Introduction

TFT Holdings (1998) Ltd t/a World Travellers Riccarton (we, us, our), comply with the New Zealand Privacy Act 2020, and other applicable information, privacy and data protection laws, (for example, the General Data Protection Regulation 2016/679), when dealing with personal information. It applies to all personal information that we collect, process, or receive. This may be in person or via our website, email, social media, apps, over the phone, or through other channels. 

Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.  Personal information can include sensitive information such as (without limitation) religious beliefs, health information, ethnic origin, affiliations or associations.

TFT Holdings (1998) Ltd t/a World Travellers Riccarton needs 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 customers.  We are firmly 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.

This or any other applicable privacy and data protection laws, does not limit or exclude any of your rights under the New Zealand Privacy Act 2020. For further information on the New Zealand Privacy Act 2020, see www.privacy.org.nz, or your local information privacy and data protection laws.

This Policy was drafted with brevity and clarity in mind.  It does not provide exhaustive detail of all aspects of our collection and use of personal information.  We are happy to provide any additional information or explanation needed.  

What Personal Information Do We Collect?

Generally, the type of personal information we collect about you is the information that is needed to facilitate your travel arrangements and bookings and to arrange travel related services and/or products on your behalf.

We therefore typically process the following types of personal information about you:

  • contact information (such as name, residential/mailing address, telephone number, email address);
  • payment account information (credit/debit card details, including card type, card number, security number and expiry date);
  • passport details;
  • loyalty program / frequent flyer details;
  • health information such as 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).

We also collect online identifiers such as your IP address and data regarding your device and the network you are using to connect with us.

When you contact us for other purposes, we may also collect personal information about you in relation to those purposes. For example, we may collect your personal information so we can contact you about a competition you have entered (e.g. if you win) or to respond to an enquiry or feedback you have sent to us. We also collect information that is required for use in the business activities of World Travellers Ltd and our related entities, including for example, financial details necessary in order to process various transactions, audio, electronic and visual information (such as video surveillance footage) used for security purposes, voice recordings for quality control and dispute resolution, and relevant personal information you may elect to provide to us.

We will only collect sensitive personal information in compliance with your local data protection laws, with your express consent and where it is reasonably necessary for, or directly related to, one or more of our functions or activities (e.g. to make travel arrangements), unless we are otherwise required or authorised to do so by law. To the extent permitted or required under your local data protection laws, you consent to us using and disclosing your sensitive information for the purpose for which it was collected. 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. A further example is if you disclose your religious beliefs to us because you are interested in, for example, certain holiday packages, in which case you consent to us using and disclosing that information in connection with facilitating your request. We will not use or disclose sensitive information for purposes other than those for which it was collected, unless we subsequently receive your express consent to use it for another purpose.

How Do We Collect Personal Information?

We will only collect personal information in compliance with your local data protection laws. We usually collect your personal information from the information you submit during the course of your relationship with us. We will collect this information directly from you unless it is unreasonable or impracticable to do so.

Generally, this collection will occur:

  • when you deal with us either in person, by telephone, letter, or email;
  • when you visit any of our websites; 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 register for promotions;
  • when you subscribe to receive marketing from us (e.g. e-newsletters);
  • when you request brochures or other information from us; or
  • when you provide information, or use our services, on social media.

Unless you choose to do so under a pseudonym or anonymously, we may also collect your personal information (other than sensitive information) when you complete surveys or provide us with feedback. 

In some circumstances, it may be 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.

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 collect, 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 your 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.

We make every effort to maintain the accuracy and completeness of your personal information which we store and to ensure all of your personal information is up to date. However, you can assist us with this considerably by promptly contacting us if there are any changes to your personal information or if you become aware that we have inaccurate personal information relating to you. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal information that you, or a person acting on your behalf, provide to us.

Children

We collect personal information from or about children aged under 16 for the purposes of providing travel services. We rely on representations from customers that they have appropriate individual or parental consent for any children included in a booking with us.

 

How Do We Use Your Personal Information?

