Privacy Policy

Welcome to Country Ltd ABN 58 636 110 846 (“Welcome to Country, we, our or us”) owns and operates the Welcome to Country website (www.welcometocountry.com) (the “Website”) and the Welcome to Country social media pages, mobile applications, programs (collectively, the “Marketplace”). We are committed to respecting your privacy in your interactions with the Marketplace and collection of your personal information.

Please ensure that you read this Privacy Policy (“Privacy Policy”) carefully as it applies to all personal information collected by us in relation to your interaction with the Marketplace.

Certain terms in this Privacy Policy start with capital letters. Unless the context provides otherwise, those words have the meaning given to them in the body of this Privacy Policy.

1. Acceptance of this Privacy Policy

1.1 The Marketplace is an online marketplace that connects customers with Aboriginal and Torres Strait Islander tours, events and cultural experiences across Australia. Welcome to Country supports existing and aspiring Aboriginal and Torres Strait Islander entrepreneurs to run successful and sustainable tourism businesses.

1.2 By accessing and/or using the Marketplace, you indicate your acceptance to be bound by this Privacy Policy and the Marketplace Terms and Conditions (“Terms”) (see the Marketplace for more details) and agree that you have had sufficient opportunity to read and understand them.

1.3 By providing personal information to us, you consent to our collection, use and disclosure of your personal information in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you should immediately cease using the Marketplace.

1.4 We may update this Privacy Policy from time to time by publishing changes to it on the Marketplace. It is recommended that you check the Marketplace periodically to ensure that you are aware of our current Privacy Policy.

1.5 For the purposes of this Privacy Policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable. For example, this may include your name, age, date of birth, gender, contact details and postcode. It may also include financial information, including your credit card information, or a photograph of you. Personal information does not include anonymous, aggregated or de-identified information or information about companies which does not identify individuals.

2. Personal information we collect

2.1 Welcome to Country, and our third party service providers, may collect personal information from you when you access the Marketplace, including:

• Your name, address, email, mobile and telephone number, date of birth;
• History records of your communications and interaction with us and the Marketplace;
• Information relating to you that you provide to us directly or indirectly through your contact with us or your use of the Marketplace;
• Details or history of preference, interests and behaviour in relation to communications, interactions, services and activities on the Marketplace;
• Your IP address, web log and related domain, browser, computer and connection information, time zone, device ID, device type, geo-location information, and some of the cookies that are installed on your device;
• Statistics on your page views of the Marketplace and how you interact with the Marketplace, the sites you were visiting before you came to the Marketplace and the search terms that referred you to the Marketplace, traffic to and from and within the Marketplace, and ad data.

3. How we collect personal information

3.1 We, or our third-party service providers, may collect personal information from you in a variety of ways including:

• Directly from you, including when you:Browse or interact with the Marketplace, including through cookies;
  • Contact us e.g. with an enquiry or to provide feedback;
  • Interact with the Marketplace e.g. click on the Marketplace banners, hyperlinks or plugins;
  • Interact with any third-party content or hyperlinks on the Marketplace;
  • Interact with us via postal, phone, email, electronic, mobile application or social media correspondence;
  • Complete forms, surveys, questionnaires or other marketing or promotional activities for us;
  • Request information from us or have a conversation with our staff;
  • Are online. See more information in clause 8
• From third parties such as our experience operators or third-party service providers; and
• From publicly available sources of information.

4. How we use personal information

4.1 We collect and use personal information in order to deliver the Marketplace, our services (and those of our experience operators or third-party service providers as identified on the Marketplace) and to otherwise conduct the functions and activities of Welcome to Country.

4.2 We may use your personal information for different purposes, including:

• to provide or connect you to our experience operators or third-party service providers’ products and services;
• to communicate with you, including about the Marketplace, our products and services and those of our experience
• operators or third-party service providers, and information which might interest you;
• to answer your requests, questions and complaints, and provide you with information;
• to enable your access, interaction and use of the Marketplace;
• to gain an understanding of your information to develop, operate or improve the Marketplace or our services;
• to improve your experience and interaction with us, the experience operators, or the Marketplace, including performing analytics, conducting research and for marketing and advertising;
• to provide you with better customer services;
• to carry out administration, marketing, planning, fraud and loss prevention activities, procurement, development, quality control and research to improve the way the Marketplace, we and our third-party service providers provide products and services to you;
• to administer forms, surveys, questionnaires, and promote and market products, services or other promotional information, activities or events;
• to comply with laws and regulations or to comply with any directions given by regulators or authorities.

5. When we disclose personal information

5.1 We use third party service providers to deliver the functions and services of the Marketplace. For example, we use Shopify to power our online Marketplace. You can read more about how Shopify uses your personal information here: https://www.shopify.com/legal/privacy.

5.2 Our third-party service providers may need access to personal information in order to provide the services or perform the functions for the Welcome to Country Marketplace. We disclose your personal information with our third-party service providers where it will assist us, and our third-party service providers, to provide their products or services to the Marketplace or to you.

5.3 We may disclose your personal information with third-parties for other reasons, including:

• it will assist us to provide the products or services you have requested;
• it is a requirement of our experience operators or third-party service providers to provide their products or services to us or to you;
• it is necessary to manage or develop the Marketplace, our business, or our corporate strategies and functions;
• we wish to conduct market research and marketing strategy analysis;
• the use or disclosure is or otherwise required or permitted by laws, regulations or professional standards; or
• you have given your consent.

