employee), you agree you have obtained the consent of the other person for us to use and disclose the other person’s personal information in accordance with this Policy and that you have otherwise made the other person aware of this Policy.
You should let us know immediately if you become aware that you’re personal information has been provided to us by another person without your consent or if you did not obtain consent before providing another person’s personal information to us.
4. When we act as agent for a travel service provider
When we book and otherwise arrange travel related products and services for you, we usually do so as agent for or on behalf of travel service providers. In this case, we usually collect personal information about you both for our internal purposes as described in this Policy, including the purpose of us processing your booking, and for the travel service provider for whom we act as agent for their internal purposes (e.g. to provide you with the booked services). As an agent, all bookings are made on your behalf subject to the Terms and
Conditions, including privacy policy, imposed by these travel service providers. We will provide you with copies of all relevant travel service provider terms, conditions and privacy policies on request.
Accordingly, you are deemed to consent to the collection, use and disclosure of your personal information by us to the relevant travel service providers, and the use and disclosure of your personal information by the relevant travel service providers including airlines, hotels and tour/cruise operators.
5. How we use and disclose your personal information?
When 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 (e.g. collection of your personal information for the purpose of your participation in a competition, provision of feedback, etc).
By continuing to use our services and/or by providing us with personal information (or allowing another person to do so on your behalf), you consent to us using and disclosing your personal information for the purpose for which it was collected, and, where permitted by your local data protection laws.
Promotional/marketing material
Where permitted by local data protection laws, we may use your personal information to send you targeted marketing activities such a E newsletter and deals relating to our products and services (and those of third parties) that we think may interest you, unless you have requested not to receive such information or have opted out at any point.
6. Personal information disclosed to third parties.
We may disclose your personal information to third parties, as set out below, and in accordance with your local data protection laws. By continuing to use our services and/or by providing us with your personal information (or allowing another person to do so on your behalf), you consent to that personal information being processed, transferred and/or disclosed by us for the purpose of fulfilling your travel booking.
Your personal information may be disclosed to the following types of third parties:
- a person making your travel booking on your behalf, where you are travelling on a booking made on your behalf by another person (for example, a family member, friend or work colleague);
- Your employer, where you are an employee of one of our corporate, business or government clients and you are participating in an event or travelling for work purposes;
- A person who can verify to us that they have a relationship with you (e.g. a family member) where you are not contactable
- Customs and immigration processes to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel;
- Government agencies and public authorities, to comply with a valid and authorized request, including a court order or other valid legal process;
- Enforcement agencies 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.
7. Is Personal Information Transferred Overseas?
We may disclose your personal information to certain overseas recipients, as set out below, which we will do in accordance with your local data protection laws.
It is possible that information will be transferred to an overseas recipient (other than any of our overseas related entities) located in a jurisdiction where you will not be able to seek redress under your local data protection laws and that does not have an equivalent level of data protection as in your jurisdiction. To the extent permitted by your local data protection laws, we will not be liable for how these overseas recipients handle, store and process your personal information.
- Travel service providers located overseas
In providing our services to you, it may be necessary for us to disclose personal information to relevant overseas travel service providers for the purpose of performing the travel service provided.
8. Security of information
Mariner Travel has implemented various physical, electronic and managerial security procedures in order to protect the personal information it holds from loss and misuse, and from unauthorized access, modification, disclosure and interference.
We are not responsible for any third party’s actions or their security controls with respect to information that third parties may collect or process via their websites, services or otherwise.
We will destroy or de-identify personal information once we no longer require it for our business purposes, or as required by law.
9. Access and Accuracy of Personal Information
You are entitled to access any personal information we may hold about you in accordance with your local data protection laws. Where personal information we hold about you is not accurate, complete or up-to-date or the information is irrelevant or misleading, you may ask us to correct that personal information, and we will respond to your request within a reasonable time. 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, unless we subsequently become aware that it is not correct.
10. Our Website
We collect website activity statistics such as the number of visitors, pages visited, time and date of visit and where you accessed our website from, so that we can make informed decisions relating to improving our website and the services we deliver. This information is anonymous and does not identify a person.
When you visit our website a cookie is placed on your computer. The cookie does not contain personal information that can identify you, but may contain information about the page you visited on our website. If you do not wish for this to occur, you can remove cookies from your computer, by following the standard procedures applicable to your internet browser.
11. Changes to our Policy
We may amend this Policy from time to time. If we make a change to the Policy, the revised version will be posted on our website.
It is your responsibility, and we encourage you, to check the website from time to time in order to determine whether there have been any changes.
