The Benson Hotel
PRIVACY POLICY
Our privacy commitment
Benson Hotel Pty Ltd (“The Benson Hotel”) is committed to providing quality services to you and this policy outlines our ongoing obligations to you in respect of how we manage your Personal Information.
We are committed to protecting your privacy and for that reason we will only collect, use, disclose, store and otherwise handle your personal and sensitive information that is necessary for us to deliver goods and services to you.
The Benson Hotel realises the importance of ensuring that personal information held by the company is treated confidentially and is committed to ensuring that all personal information is only collected, disclosed, used and stored in accordance with the Australian Privacy Principles set out under the federal Privacy Act 1988.
What is ‘personal information’?
‘Personal Information’ is information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.
What information we collect
We offer products and services related to accommodation and food and beverage services.
The information that we collect about you will vary depending on the way in which you interact with our businesses; however, it is mostly information that is provided by you, such as your name, date of birth, contact details (including address, email address and any phone or mobile numbers), occupation/employment details, emergency contact details, association membership numbers, corporate account number, group booking number and financial information such as credit card or bank account details.
Children’s Privacy: Our websites are not intended for children and we do not knowingly solicit or collect personal information in respect of persons under the age of 18.
Depending on how you are using our products and services we may also collect more detailed information such as information about how you use our products and services:
- Details of guardian/s for minors;
- Details of participation in membership programs;
- Information regarding selections and preferences when accessing our venue or services;
- History of preferences, interests and behaviour relating to transactions, products, services and activity with our digital services;
- Your computer IP address when visiting any of our websites;
- Your image if required for membership identification;
- Records of your communications and interactions with us;
We may collect some forms of sensitive information. This is most likely to be health information.
Where we collect sensitive information from you, we will only do so with your consent. This information will only be used for the purpose it was collected or, in exceptional circumstances, to lessen a serious threat to a person’s health or safety.
You are not obliged to provide personal or sensitive information to us; however, we may not be able to provide goods or services to you if you don’t.
If you provide us with another person’s personal information, you must have their consent to do so and we rely on you to have informed those individuals that you are providing their personal information to us and have advised them about this statement.
Collection and Storage of personal information
We will, in most circumstances and wherever possible, collect your personal information directly from you (unless it is unreasonable or impractical for us to do so). If we collect your personal information from another person and we reasonably believe that you may not have consented to the disclosure of that information to us or that information is otherwise not permitted to be disclosed to us, we will, whenever reasonably possible, make you aware that your information has been collected and the reasons for doing so.
Examples of how we may collect personal information from you are: telephone calls, face-to-face discussions, your emails, website contact forms, 3rd party booking and reservation systems and other correspondence to us.
Generally, we hold your personal information electronically and in hard copy, both at our premises and at facilities owned and operated by related companies. When personal information is held by us electronically, it is stored with our other business data within Australia.
Your information is only accessed on a ‘need to know’ basis and this forms part of the controls we apply to protecting your personal information.
Use of personal information
We need to use your information to provide you with our products and services. This may also extend to:
- Administering our business activities;
- Providing customer service;
- Personalising your digital experience;
- Contacting you regarding your reservation, booking or experience with our business;
- Making other products available to you;
- Processing bookings or applications that you submit;
- Processing and fulfilling gift vouchers;
- Surveys, direct marketing, promotions and competitions;
- Accounting purposes such as billing of services, products and memberships;
- Evaluation and improvement of the effectiveness of our website and official social media pages;
- Collecting diagnostic and statistical information relating to our IT systems;
- Facilitating our internal business operations, including the fulfilment of legal requirements and assessing new and/or improved services.
Disclosure of personal information
Personal information may need to be disclosed to external service providers engaged by The Benson Hotel in order for those service providers to fulfil their service obligations to our business. For example:
- Our contract partners to verify membership details, confirm bookings, administer gift vouchers or prizes, manage safety incidents and to provide you with goods and services;
- Service providers who are engaged to provide us services relating to accounting, legal, data analysis, online computing, contract management, business consulting, marketing, research, auditing, delivery, security, laundry, cleaning, IT, maintenance and mailing services;
- Insurers in the case of a safety incident;
- A third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
- Any other party with which we are legally required to share.
