Turu and Privacy
At Turu, we are committed to protecting and maintaining your privacy. Turu is bound by the National Privacy Principles (“NPPs”) contained in the Privacy Act 1988 (Cth) (“Privacy Act”). As part of our normal operations we may collect your personal information.
What kind of personal information does Turu collect and how does Turu collect it?
The types of personal information we collect will vary depending on the nature of your dealings with Turu (and our agents, contractors and third parties).
Turu collects most information directly from you. In most cases we collect this information so you can use our website, make inquiries and bookings with holiday parks, camping grounds and other park accommodation ("Holiday Parks"), and post opinions, comments and reviews. We may also collect information so you can request a product or service from Turu and third parties (including Holiday Parks), redeem special offers from Turu and third parties making such offers, complete a survey or questionnaire, enter a competition, seek employment, or communicate with Turu by e-mail, telephone or in writing.
Sometimes we may collect personal information to assist in identifying ways in which Turu can service you better, such as providing our products and services to you more effectively, and to assist our internal administration and operations, including accounting, risk management, record keeping, archiving and staff training.
In general, the type of personal information Turu collects and holds could include (but is not limited to) your name, address (postal and/or email), phone number and other contact details, gender, details relating to your use of the Turu website (e.g. inquiries or bookings you make with Holiday Parks, or reviews and comments you post) or the phone numbers listed on Turu, and any preferences you tell us about.
How Turu uses Personal Information
Turu uses personal information for the primary purpose for which it is collected and for other secondary purposes that are related to the primary purpose.
In general, Turu uses personal information for the following secondary purposes:
- to provide offers and information to persons who sign up to receive them from Turu;
- to provide other products or services which are requested from Turu, including advertising services;
- to process and administer our dealings with you;
- to develop processes, products and services to better meet your needs;
- to help Turu manage and enhance its products and services and the offers made to members;
- to communicate with online users of its offers;
- to provide people with ongoing information and advertising about Turu's products and services in which they may have an interest; and
- unless requested not to, Turu may provide your personal information to third parties which may in turn provide your personal information to other third parties for marketing purposes.
Where you use Turu to make an online booking with a Holiday Park, Turu uses the personal information it has collected from you, such as your name and contact details, to provide that service.
Links to Third Party Websites
Turu operates one main website in relation to its products and services and general business. To the extent that Turu contains links to sites operated by third parties and not related to Turu products, services or events (“Linked Websites”), the Linked Websites are not controlled by Turu and we are not responsible for the privacy practices of those companies. Before disclosing your personal information to Linked Websites, we advise you to examine their privacy policies.
Third Party Advertisements Online
To try and bring you offers that are of interest to you, Turu has relationships with other companies that we allow to place advertisements on our web pages. If you visit our website, advertisement server companies may collect information such as your domain type, your IP address and clickstream information.
Cookies and IP Addresses
We also log your IP address in order to help diagnose problems with our server, administer our website and track usage statistics. Your IP address may vary each time you visit, or it may be the same, depending on the type of internet connection you use to access the website. Either way, it would be extremely difficult for us to identify you through your IP address, and we make no attempt to do so. If you reached our website by clicking on a link or advertisement on another site, then we also log that information. This helps us to maximize our internet exposure, and to understand the interests of our users. All of this information is collected and used only in the aggregate; that is, it is entered into our database, where we can use it to generate overall reports on our visitors, but not reports about individual visitors.
To whom might Turu disclose Personal Information?
Turu may disclose personal information it collects about you for a variety of purposes in connection with Turu providing its products and services and special offers to you (including to our agents, contractors or to a related company). Turu may provide your personal information to:
- any Holiday Parks in relation to any bookings or inquiries you make via our website or via the phone number listed on the Turu website;
- organisations who are sponsoring, organising or otherwise involved with or participating in an offer, promotion, competition or survey;
- other companies or individuals Turu engages to perform functions on behalf of Turu such as for online bookings, production functions, printing functions, data analysis, telemarketing, research and advertising; and
- anyone you authorise Turu to disclose personal information to.
Turu may decide to buy or sell assets which form part of or relate to its business. In any such transaction, personal information will usually be one of the transferred assets and will be disclosed to the purchaser.
Where we disclose personal information to third party contractors, agents or related companies, we take steps to ensure that those agents, contractors or related third parties:
- comply with the NPPs when they handle personal information about you (regardless of whether they are a small business and would otherwise be exempt from the NPPs); and
- are authorised only to use personal information in order to provide the services or to perform the functions we require.
Otherwise, we only disclose personal information if required or permitted to do so by law or if the disclosure is permitted under the Privacy Act.
How does Turu treat Sensitive Information?
In referring to 'sensitive information' Turu means information relating to a person's racial or ethnic origin, membership of political bodies, religions, trade unions or other professional or trade association, sexual preferences, criminal record and health information.
Turu generally does not need to collect sensitive information from you, but you may choose to provide Turu with sensitive information (for example, if you have a disability that requires special services or facilities at a Holiday Park).It is Turu’s policy that this information will be used and disclosed only for the purpose for which it was provided or a directly related secondary purpose, unless you agree otherwise or use or disclosure of this information is allowed by law.
Management and security of personal information
We take physical, electronic and managerial steps to ensure that the personal information we hold is secure from unauthorised access, destruction, use, modification or disclosure. We only permit your details to be accessed by authorised personnel and we educate our staff about their responsibilities under the NPPs. Turu has also appointed a Privacy Officer to oversee Turu’s management of personal information in accordance with this policy and the Privacy Act.
Additionally, we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We also impose strict requirements of security and confidentially on all third parties as to how they store, handle and deal with personal information.
In striving to ensure that the security, integrity and privacy of personal information submitted to our site is maintained to the highest level, Turu regularly reviews and updates its security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be totally secure and you need to be aware of this when using our website.
Sometimes, Turu needs to collect personal information about individuals who are not customers. This will usually arise where we collect the name and business contact details of a person who is the contact in a government agency or company with whom we deal. Turu's policy is to only use personal information collected from non-customers for the main business purpose for which it was collected.
Transborder data flows
Updating Personal Information
Turu endeavours to ensure that the personal information it holds is accurate, complete and up-to-date. Turu encourages you to contact it as soon as possible in order to update any personal information it holds about you. Turu's contact details are set out below.
Under the Privacy Act, you have the right to obtain access to any personal information which Turu holds about you and to advise Turu of any perceived inaccuracy. There are some limitations to this right set out in the Act, which mean that we can refuse to provide you access to that information in limited circumstances, including where granting you access might have an unreasonable impact on the privacy of other individuals, if the request is frivolous or vexatious; and if the information relates to anticipated legal proceedings.
To make a request to access any personal information Turu holds about you, please contact Turu in writing as set out below. Turu will require you to verify your identity and specify what personal information you require. Turu may charge a fee to cover the cost of verifying your application and locating, retrieving, reviewing and copying any material requested. If the personal information sought is extensive, Turu will advise of the likely cost in advance and can help to refine your request if required.
How to contact Turu
If you would like to make an access request or wish to provide feedback about this policy, please contact Turu by writing to Turu’s Privacy Officer at the address specified above, or via e-mail to firstname.lastname@example.org.
Last updated: 28 December 2012.