6. Who we disclose personal information to

6.1 We may disclose personal information for the purposes described in this Privacy Policy to:

• our employees, contractors, agents and related bodies corporate;
• our experience operators, related service providers, who provide information about their services on the Marketplace;
• third party suppliers and other service providers, including providers for the operation of the Marketplace or in connection with providing or marketing our products and services, and those of our experience operators and third-party service providers, to you;
• our partners and professional advisors;
• specific third parties authorised by you to receive information held about you by our third-party service providers;
• those agencies for which the disclosure is required by law.

6.2 The Marketplace is housed in Australia. However, we may disclose personal information outside of Australia, including to third party suppliers and third-party service providers located in places such as Canada and the United States, depending on the nature of the services those recipients provide to us (for example, storing data via a cloud service).

6.3 We will take all reasonable steps to ensure that any overseas recipient deals with your personal information in a way that is consistent with Australia’s privacy laws.

7. Direct marketing

7.1 You may elect to receive marketing materials from us by contacting us or using the opt-in facilities provided (e.g. by signing up via the Marketplace).

7.2 Where you have elected to receive marketing materials from us and/or our experience operators, third-party service providers or partners, we or they may use the personal information you have provided to send you direct marketing communications and information about the Marketplace, or our or their products or services. This may take the form of email, SMS, mail or other forms of communication, in accordance with the Spam Act 2003 (Cth) and Australian privacy laws.

7.3 If you decide that you no longer wish to receive marketing materials from us and/or our experience operators, third-party service providers or partners, you can do so using the opt-out facilities provided in the marketing materials. You acknowledge that it may take up to 7 days for this request to be processed.

8. Cookies Policy

8.1 We use cookies, awstats or similar technologies (“Cookies”) to analyse trends, administer the Marketplace, track users’ movements around the Marketplace and to gather demographic information about our user base as a whole.

8.2 You agree that we may store Cookies on your devices and issue and request Cookies from your device to collect both personal and non-personal information. You can control the use of Cookies at the individual browser level, but if you disable Cookies, it may limit your use of certain features or functions on the Marketplace.

8.3 We use Cookies for the following reasons, including without limitation to:

• link you to experience operators and experiences;
• record your interactions with the Marketplace, including what pages you access and how long you stay on the site;
• improve our performance by reporting any errors that occur;
• provide statistics about how the Marketplace is used;
• remember settings that you use for the Marketplace;
• identify and show that you are logged into the Marketplace;
• link to social networks like Facebook and Twitter;
• provide more suitable ads tailored to you.

8.4 We may partner with third parties to manage our advertising on the Marketplace and other sites. Our third-party partners may use technologies such as Cookies to gather information about your activities on the Marketplace in order to provide you advertising based on your browsing activities and interests.

9. Links

9.1 The Marketplace contain links to products and services, websites, applications and embedded content owned and operated by third-party service providers and other third parties that may not be governed by this Privacy Policy or Australian privacy laws.

9.2 We in no way endorse those linked sites or content and are in no way responsible for the privacy practices or policies of, or any content on, those sites.

9.3 We recommend you review the privacy policy of each third-party site you choose to link to from the Marketplace to determine their use of any data collected from you, especially if you intend to disclose any personal information via that site.

10. Security and Accuracy

10.1 Our third-party services providers who collect and hold your personal information will take precautions to protect your personal information in accordance with relevant privacy laws and standards.

10.2 Where a third-party service provider notifies us that there has been a security incident involving the unauthorised access, use or disclosure of personal information they hold, we will take reasonable steps and work cooperatively with the third-party service provider to protect the personal information we have disclosed to them.

10.3 We will take such steps (if any) as are reasonable in the circumstances to ensure personal information we collect, use or disclose is accurate, up-to-date and complete for the purpose for which it is collected, but make no warranties about the accuracy of personal information.

11. Access and corrections of personal information

11.1 You may ask us in writing to provide you with details of your personal information we have collected and which is held by our third-party services providers. We, or our third-party service providers, will provide you with this information where reasonable and practicable to do so, and in accordance with relevant privacy laws.

11.2 You may request correction to the personal information about you that is held by our third party service providers. We will take such steps as are reasonable in the circumstances to correct your personal information as requested to ensure it is accurate, up-to-date and complete.

11.3 If you are a European resident, you have the right to access personal information about you held by our third party service providers. You may also ask that your personal information be corrected, updated, or deleted.

12. Making a complaint about breach of privacy

12.1 If you wish to make a complaint about the way we have handled your personal information, you can contact us by using the details set out in the ‘Contact Us’ section below. Please include your name, email address and/or telephone number and clearly describe your complaint. We will ensure that complaints regarding alleged breaches of privacy are investigated swiftly.

12.2 If you would like further information about privacy and the protection of your personal information, or if you feel we have not resolved your complaint satisfactorily, you can contact the Office of the Australian Information Commissioner at oaic.gov.au.

13. Hotjar

13.1 We use Hotjar in order to better understand our users’ needs and to optimize this service and experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behaviour and their devices. This includes a device’s IP address (processed during your session and stored in a de-identified form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), and the preferred language used to display our website. Hotjar stores this information on our behalf in a pseudonymized user profile. Hotjar is contractually forbidden to sell any of the data collected on our behalf. For further details, please see the ‘about Hotjar’ section of Hotjar’s support site.

14. Contact Us

14.1 Please address all requests and questions about this Privacy Policy to:

Welcome to Country
Level 1/18 Bulletin Place
Sydney NSW 2000
info@welcometocountry.com.au

14.2 When contacting us you are entitled to remain anonymous or provide a pseudonym, however it may be impractical for us to deal with you on an anonymous basis or through a pseudonym (e.g. if your request or question relates to an experience booking through the Marketplace).