We will only process your information, where:

    • you have given your consent to such processing (which you may withdraw at any time);
    • the processing is necessary to provide our services to you;
    • the processing is necessary for compliance with our legal obligations; and/or
  • the processing is necessary for our legitimate interests or those of any third party recipients that receive your personal information.

     

We may use your personal information to:

  • verify your identity;

     

  • provide our websites, third party products and other services to you;

     

  • provide you with travel documentation;

     

  • market our third party products and our own services to you, including contacting you electronically (e.g. by text or email for this purpose);
  • publish things on our websites (e.g. comments on pages);

     

  • run promotions (e.g. referral and loyalty programmes, surveys and contests);

     

  • bill you and collect money that you owe us, including authorising and processing credit card transactions;

     

  • respond to communications from you, including enquiries and complaints;

     

  • tailor content or advertisements on our websites;

     

  • protect and/or enforce our legal rights and interests, including defending any claim;

     

  • respond to lawful requests by public authorities, including to comply with law enforcement requirements, or for any other purpose authorised by you or applicable law;
  • providing you with services and tools you choose to use (for example, saving travel preferences on our websites to a wishlist or saving personal information to allow for pre-population of online forms);
  • identification of fraud or error;    
  • developing and improving our products and services and those of our related entities;    
  • servicing our relationship with you by, among other things, creating and maintaining a customer profile to enable our brands to service you better or presenting options on our website we think may interest you based on your browsing and preferences;   
  • involving you in market research, gauging customer satisfaction and seeking feedback regarding our relationship with you and/or the service we have provided;    
  • for research and analysis in relation to our business and services, including but not limited to trends and preferences in sales and travel destinations and use of our websites;    
  • internal accounting and administration; and
  • to comply with our legal obligations and any applicable customs/immigration requirements relating to your travel.


We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.

Where permitted by local data protection laws, we may use your personal information to send you targeted marketing activities 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. These may include, but are not limited to, mail outs, electronic marketing and notifications as described below, and telephone calls. We will only use your personal information to send electronic marketing materials to you (including e-newsletters, email, SMS, MMS and iM) if you have opted-in to receive them or not opted out of receiving them, depending upon the applicable law. You can subscribe to receive e-newsletters and other electronic promotional/marketing materials by following the relevant links on our website or requesting one of our consultants to do so for you.

Should you no longer wish to receive promotional/marketing material from us, participate in market research or receive other types of communication from us, you can unsubscribe at any time. Please also see the “Your rights” section of this Policy to learn about your ability, at any time, to opt out or limit the use of your browsing behaviour for online behavioural advertising purposes.

Is Personal Information Disclosed to Third Parties?

We do not and will not sell, rent out or trade your personal information. We will only disclose your personal information to third parties in the ways set out in this Policy and, in particular, as set out below, and in accordance with your local data protection laws. Note that, in this Policy, where we say “disclose”, this includes to transfer, share (including verbally and in writing), send, or otherwise make available or accessible your personal information to another person or entity.

Your personal information may be disclosed to the following types of third parties:

  • our contractors, suppliers and service providers, including without limitation:
    • in each of the circumstances set out under the heading “How do we use your personal information?”;
    • suppliers of IT based solutions that assist us in providing products and services to you (such as any external data hosting providers we may use);
    • publishers, printers and distributors of marketing material;
    • event and expo organisers;
    • marketing, market research, research and analysis and communications agencies;
    • mailing houses, freight services, courier services; and
    • external business advisers (such as lawyers, accountants, auditors and recruitment consultants);
  • our related entities and brands;
  • travel service providers such as travel wholesalers, tour operators, airlines, hotels, car rental companies, transfer handlers and other related service providers;
  • any third party to whom we assign or novate any of our rights or obligations;
  • financial institutions such as banks, when processing financial transactions;
  • a credit reference agency for the purposes of credit checking you;
  • 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, the person correctly answers our required security questions and the request is, in our opinion, in your interest (for example, where the person is concerned for your welfare or needs to undertake action on your behalf due to unforeseen circumstances);
  • any other person with your consent;
  • as required or authorised by applicable law, and to comply with our legal obligations;
  • customs and immigration 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 authorised request, including a court order or other valid legal process;
  • various regulatory bodies and law enforcement officials and agencies, including to protect against fraud and for related security purposes; and
  • 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.

