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Effective 1 March 2011

HotelClub Pty Ltd ("HotelClub") is committed to ensuring our customers'' privacy and the security of all Personal Information collected. In accordance with privacy legislation, this Privacy Policy outlines HotelClub''s Personal Information collection practices, how that Personal Information is used and the choices you can make about the way the Personal Information you provide to us is collected and used.

• We will not collect Personal Information without your knowledge and permission;
• We will not knowingly disclose your Personal Information to third parties, except as provided in this Privacy Policy;
• We will allow you to view, correct or remove your Personal Information;
• We will only use your Personal Information in order to provide and enhance the Products or Services offered on our Web Site; and
• We will take all reasonable steps to protect the security of the Personal Information we collect from you.

1. Definitionstop

   
   In this Privacy Policy, terms that commence with a capital letter are defined in this Section 1 or in the preamble.
   
   "Affiliates and Business Partners" means other companies who HotelClub is related to or contracts with in the hotel and travel services industries.
   
   To "Book" means to reserve.
   
   "Cookie" means a small computer file that is sent from our web server to a Subscriber, Member or Guest''s computer for the purpose of future identification of that computer on future visits to the Web Site.
   
   "Guest" means an individual who can search and book Products or Services on the Web Site without being a Member.
   
   "Member" means an individual who has registered with the Web Site. Members have a Member ID and a password.
   
   "Member ID" means the e-mail address you use (with your password) to login to our Web Site.
   
   "HotelClub" or "we" means HotelClub and its subsidiaries and affiliates.
   
   "Personal Information" means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred from the information. This includes, for example, name, e-mail and mailing address, telephone number, billing and account information and other information incidental to providing Products or Services (including information about individuals traveling with you).
   
   "Products or Services" means the hotel accommodation and any other items available from the Web Site.
   
   "Session Data" means usage information, such as the type of Internet browser and operating system an individual uses, the domain name of the web site from which the individual came, the date, time and duration of the visit, number of visits, average time spent on the Web Site, pages viewed, domain name of the individual and number of cookies accumulated.
   
   "Subscriber" means an individual who elects to receive offers or promotions by email or otherwise from HotelClub without becoming a Member or a Guest.
   
   "User" means a Guest or Member.
   
   "Web Site" means the www.HotelClub.com web site and its respective sub web sites together with the respective content, Products and Services available from this Web Site or sub Web Sites.

2. Consenttop

   
   BY SUBMITTING PERSONAL INFORMATION TO US, AND/OR USING OUR WEB SITE, YOU AGREE THAT WE MAY COLLECT, USE AND DISCLOSE SUCH PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW.
   
   If you do not agree with these terms, do not view the Web Site and do not provide any Personal Information to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Information, we may not be able to provide you with products or services offered on our Web Site.

3. The Personal Information we collecttop

   
   When you are just visiting
   
   You can visit certain areas of our Web Site without revealing who you are or signing-in.
   
   When you visit our Web Site as a Guest, Member or Subscriber, we collect Session Data through Cookies and pixel tags.
   
   When you register as a Member
   
   If you register with us as a Member, we collect Personal Information that is necessary to provide the Products and Services offered on our Web Site. We require that you provide your name and e-mail address. You will also have a password, which will be required to gain access to portions of our Web Site reserved for Member use. You may elect to provide other information.
   
   When you Book Products or Services as a Member
   
   When you Book Products or Services from our Web Site as a Member, you must provide payment or other necessary information. This includes, for example, billing information or similar information as required.
   
   When you "Subscribe"
   
   When you become a Subscriber, we collect your name and email address so that you may receive offers or promotions from HotelClub without becoming a Member or Guest.
   
   When you call or write to our Customer Service Team
   
   When you call or write to our Customer Service Team, we collect contact information (for example name, phone number, mailing address or e-mail address) and information about the relevant Booking as necessary to assist you. For example, if you call for assistance with a preexisting Booking, or to make a Booking, we may request your contact and billing information.
   
