Privacy Policy

TRAVEL SPARK PTY LTD – PRIVACY POLICY

Effective Date: 15 February 2025

1. Introduction

Travel Spark Pty Ltd (“Travel Spark,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website, [Insert Website Address] (the “Website”), and contact us for consulting services. We comply with the Australian Privacy Principles (APPs) as outlined in the Privacy Act 1988 (Cth). While we are primarily a consulting company and not a data processor in the traditional travel agency sense, we respect data privacy principles globally and aim to responsibly handle any personal information we collect.

2. Scope

This Privacy Policy applies to all personal information collected by Travel Spark, including through our Website’s contact forms, direct email communications, telephone conversations, and other interactions with prospective and current clients. This policy applies to all clients worldwide.

3. Information We Collect

We collect the following types of information:

  • Personal Information You Provide Directly:
    • Contact Information: Name, email address, postal address, phone number, company name, job title.
    • Information Provided in Inquiries: Details about your consulting needs, business goals, challenges, and other information you voluntarily provide when contacting us via our website contact form, email, or phone.
    • Client Relationship Management (CRM) Data: Notes from meetings and correspondence, service preferences, and project-related information if you become a client.
    • Billing Information: Payment details necessary for invoicing and payment processing (e.g., bank account details), only if you become a client. Please note that Travel Spark does not process Credit Card information on its website. Credit card information is collected offline via a secure process.
    • Marketing Preferences: Your preferences for receiving marketing communications (e.g. opting into a newsletter).
  • Information Collected Automatically (Limited):
    • Log Data: IP address, browser type, operating system, referring website, pages visited, date/time stamps (primarily for website security and basic usage analysis).
    • Cookies and Similar Technologies (Limited): We use essential cookies for the functioning of our website. We may also use cookies for basic analytics. (See Section 7 for details).

4. How We Use Your Information

We use your information for the following purposes:

  • Responding to Inquiries and Providing Information:
    • Answering your questions about our consulting services.
    • Providing you with quotes and proposals.
  • Client Relationship Management:
    • Managing our client relationships and providing consulting services.
    • Communicating with you about projects and services.
    • Invoicing and processing payments (for clients only).
  • Marketing (with Consent):
    • Sending you marketing communications (e.g., newsletters, updates) if you have opted in to receive them.
    • Analysing the effectiveness of our marketing efforts.
  • Website Improvement and Security:
    • Analysing website usage patterns to improve our website’s functionality.
    • Maintaining the security and integrity of our Website.
  • Legal and Compliance:
    • Complying with applicable laws and regulations.
    • Protecting our rights and interests.
    • Resolving disputes.

5. Disclosure of Your Information

We may disclose your information to the following categories of recipients:

  • IT Service Providers: Companies that provide us with IT support, data storage, and website hosting services.
  • Accounting and Legal Professionals: To assist with financial and legal compliance.
  • Payment Processors: Third-party payment processors who handle your payment information securely (for clients only). (We use [List Payment Gateway names used, e.g., Stripe, PayPal]).
  • Marketing Service Providers: Companies that assist us with our marketing efforts (e.g., email marketing platforms, social media management tools). These companies will only be able to send messages to those who opt into receiving marketing material.
  • Legal and Regulatory Authorities: Government agencies, law enforcement authorities, and courts, as required by law.
  • In the event of a merger, acquisition, or sale of all or a portion of our assets: Your information may be transferred to the acquiring entity.

We will only disclose your personal information to third parties who have appropriate data protection safeguards in place and who are contractually obligated to use your information only for the purposes we have specified. If we disclose your information to a third party located outside of Australia, we will take reasonable steps to ensure that the recipient handles your information in accordance with the APPs or similar data protection laws.

6. Cross-Border Data Transfers

Your personal information may be transferred to and stored in countries outside of Australia, including the United States, if our IT service providers or marketing platforms are located in those countries. These countries may have data protection laws that are different from those in Australia. We will take reasonable steps to ensure that your information is protected in accordance with the APPs or similar data protection laws when it is transferred to another country. This includes, but is not limited to, using standard contractual clauses approved by the European Commission or relying on the recipient’s Binding Corporate Rules (BCRs) where applicable.