When you engage us to book flights on your behalf, we will provide your personal information (i.e. name, email address and/or mobile number) to the relevant airline. This enables airlines to advise passengers of irregular flight operations and disruptions (e.g. flight cancellations, schedule changes) directly.

Other than the above, we will not disclose your personal information without your consent unless we reasonably believe that disclosure is necessary to lessen or prevent a threat to life, health or safety of an individual or to public health or safety or for certain action to be undertaken by an enforcement body (e.g. prevention, detection, investigation, prosecution or punishment of criminal offences), or where such disclosure is authorised or required by law (including applicable privacy / data protection laws).

On our websites, you may choose to use certain features that can be accessed through, or for which we partner with, other entities that are not otherwise affiliated with us. These features, which include social networking and geo-location tools, are operated by third parties, including social networks, and are clearly identified as such. These third parties may use or share personal information in accordance with their own privacy policies. We strongly suggest you review the third parties’ privacy policies if you use the relevant features.  

A business that supports our websites, products and services or delivers services that we sell as agent may be located outside of New Zealand (the country where we are incorporated) and also outside of the country where you are located.  This means that the personal information we collect may be transferred to, and stored in, a country outside of New Zealand and the country where you are located. World Travellers Ltd acts as a travel agent on behalf of travel services suppliers. Relevant personal information that we collect at the time of booking/quote will need to be provided to those travel service suppliers (for example, airlines) and other supporting entities (for example, reservation systems) in order to facilitate and process your booking/quote. Where travel service suppliers or other supporting entities that process your booking/quote are located outside of New Zealand, we cannot guarantee that your personal information will be protected to the same standards as apply in New Zealand. By proceeding with your booking/quote, you acknowledge and consent to this.

Is Personal Information Transferred Overseas?

We may disclose your personal information to certain overseas recipients, as set out below. We will ensure that any such international transfers are either necessary for the performance of a contract between you and the overseas recipient or are made subject to appropriate or suitable safeguards.

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.

We use many different service providers all over the world, so it is not possible for us to set out in this policy all of the different countries to which we may send your personal information. However, if you have any specific questions about where or to whom your personal information will be sent, please do not hesitate to contact us.

Also, we may share information about your use of our websites with our trusted advertising and analytics partners through the use of cookies, web beacons, and similar storage technologies.  Please refer to our cookie policy below for further information.

Protecting Your Personal Information

As required by applicable law, we will take steps to keep your personal information safe from loss, unauthorised activity, or other misuse.  We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information.

You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services.  You should not disclose your password to third parties.  Please notify us immediately if there is any unauthorised use of your account or any other breach of security.

Accessing and Correcting Your Personal Information

Subject to certain grounds for refusal under applicable law, you have the right to access your personal information that we hold and to request a correction to your personal information.  Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.

Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal information, we will make the correction.  In all other cases, we will take reasonable steps to make a note of the personal information that was the subject of your correction request.

If you want to exercise either of the above rights, email your World Travellers Agent.  Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).

Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information. 

Social Media Integrations

Our websites and mobile applications may use social media features and widgets (such as “Like” and “Share” buttons/widgets) (“SM Features”). These are provided and operated by third party companies (e.g. Facebook) and either hosted by a third party or hosted directly on our website or mobile application. SM Features may collect information such as the page you are visiting on our website/mobile application, your IP address, and may set cookies to enable the SM Feature to function properly.

If you are logged into your account with the third party company, then the third party may be able to link information about your visit to and use of our website or mobile application to your social media account with them. Similarly, your interactions with the SM Features may be recorded by the third party. In addition, the third party company may send us information in line with their policies, such as your name, profile picture, gender, friend lists and any other information you have chosen to make available, and we may share information with the third party company for the purposes of serving targeted marketing to you via the third party social media platform. You can manage the sharing of information and opt out from targeted marketing via your privacy settings for the third party social media platform.