Where personal information is disclosed to an external party, The Benson Hotel will take steps to ensure that the external party treats such information confidentially and in accordance with the federal Privacy Act 1988.
Email communications
We may use your contact details to send you newsletters, marketing emails or invitations to The Benson Hotel events, which may be of interest to you. However, you may at any time opt out of receiving such materials by contacting us. Please see details below.
Accessing and correcting personal information
You may request us to provide you with access to personal information we hold about you. We will process all requests for access to personal information in accordance with the Australian Privacy Principles. In most cases, we will provide you with access to your personal information. However, we may refuse access in certain situations as listed in the Australian Privacy Principles. If we refuse to give you access, we will provide you with reasons for our refusal.
If any personal information we hold about you is not accurate, complete or up to date, please let us know and in most cases, we will use all reasonable efforts to update the information.
To make any such requests please contact us by email hello@thebensonhotel.com.au
Personal information security
The Benson Hotel is committed to keeping secure the data you provide to us and we will take all reasonable precautions to protect your personally identifiable information from loss, misuse or alteration.
Making a privacy complaint
If you have any disputes or complaints about the way in which your personal information has been handled by us, please contact us. To make such a complaint please contact us by email hello@thebensonhotel.com.au
We will investigate any dispute or complaint and respond to you within a reasonable time. If you still consider that your privacy complaint has not been resolved, you may then take your complaint to the Office of the Australian Information Commissioner (OAIC) by visiting www.oaic.gov.au or calling 1300 363 992.
GDPR – Processing EU Personal Data
This section entitled “GDPR – Processing EU Personal Data” only applies if you access our products or services in the EU and your personal data (as defined in this section) is processed and/or monitored as a result.
General – When we process your personal information, we will comply with the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), any local implementing laws and any successor legislation to the GDPR and the local implementing laws. We are the data controller (as defined in GDPR) of the data you pass to us pursuant to this policy.
Where we refer to “personal information” throughout this policy, it has the meaning set out in the Privacy Act (as explained at the beginning of this policy) and also the meaning given to “personal data” in the GDPR. “Processing” has the meaning set out in GDPR and, in practice, means doing anything with your personal information, including storing it.
Retention – if you are a regular customer of ours, we will retain your personal information for no longer than 8 years from the date of our last interaction with you. This enables us to comply with certain legal obligations and financial reporting requirements. We may choose to retain your personal information for a shorter period if we are permitted to do so under our legal and regulatory requirements.
We will also delete or update your personal information if you ask us to do so in accordance with the requirements of GDPR.
Grounds for processing – we collect most of your personal information on the grounds of our legitimate interests or fulfillment of a contract, for example, providing you with accommodation, food and/or beverage services and liaising with you in respect of those services. If we deem it appropriate, we may also rely on legitimate interests to send you marketing communications. If we are unable to rely on legitimate interests or another ground to process your personal information, we will seek consent from you in accordance with the requirements of GDPR.
If we have obtained consent from you to process your data, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us using the contact information set out below. Please bear in mind that if you withdraw your consent it may affect our ability to carry out tasks for your benefit. Withdrawal of your consent will not affect any processing we have carried out in respect of your personal information prior to you withdrawing consent.
Your rights – there are a number of rights available to you under GDPR. These include:
- the right to access your personal information and ask us to provide certain information about the processing we carry out in respect of your personal information;
- the right to ask us to rectify any personal information we process that you believe is incorrect or incomplete;
- the right to ask us to erase your personal information; the right to ask us to restrict the processing we carry out in respect of your personal information, or to object to the processing we carry out; and
- the right to have your data provided to another data controller in a structured, commonly used and machine-readable format (data portability).
Please note that there are some exceptions and caveats to the rights listed above.
Complaints – in addition to your rights set out above in the section entitled “Making a Privacy Complaint”, you are entitled to complain to the relevant supervisory authority in your jurisdiction.
Contacting us
If you have any questions about this Privacy Statement, our management of your information or if you would like a copy of this statement, please contact us by email hello@thebensonhotel.com.au:
Changes to our privacy policy
From time to time it may be necessary for us to revise our privacy policy. We reserve the right to change our privacy policy at any time without prior notice. We will notify you of the changes by posting an updated version of the policy on our website.
This Privacy Statement came into effect on 26 May 2021.