   When we send e-mails or e-newsletters
   
   When we send e-mails or e-newsletters, or when you forward a promotion or search results to a third party, using the "Refer a Friend" feature, we may insert a pixel tag in the e-mail. If you "Refer a Friend" to a promotion or page that you found on our Web Site, a one-time email will be sent to your friend about this information. In these instances we do not store or use that data for any additional or ongoing marketing purposes.

4. How we use the Personal Informationtop

   
   We use Personal Information in order to provide and enhance the Products or Services offered on our Web Site:
   
   
   • To record your travel preferences, to make on your behalf, or to communicate with you about your travel plans;
   • To issue invoices, administer accounts, collect and process payments;
   • To provide tips or guidance on how to use our Web Site, inform you of new features on our Web Site or provide other information that may be of interest to users;
   • To personalize the service we provide to you, tailor your experience at our Web Site to your interests and make more appropriate travel recommendations;
   • To send you e-mails, e-newsletters, personalized offers via direct messaging or other communications about our services, if you have subscribed to receive this information or you have not advised us that you do not wish to receive such communications;
   • To manage our Web Site, diagnose technical problems, improve content and allocate the resources of our systems so that your experience with our Web Site is as efficient as possible;
   • To process and track your transactions;
   • To send you information about our and our Affiliates'' and Business Partners'' products and services and other information and materials that may be of interest to you;
   • To develop, enhance, market, sell or provide HotelClub''s Products or Services, or those of companies with which we have a commercial relationship, but only if you have granted us permission to do so or we are otherwise able to do so under applicable law;
   • To evaluate credit standing and to match credit bureau or credit reporting agency information; to investigate, detect and protect HotelClub and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activities; in performing these evaluations, personal information provided by you may be disclosed to a registered credit agency which may keep a record of that information.
   • To effect a corporate transaction in connection with the sale, merger, spin-off or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in the regular course of business;
   • To audit compliance with our policies and contractual obligations;
   • As permitted by, and to comply with, any legal or regulatory requirements or provisions; or
   • For any other purpose to which you consent.
   
   Aggregated Information
   Aggregated information is information recorded in any form about more than one individual, where the identity of the individual is not known and cannot be inferred from the information. We may use aggregated information to describe our User base to current or potential partners, investors and advertisers; after a survey, to understand and respond to market needs and preferences; or to make recommendations to other Users of our Web Site. For example, if Users of our Web Site who have traveled to a particular destination told us that they had positive experiences at a hotel in that destination, we might recommend that hotel.
   
   What we do NOT do
   We do not and will not, at any time, request your credit card information, Member ID or login password in a non-secure or unsolicited e-mail or telephone communication.
   Identity theft and the practice currently known as "phishing" are of great concern to us. Safeguarding information to help protect you from identity theft is our priority.

5. To whom we disclose Personal Informationtop

   
   From time to time, we may disclose your Personal Information as follows:
   
   
   • To those hotels with which you make arrangements through our Web Site. We provide them with the Personal Information needed to make and complete the booking or reservation;
   • To organizations that perform services for or on behalf of HotelClub , for example to provide customer service, process credit cards, for research, marketing, data processing, to measure the use of our Web Site, to facilitate usage by a User, or to offer credit card services or evaluate your creditworthiness. We will share with these companies only that Personal Information which they need to work on our behalf. Some of these service providers may be located in countries outside Australia. Your Personal Information will be provided to these organizations only if they agree to use such information solely for the purpose of providing services to HotelClub , and under the instructions of HotelClub , and with respect to that information, to act in a manner consistent with the relevant principles articulated in this Policy;
   • By submitting your Personal Information, you consent to the transfer, storing and processing of your Personal Information outside Australia to other companies in our group or to third parties who will provide you with a product or service to help us provide our services to you;
   • We may collaborate with other companies to offer you additional Products or Services, for example, through promotions. We will share Personal Information that is necessary for these other companies to provide the Products or Services that you have requested.
   This policy does not cover the use of your Personal Information by these other companies. We encourage you to read a company''s privacy policy before requesting any of its products or services.
   • To protect our Web Site and our rights under our Terms and Conditions of Use; to protect ourselves against liability or prevent fraudulent activity; or where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain;
   • To effect a corporate transaction, in connection with the sale, merger, spin-off or other corporate reorganization of our corporation, where the information is provided to the new controlling entity in regular course of business; and
   • To our insurers and to regulatory agencies.
   