Your interactions with these SM Features are governed by the privacy policy of the third party company providing them. For more information about the data practices of these third party companies, and to find out more about what personal information is collected about you and how the third party uses such personal information, please refer to their privacy policy directly.

IP Addresses

When you access our website, use any of our mobile applications or open electronic correspondence or communications from us, our servers may record data regarding your device and the network you are using to connect with us, including your IP address. An IP address is a series of numbers which identify your computer, and which are generally assigned when you access the internet.  

We may use IP addresses for system administration, investigation of security issues and compiling anonymised data regarding usage of our website and/or mobile applications. We may also link IP addresses to other personal information we hold about you and use it for the purposes described above (e.g. to better tailor our marketing and advertising materials, provided you have opted in to receive electronic marketing). 

Internet Use

While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.

If you follow a link on our websites to another website, the owner of that website will have its own privacy policy relating to your personal information.  We suggest you review that website’s privacy policy before you provide personal information to that owner or website.

Data Retention Policy

The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer. 

LAWFUL BASIS FOR PROCESSING PERSONAL INFORMATION

Our lawful basis for processing your personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it. 

Generally, we collect personal information from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms). 

Where we process personal information based on your consent, you may withdraw your consent at any time. 

Our lawful basis for processing your sensitive information is your consent.

Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws.

If you have any question about the legal basis on which we process personal information or need further information, please contact us.

Your Rights

Your rights in relation to your personal information include:

  • right of access – if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information.
  • right to rectification – if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible.
  • right to erasure – when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information.
  • right to withdraw consent – if the basis of our processing of your personal information is consent, you can withdraw that consent at any time.
  • right to restrict processing – you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible.
  • right to object to processing – you may request that we stop processing your personal information at any time and we will do so to the extent required by applicable law.
  • rights related to automated decision-making, including profiling – you have the right to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except where such automated decision-making is necessary for entering into, or the performance of, a contract with you, is authorised by applicable laws or is based on your explicit consent. We do not undertake automated individual decision-making.
  • right to data portability – you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller.
  • the right to complain to a supervisory authority – you can report any concern you have about our privacy practices to your local data protection authority.


Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.

If you would like to exercise any of your above rights, please contact us.  If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.

COOKIE POLICY

Introduction

We use cookies on our websites and as part of our related services, and receive information collected through cookies.  This cookie policy explains how we use cookies and how you can opt out of cookies. 

By continuing to use our websites and related services, you indicate your agreement for us to use the cookies described below.

We use the term cookies in this cookie policy to mean cookies or similar technologies such as web beacons, clear GIFs, and pixel tags.

What Are Cookies

Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website.  Cookies can be recognised by the website that downloaded them, or by other websites that use the same cookies.  This helps a website know if the browsing device has visited that or other websites before. 

Cookies can be used to collect information relating to your use of a website or your device, let you navigate between pages effectively, help to remember your preferences and generally improve your browsing experience.  Cookies can also help ensure advertising you see online is more relevant to you and your interests.

Cookies can be session or persistent cookies.  Session cookies are temporary and only stay on your browser until you stop browsing.  Persistent cookies stay on your device until they expire or are deleted.

The cookies used on our website may be first party cookies (i.e. set by us) or third party cookies (i.e. cookies set on our website by a person other than us).  The third party companies that place cookies on our website will have their own privacy policies.

Feedback / Complaints / Subject Access Requests / Contact

You can direct any questions or complaints about the use or disclosure of your personal information to [email protected]

If you wish to make a Subject Access Request to inform us of a change or correction to your personal information, request a copy of the information we collect on you, request deletion of your information or would like to restrict the further processing of your data, please contact your World Travellers Agent.

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. We will post a prominent notice on our website to notify you of any significant changes to our Policy and indicate at the end of the Policy when it was most recently updated. 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.

This Privacy Policy was last updated on 9th September 2021.