Privacy Policy

1. General

This Privacy Policy explains how Kode Entertainment Group Pty Ltd (ACN 140 154 730) and its subsidiaries and related bodies handle and protect your personal information. It also explains how you may request to access and correct your personal information, how to make a privacy complaint and how we will handle complaints. We recommend that you review this policy regularly as we may amend it from time to time to meet our legal obligations, reflect our current practices and ensure we are transparent about our information management.

Kode Group, its websites and apps operate from Australia and this policy provides information in accordance with our obligations under the Privacy Act.

By providing personal information to Kode Group, either directly or allowing another person to do so on your behalf, you acknowledge that this Policy will apply to how we handle your personal information.

If you do not wish your personal information to be handled in accordance with this Policy, we recommend that you do not provide your personal information to us. If you do not provide us with all the personal information we request, or if you do not provide any consent we require to be authorised to collect and handle certain personal information, this may affect our ability to provide services to you or respond to your inquiry, request or complaint.

2. What Personal Information do we collect and how?
We collect personal information from you in order to:

  • provide you with services in the travel industry and such other services as we may offer from time to time;

  • better understand your requirements and preferences; and/or

  • provide details to third parties for whom we make bookings on your behalf, including, but not limited to, airlines, hotels, venues and tour operators around the world.

For example, we collect personal information from you in order to provide you with services. Without these details we may not be able to carry on our business and provide our services to you.

We may collect your personal information from you in a number of places, including when you visit the registration website or the program website, when you call, email or otherwise contact us.

We may collect information directly from you. However, in certain circumstances we may collect personal information from third parties, such as Rinnai Australia Pty Ltd, and third party suppliers and who assist us to operate our business, or where we obtain information from other publicly available sources such as government websites. We may also collect your personal information from someone duly authorised to act on your behalf or law enforcement agencies and other government entities. Your personal information will ordinarily only be collected from third parties if it unreasonable or impractical to collect that personal information from you directly.

3. For what purposes do we collect your personal information?
We collect your personal information for the following purposes in relation to providing you with our event and travel services, advice and to assist you with booking travel and travel related products and services:

  • Complete your travel bookings

  • Provide you with travel products, services and advice

  • Consider your request for a product or service

  • Assist in arrangements and reservations with suppliers (such as airlines, tour operators, car hire operators, hotels and insurance providers) in relation to the provision of a product or service

  • Collect and process payments, through us or a third party

  • Facilitate your participation in loyalty programs

  • For quality assurance and other purposes and so that we can censor, edit, remove or prohibit the transmission or receipt of any information communicated through our systems that we deem inappropriate or in violation of our terms and conditions

  • Complete a travel profile about you

  • Enable you to, participate in a survey, competition or promotion

  • Process a transaction through our website, over the phone, through a mobile application or a franchised agent;

  • Analyse how our products and services (including any websites) are used and understand the effectiveness of our communications

  • Personalise the service or communication we provide to you, tailor your experience on our website or other websites to your interests and make more appropriate travel recommendations

  • Investigate, detect and protect us and other third parties against, negligence, breach of contract, fraud, theft and other illegal activities; and

  • Respond to and manage inquiries, complaints, feedback and claims

4. When do we disclose your personal information? 
Kode Group is committed to protecting your personal information and will not collect, hold, use or disclose it other than for the main reason for which you have voluntarily provided and if necessary for the purpose of conducting business. For example:

  • booking any travel related to a Rinnai Australia program

  • a purpose which is related to the services we provide to you and for which you would reasonably expect us to use the information;

  • where we reasonably believe that the use or disclosure is necessary to lessen or prevent serious and imminent threat to an individual’s health or safety or the public’s health or safety;

  • a purpose required, authorised or permitted by law;

  • a purpose made known to you and to which you have consented;

When you visit the registration site, we require your contact information and travel details. Any information that you enter onto an online form (for example, contact details) will only be collected by us if you submit this online form. If you cancel the online form or log out prior to submitting your form, any information which you had entered is automatically deleted.

5. How we may disclose your personal information
Kode Group may disclose your personal information to Rinnai Australia Pty Ltd, Centium Software Registration, Cover More Insurance, Stripe Online Credit Card Processing, airlines, hotels, venues and tour operators and/or services we are providing to you, including:

  • our professional advisors, including lawyers, accountants, tax advisors and auditors;

  • travel service providers;

  • Cash Card, Credit Card, Debit Card, E-Commerce suppliers.

  • law enforcement bodies to assist in their functions, courts of law or as otherwise required or authorised by law; and

  • regulatory or government bodies for the purposes of resolving customer complaints or investigations and any other regulatory obligations.