   Disclosure without consent
   
   Please note that there are circumstances where the use or disclosure of Personal Information may be justified or permitted, or where HotelClub may be obligated to disclose information without consent.
   
   Such circumstances may include:
   
   
   • If required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information or to comply with the rules or court relating to the production of records. If we receive a formal request to disclose your Personal Information in connection with a legal action, we will attempt to contact you about it, if permitted by law, via the e-mail address you provided during registration, before we respond to that request. If you have not registered with us, we will attempt to contact you on the details you have provided in your transactions with us.
   • If a law, regulation, rule or guideline requires it.
   • To a person who needs the information because of an emergency that threatens the life, health or security of an identifiable person or group.
   • Where it is necessary to collect monies owing to us.

6. How we retain and store Personal Informationtop

   
   We will retain your Personal Information in our databases in accordance with our records management policy and applicable laws. This period may extend beyond the end of your relationship with us, but it will be only as long as it is necessary for us to fulfill the purposes for which your Personal Information was collected – this may include ensuring that we have sufficient information to respond to any issues that may arise later. For example, we may need or be required to retain information to allow you to obtain credit for a trip you Booked but had to cancel. We may also need to retain certain information to prevent fraudulent activity; to protect ourselves against liability, permit us to pursue available remedies or limit any damages that we may sustain; or where a law, regulation, rule or guideline requires it.
   
   Your Personal Information will be stored in secured locations and on servers controlled by HotelClub , located either at our offices or at the offices of our service providers as described in How we protect Personal Information.

7. How we protect Personal Informationtop

   
   HotelClub employs physical, administrative and technical safeguards to help protect the confidentiality and integrity of Personal Information and to reduce the risk of loss, misuse, unauthorized access disclosure or modification of Personal Information. When Personal Information is sent to our service providers, we require, in our contracts with them, that they protect all Personal Information in a manner consistent with the principles articulated in this Privacy Policy.
   If you choose to contact HotelClub through the Web Site, you should be aware that any information transmitted electronically via the World Wide Web might not be secure. HotelClub assumes no liability for the loss of any information that you transmit to us via the World Wide Web. However, should you choose to pay by credit card when making a booking or reservation on the Web Site, your card details are encrypted for the transaction.
   In communicating with you, we may send e-mail as unencrypted plain text because we are aware that most Members, Guests or Subscribers cannot readily process encrypted e-mail. This is done for your convenience, but with the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail.
   
   While being transmitted over the Internet, your credit card details are protected using SSL (Secure Socket Layer) encryption. Credit card details are only used to pay for accommodation related costs booked through our service. These details are stored securely at all times, are not used for any other purpose and will never be provided to any unauthorised third parties.

8. How to access or correct your Personal Informationtop

   
   We endeavor to ensure that Personal Information is as accurate, complete and current as necessary for the purposes for which we use that information. If you are a Member, we encourage you to visit your member profile tab to review your Personal Information. All Users of the Web Site may request access to, update of correct Personal Information we hold about them by emailing us at privacy@HotelClub.com.
   
   At any time, HotelClub Members can view and/or update all the Personal Information in their member profile. To do so, login on the Membership Homepage and click on "My Profile" to view and/or make the required changes. Should you wish to cancel your membership with HotelClub , simply notify us by sending an email to customer_service@HotelClub.com.
   
   If you request that we remove all of the Personal Information or travel records stored in My Account, we will promptly do so. Once required Personal Information is removed, however, you will not be able to use many of the services available on our Web Site to Members, unless you re-register.
   
   Please remember that we may not be able to honor your request if we are legally obligated to retain that information, or for other reasons as described in ''How we retain and store your Personal Information''.

9. Privacytop

   
   Cookies
   A Cookie is a small text file that our computer sends to your computer, and that your computer sends back to us each time you make a request from our Web Site. A cookie contains a unique identification number that identifies the user''s browser, but not necessarily the user. A pixel tag is a small graphic image similar to a cookie.
   
