Our commitment to Privacy
Australian Tourist Park Management ACN 061 270 513 (ATPM) is a member of the the National Roads and Motorists’ Association Limited (ACN 000 010 506) (NRMA)* group of companies.
ATPM is committed to treating the privacy of our customers with utmost importance
A reference in this document to ATPM includes when ATPM handles personal information as an agent of any business that it operates or manages.
The types Personal Information we collect
The personal information that ATPM collects may include an individual’s:
- Date of Birth and gender;
- Driver’s license number and/or passport number and, upon our request, a copy of your driver’s license or passport;
- Residential tenancy particulars.
- Email addresses / IP addresses;
- Telephone numbers;
- Date of birth;
- Vehicle details including registrations and vehicle make and model;
- Payment information (such as credit card, PayPal or bank details);
- Financial and transaction details associated with bookings, products and services;
- Special needs or preferences;
- Information concerning previous interactions with ATPM, parks managed by ATPM and business partners;
- Your social media preferences;
- Any benefits you obtain from your Motoring Club Membership (including NRMA, RACQ and RACWA) any of the above information in respect of additional cardholders or your family members; and
- Any preferences you tell us about or other information that you provide.
In addition, ATPM may collect sensitive information by consent to assist with providing services to cater to special needs.
Please see the Direct Marketing section of this policy for more examples of the kinds of personal information we collect.
Why we collect Personal Information
The primary use for obtaining personal information is to effectively administer records, accounts and financial transactions, to assist our internal administration and operations including accounting, risk management, record keeping, archiving, systems development and testing, and staff training, to provide for administration and operations, verify and manage Motoring Club membership particulars and subscriptions (for example, with the NRMA), arrange bookings and accommodation, establish residential tenancy agreements, book tours and other services on a customer’s behalf, to improve services to meet customer preferences, provide opportunity for future sales and marketing and provide other goods, and services in connection with ATPM business or undertaking. Some personal information obtained is required by law such as properly identifying parties to a contract and to establish binding agreements such as a residential tenancy agreement.
The information obtained provides a means for ATPM to contact customers, provide tourism information and assist in managing risks associated with staying at a Park including responding to emergencies, responding public safety threats or where there is a serious threat to health, life or safety. Personal information also assists in understanding the demographics of existing and future customers and providing appropriate facilities to meet customer needs and to offer marketing material to customers to provide information on goods and services offered. In addition, such information may be used by ATPM enterprises, business partners and associates for the above-mentioned purposes associated with ATPM’s business and undertaking or disclosed to other persons or organisations if it is reasonably expected by the individual.
How we collect personal information
Generally, we collect personal information directly from you, such as when you apply for Membership or request a product or service, in the course of providing you with that product or service (e.g. Roadside Assistance), or when you have other dealings with us.
We may collect and update that information over the phone, at roadside, over the Internet, in person (when you visit us at an ATPM managed Holiday Park or NRMA office), when you write to us or if you participate in our marketing campaigns. We may also collect personal information through third parties such as:
- Our related companies;
- Affiliated interstate motorists’ clubs;
- Insurance Australia Limited* (trading as NRMA Insurance) and its related entities;
- Our third party service providers and business partners;
- Data washing organisations and postal service providers, including Australia Post.
We may use and disclose the personal information we collect for the purpose of providing you with tailored marketing communications about our goods and services, or to conduct market research. Typically, we send these communications to your email address or mailing address.
When we disclose personal information
As ATPM is concerned with maintaining the privacy of personal information, such information will not be disclosed to third parties that are not directly involved or associated with ATPM’s business or undertaking unless:
- an emergency exists where disclosure of such information will assist in the response; and
- a law enforcement agency or person duly authorised by law requests the disclosure of such information for bona fide reasons.
Personal information such as basic contact details sourced from the ATPM subscription base, memberships and accommodation records may be provided to other ATPM and related entities, business partners and associates for bona fide purposes associated with ATPM’s business and undertaking. This includes the opportunity to provide information concerning products and services offered by ATPM and other entities including companies in the NRMA Group, to our other business partners, our service providers and Insurance Australia Limited* (trading as NRMA Insurance) .