We may be required to disclose your personal information overseas, where the services we provide you are related to overseas travel. Your personal information may also be disclosed to other third parties overseas who provide us with insurance, IT, communications and other services.

The countries where these third parties are located may not have data protection laws similar to Australia. In such a case, we will endeavour to take such steps that are reasonable in circumstances to ensure that the information disclosed and used by such parties are bound by confidentiality obligations

6. Website & Cookies

(a) We may collect information when you access and use our program websites and registration sites by utilising features and technologies of your internet browser, including cookies, beacons, tags, scripts and similar technologies. A cookie is a piece of data that enables us to track and target your preferences.

(b) The type of information we collect may include statistical information, details of your operating system, location, your internet protocol (IP) address, the date and time of your visit, the pages you have accessed, the links which you have clicked and the type of browser that you were using.

(c) We may use cookies, beacons, tags, scripts and similar technologies to:

(i) enable us to identify you as a return user and personalise and enhance your experience and use of our Site; and

(ii) help us improve our service to you when you access our Site and to ensure that our Site remain easy to use and navigate.

(d) Most browsers are initially set up to accept cookies. However, you can reset your browser to refuse all cookies or warn you before accepting cookies.

(e) If you reject our cookies or similar technologies, you may still use the Site but may only have limited functionality of the Site.

(f) We may also use your IP address to analyse trends, administer the Site and other websites we operate, track traffic patterns and gather demographic information.

(g) Your IP address and other personal information may be used for credit fraud protection and risk reduction.

7. Storage and Security of Personal Information 

(a) Kode takes reasonable steps in the circumstances to keep your personal information safe. We use a combination of technical, administrative, and physical controls to protect and maintain the security of your personal information. We also use SSL (Secure Socket Layer) encryption when transmitting payment information.

(b) Our officers, employees, agents and third-party contractors are expected to observe the confidentiality of your personal information.

(c)  Wherever possible, we procure that Authorised Affiliates who have access to your personal information take reasonable steps to:

(i) protect and maintain the security of your personal information; and

(ii) comply with the relevant APPs when accessing and using your personal information.

 
8. Accessing and Updating your Personal Information 

You may ask Kode for access to any personal information we hold about you, subject to some exceptions in the Privacy Act. You can also ask us to correct personal information Kode Group holds about you. You can contact Kode Group using the details below to request access to or correction of the personal information we hold about you.

We may seek further information from you to verify your identity and/or clarify details of any request made. We will endeavour to respond to your request as soon practicable.

We may refuse you access to personal information we hold about you where required by law. If we refuse, we will give you written notice setting out the reasons for refusal (unless unreasonable for us to do so) and measures you can take to complain about the refusal.

9. Direct Marketing and your Privacy

We may use your personal information to send you information, including about our product and service offerings, where you have provided your consent (expressly or impliedly) for us to do so or we are permitted to do so by law.

We may send this information to you via the communication channels specified at the time you provide your consent. These communication channels may include mail, email, SMS telephone, social media or by customising online content and displaying advertising on our Site.

You can opt-out of receiving direct marketing communications from us, including communications from us on behalf of our business partners at any time by using the unsubscribe facility in the electronic communication you receive.

10. Privacy Complaints

(a) If you have any issues about this policy or the way we handle your personal information, please contact us using the details below and provide full details of your complaint and any supporting documentation.

(b)       At all times, privacy complaints:

(i)         will be treated seriously;

(ii)        will be dealt with promptly;

(iii)       will be dealt with in a confidential manner; and

(iv)      will not affect your existing obligations or your commercial arrangements with us.

(c)       Our Privacy Officer will endeavour to:

(i)         respond to you within 10 business days; and

(ii)        investigate and attempt to resolve your concerns within 30 business days or any longer period necessary and notified to you by our Privacy Officer. If you wish to complain about our handling of your personal information, please contact our Compliance Manager using the details below.

If your complaint is not satisfactorily resolved, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC). For more information on privacy, you can contact the OAIC’s hotline service on 1300 363 992 or visit the OAIC’s website at www.oaic.gov.au.

11. Changes to the Privacy Policy

We may make changes to this Privacy Policy from time to time for any reason whatsoever. We will publish any changes on this website. Where material changes are made to the Privacy Policy, we will provide you with reasonable notice before the changes take effect. By continuing to use our website or by continuing to provide us with your information after the changes take effect, you confirm your acceptance of these changes.

Contact Details 
Kode Group
hello@kodegroup.com.au
03 9008 4616
Po Box 113, South Yarra VIC 3141