   When you access our Web Site, our computer may seek to place "cookies" or "pixel tags" on your personal computer to collect Session Data. Cookies and pixel tags are used for the purpose of helping us to recognize you when you visit our Web Site again and to help us customize your online experience. Unless a user specifically informs us of his/her identity (e.g. by registering with us), we will not know who the individual user is.
   
   Most Internet browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies or prompt you before accepting a cookie from the Web Sites you visit. You can learn more about the use of cookies by visiting http://networkadvertising.org or http://www.allaboutcookies.org.
   
   If you decide not to accept our cookies, you will be able to access those parts of our Web Site that are available to the general public, but you will not be able to access many of the Products and Services offered at our Web Site.
   
   Third Parties and Advertising
   Third parties advertise on our Web Site, and we also contract with third parties to serve ads across the Internet. These third parties may serve ads about our products or services, or third party products or services in which, based on your Session Data, we or our Business Partners believe you may be interested. While we may share Session Data with third parties to help facilitate the serving of these ads, we do not share any Personal Information about you unless you give us permission to do so, separate from any permission you provide during the Member registration process. These third parties may seek to use cookies and pixel tags, including those collected on our Web Site, to track Session Data about the ads you have seen and types of things in which you appear interested. These third parties may also use combined information about your visits to our Web Site and other sites in order to provide advertisements about related goods and services that may be of interest to you.
   
   When you click on a third party''s link from our Web Site, you will leave our Web Site and will enter that third party''s site. We are not responsible for such third party''s sites. You should carefully review the privacy statements of any other web site you visit, because those privacy statements will apply to your visit to that web site, and may be very different from our policy.
   
   Opting out of promotional information
   We at HotelClub work hard to provide our customers with the best possible rates in all our hotels. From time to time, we will send our Members and Subscribers newsletters, updates and specials for hotels in certain areas. You will only receive this correspondence if you have specifically chosen to do so and we hope that you will find these items informative and useful. However, should you choose to not receive them in the future, you will have the ability to unsubscribe from the mail database by clicking on the Unsubscribe link at the bottom of each email.
   
   Monitoring
   HotelClub may from time to time monitor and review any information transmitted or received through the Web Site, or through telephone or email communications, for quality assurance and other purposes. We reserve the right to censor, edit, remove or prohibit the transmission or receipt of any information that HotelClub deems inappropriate or in violation of these Terms and Conditions. During monitoring the information may be examined, recorded or copied.
   
   Links
   For your convenience, our Web Site provides links to other web sites. When you click on one of these links, you are leaving our Web Site and entering another web site. We are not responsible for such third party web sites. You should carefully review the privacy statements of any other web sites you visit, because those privacy statements will apply to your visit to such other web sites.

10. Changes to the Privacy Policytop

    
    We may change or supplement this Privacy Policy from time to time. Privacy Policy changes will apply to the information collected from the date we post the revised Privacy Policy on our Web Site, as well as to existing information held by us. PLEASE CHECK THIS PRIVACY POLICY PUBLISHED ON THE WEB SITE REGULARLY TO ENSURE THAT YOU ARE AWARE OF ALL CHANGES TO THIS PRIVACY POLICY. YOUR CONTINUOUS USE OF OUR WEB SITE IMPLIES THAT YOU ACCEPT ALL CHANGES IN THIS PRIVACY POLICY.
    
    If we decide to change this policy in a material way, we will obtain the necessary consents required under applicable privacy laws if we seek to collect, use or disclose Personal Information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law. If any proposed change is unacceptable to you, you may request that we remove your Personal Information from our records, as described in ''How to access or correct your Personal Information''.

11. How to contact ustop

    
    If you have any concerns or queries about the Privacy Policy of HotelClub or would like more information, please contact us on privacy@HotelClub.com. We will attempt to respond to all reasonable concerns or inquiries sent to this email address within thirty (30) business days of receipt or as required by applicable law. If we receive your request at a different email address, we will respond within a reasonable period of time.
    
    CUSTOMERS - Please DO NOT submit booking enquiries to the above email address, as they will not be answered. If you have a question about an existing or new booking, please go our Customer Service Center.





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