We may disclose your personal information where we are required or authorised by law to disclose your personal information or for any purposes connected to a fraud, crime prevention or impropriety investigation.
Personal information may be used for direct marketing purposes where, in absence of an objection, implied consent is assumed. ATPM will also provide options for a person to opt out of receiving marketing material.
In addition, ATPM may use information appropriately and lawfully sourced by a third party for direct marketing purposes if the information is not sensitive information and:
a) it is impracticable for ATPM to seek your consent before that particular use;
b) you have not made a request to ATPM not to receive direct marketing communications;
c) in each direct marketing communication with you, ATPM includes a prominent notice informing you how to opt out if you wish not to receive any further direct marketing communications.
We may collect information about your social media preferences and activities so that we can engage with our customers on social media sites. We may also collect certain demographic information and behavioural information from social media platforms to better serve consumers with more targeted advertising.
If we do not collect information in the ways described above, we may not be able to let you know about our products and services in the most effective way.
Opting out of direct marketing
If you do not wish to receive direct marketing information from ATPM, please use the contact details below to update your preferences, or use the unsubscribe feature on our electronic marketing communications.
Please note that if you make such a request, we may still need to use your personal information to provide you with the services and products you have requested as a customer or Motoring Club Member; and
It may not be possible for us to immediately action a request to cease receiving any or all direct marketing material. However, we will respond to such requests as soon as practicable and will make all reasonable efforts to promptly activate a change in preference or a opt-out of receiving future direct marketing material.
Protection of personal information
ATPM takes reasonable steps to ensure the personal information it holds is accurate and up-to-date, and is protected from misuse, interference and loss, and unauthorised access, modification or disclosure. All information stored electronically is protected by unique password and network protection with access limited to key positions held within ATPM. Physical records are kept in secure locations to prevent unauthorised access or disclosure. In addition, once records are no longer of use, personal particulars will be removed to de-identify any such records.
When the opportunity arises, ATPM will take steps to confirm or update the personal information and contact particulars to ensure currency is maintained as is practicable.
Website cookies and digital services
Information is also generated and collected whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance. Some parts of our websites also use “cookies”. A “cookie” is a small text file that is placed on your computer’s hard drive by a web page server. Cookies store information about the use of our website and are used to identify new or previous visitors to the website and what pages have been accessed. Most web browsers are set to accept cookies, but this function can usually be disabled if you wish. Please note that if you do disable this, not all functionality on our websites will be available to you.
Overseas disclosure of personal information
To provide location-based services on any of our iPhone or Android application, ATPM, its partners and licensees may collect, use, and share location data, including the real-time geographic location of your mobile device. This location data is used by ATPM, its related companies, its partners and licensees to provide and improve location-based features and services. The location data is collected anonymously in a form that does not personally identify you, however we may request you to provide personal information and link that information to your location data for the purpose of providing some of the location based features of our iPhone or Android application.
Openness, Access and Correction
ATPM will provide access to personal information held by us on you, according to our obligations under the Privacy Act. We may charge a fee for retrieving this information, in which case we will inform you of the fee in advance of providing the information. Prior to information being released, precautions will be taken to confirm the person’s identity by reference to information held and other unique information held. If your personal details change, such as your address or phone number, please contact us on ATPM Head Office on (07) 5607 1405 or firstname.lastname@example.org to update your details.
Making a complaint
If you wish to complain about our handling of your personal information, please send a written complaint to the Privacy Officer in the first instance by using the contact details below. We undertake to promptly acknowledge and investigate any complaint about the way we manage personal information. If you are dissatisfied with the outcome of our investigation, you may take your privacy complaint to the Office of the Australian Information Commissioner (OAIC). For information in making a complaint to the OAIC, please visit the OAIC’s website http://www.oaic.gov.au/privacy/privacy-complaints, or phone1300 363 992.
Any queries relating to this policy, enquiries about the personal information held, requests to update personal information, requests to be excluded from receiving marketing communications or complaints may be directed to the ATPM Head Office on (07) 5607 1405 or email@example.com.
*Insurance Australia Limited (trading as NRMA Insurance) and its related entities are separate and unrelated to National Roads and Motorists’ Association Limited.
[Last amended on 1 June 2017]