7. Cookies and Similar Technologies

We use cookies and similar technologies to collect information about your browsing activity on our Website. Cookies are small text files that are stored on your device. They help us to:

  • Essential Cookies: Allow you to browse the Website and use its features, such as the contact form.
  • Analytics Cookies (Optional): Collect information about how you use the Website, such as which pages you visit and how long you stay on each page. We use this information to improve our website. These cookies are only activated if you consent to them.

You can control cookies through your browser settings. You can choose to block all cookies, or only certain types of cookies. Please note that blocking essential cookies may affect your ability to use certain features of our Website.

  • Cookie Consent: Our website utilises a cookie banner to obtain your consent for the use of non-essential cookies. You have the right to withdraw your consent at any time.

8. Data Security

We take reasonable steps to protect your information from unauthorised access, use, disclosure, alteration, or destruction. These steps include:

  • Using encryption to protect sensitive information transmitted online.
  • Storing your information on secure servers.
  • Implementing access controls to restrict access to your information.
  • Regularly monitoring our systems for security vulnerabilities.
  • Training our employees on data security best practices.
  • Using firewalls and intrusion detection systems.

However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, we cannot guarantee the absolute security of your information.

9. Data Retention

We will retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When we no longer need your personal information, we will securely delete or anonymise it.

Specifically, we retain:

  • Inquiry data: For [Number] months, unless you become a client.
  • Client data: For [Number] years after the termination of our consulting engagement, to comply with legal and accounting requirements.
  • Marketing data: Until you unsubscribe from our marketing communications.
  • Log data: For [Number] months for security and analytics purposes.

10. Your Rights

You have the following rights regarding your personal information:

  • Access: You have the right to request access to the personal information we hold about you.
  • Correction: You have the right to request that we correct any inaccurate or incomplete personal information we hold about you.
  • Erasure: You have the right to request that we erase your personal information, subject to certain exceptions.
  • Restriction of Processing: You have the right to request that we restrict the processing of your personal information, subject to certain exceptions.
  • Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format, and to transmit that information to another controller (where technically feasible).
  • Objection: You have the right to object to the processing of your personal information for certain purposes, such as direct marketing.
  • Withdrawal of Consent: If we are processing your personal information based on your consent, you have the right to withdraw your consent at any time.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that we have violated your privacy rights. In Australia, this is the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au.

To exercise any of these rights, please contact us using the contact information provided in Section 13. We may require you to verify your identity before processing your request.

11. Children’s Privacy

Our Website is not directed to children under the age of 16. We do not knowingly collect personal information from children under 16. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately.

12. Links to Other Websites

Our Website may contain links to other websites that are not owned or controlled by us. We are not responsible for the privacy practices of these websites. We encourage you to review the privacy policies of any websites you visit.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us:

Travel Spark Pty Ltd
Email: hello@travelspark.com.au

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post any changes on our Website and update the “Effective Date” at the top of this policy. We encourage you to review this Privacy Policy periodically. If we make significant changes, we will provide you with more prominent notice (e.g., via email).

15. Australian Privacy Principles Compliance

We adhere to the 13 Australian Privacy Principles (APPs) in our handling of personal information. Further information about the APPs can be found on the website of the Office of the Australian Information Commissioner (OAIC): www.oaic.gov.au.

16. GDPR and CCPA/CPRA Compliance (Where Applicable)

While we primarily operate as a consulting company, we acknowledge the principles of GDPR and CCPA/CPRA and strive to respect the data privacy rights of individuals globally.

  • GDPR: If you are located in the European Economic Area (EEA) or the United Kingdom (UK), you have rights under the GDPR as outlined above. We process your personal data based on your consent (for marketing), the need to perform a contract with you (if you are a client), our legitimate interests (responding to inquiries and managing our business), or a legal obligation.

• • CCPA/CPRA: If you are a California resident, you have rights under the CCPA/CPRA, including the right to know what personal information we collect about you, the right to delete your personal information, and the right to non-discrimination for exercising your CCPA/CPRA rights. Travel Spark does not sell personal information.

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