Cosmopolitan Hotel Privacy Statement
Tenware Pty Ltd ACN 090 706 595

INTRODUCTION

From time to time, Tenware Pty Ltd (Cosmopolitan Hotel) (“Company”) may collect, hold, use and/or disclose personal information relating to its customers, in the performance of its business activities. The Privacy Act 1988 (Cth) (“Act”) and Australian Privacy Principles (“APP”) contain important provisions designed to regulate the collection, maintenance and use of personal information by businesses. The Company takes its obligations under the Act and APP very seriously. We are committed to the protection and proper use of any personal information you give to us. This Customer Privacy Statement sets out our policy for the collection, handling and use of our customers’ personal information, in accordance with the Act and the APP.

TYPE OF INFORMATION

Personal information means information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.

Throughout your dealings with us we may request that you provide us with your personal information. The Company collects personal information that is reasonably necessary for one or more of its functions or activities.

The Company is principally a hospitality business, and we carry out a number of hospitality activities and functions, including operating a hotel, online bookings and information, promotional materials, credit and other card systems and customer reward schemes. The information we collect and hold will depend on the type of service we provide you. Generally, however, the type of personal information that we may collect and hold will include your name, address, date of birth and contact details as well as other basic personal information such as e-mail address and website usage details, and in certain cases, your credit card details.

COLLECTING AND HOLDING

The Company must collect personal information only by lawful and fair means.

The Company will collect personal information directly from you if it is reasonable or practicable to do so. The ways in which the Company may collect personal information from you includes but is not limited to:

• email or other written communications;
• telephone calls;
• in person;
• through transactions;
• through our website;
• through surveillance cameras;
• through application forms;
• by technology that is used to support communications between us, which may be:
a. through publicly available information sources (which may include telephone directories, the internet and social media sites); and
b. direct marketing database providers.

When the Company collects personal information about you through publicly available information sources, it will manage such information in accordance with the APPs. You agree that, where you provide us with your phone number (including home, work or mobile number), or your email address, that we can contact you by phone, email, SMS or MMS on that number or via that email address until such time as you to tell us to stop.

USE & DISCLOSURE OF YOUR PERSONAL INFORMATION

The main purposes for which the Company may collect, hold, use and/or disclose personal information may include but are not limited to:
• providing you with a service or product;
• customer service management;
• events;
• surveys and general research; and
• if you consent, or if required or authorised under law.

The Company may use or disclose personal information (other than sensitive information) about you for the purpose of direct marketing (for example, advising you of new goods and/or services being offered by the Company).

You can opt out of receiving direct marketing communications from the Company by contacting the Privacy Officer in writing or accessing the Company’s website and unsubscribing.
The Company may disclose your personal information for any of the purposes for which it was collected, as set out in this Customer Privacy Statement, or whether it is under a legal duty to do so.
Disclosure will usually be internally and to related entities or to third parties such as contracted service suppliers.

When we engage a third-party supplier or contractor we will ensure their privacy policies meet our standards before disclosing any of your personal information to that third-party supplier or contractor.

The Company will not disclose customers’ personal information to overseas recipients.

Other than as set out in our Customer Privacy Statement we will not disclose personal information for any other purpose other than for that which it has been provided.

Cross-border disclosure of personal information

As the Company utilises the services of overseas servers, your personal information may be to overseas recipients for the purposes of cloud storage.

ACCESS, CORRECTION & OPENNESS

Our privacy policy is designed to protect you, the customer. We have therefore adopted a policy of openness which means you can access your personal information upon request. The Company will respond to any request within a reasonable period. There are certain circumstances in which the Company may refuse to grant you access to the personal information. In such situations the Company will give you written notice that sets out:

• the reasons for the refusal; and
• the mechanisms available to you to make a complaint.

If the Company holds information that is inaccurate, out-of-date, incomplete, irrelevant or misleading, it must take reasonable steps to correct the information.

You can make a request for the Company to correct your personal information. We provide multiple ways in which you can contact us; online, by phone, in-store or at our head office. The Company will take reasonable steps to correct the information, and will respond to any such requests within a reasonable period. We may also contact you from time to time to check that your information is still accurate.

There are certain circumstances in which the Company may refuse to correct personal information. In such situations the Company will give you written notice that sets out:

• the reasons for the refusal; and
• the mechanisms available to you to make a complaint.

If the Company corrects personal information that it has previously supplied to a third party and you request us to notify the third party of the correction, the Company will take reasonable steps to give that notification unless it is impracticable or unlawful to do so.

INTEGRITY AND SECURITY OF PERSONAL INFORMATION

The Company will take such steps (if any) as are reasonable in the circumstances to ensure that the personal information that it:
• collects is accurate, up-to-date and complete; and
• uses or discloses is, having regard to the purpose of the use or disclosure, accurate, up-to-date and complete.

We are committed to the protection of your personal information. The Company will take all reasonable steps to ensure any personal information we receive is held, whether electronically or by hard copy, securely in order to protect it from misuse, loss, unauthorised access, modification or disclosure. The Company will regularly review our data management systems to ensure the integrity of those systems.

If the Company holds personal information, and it no longer needs the information for any purpose for which the information may be used or disclosed, the information is not contained in any Commonwealth record and the Company is not required by law to retain the information, it will take such steps as are reasonable in the circumstances to destroy the information or to ensure it is de-identified.

COOKIES

We may use cookies to collect information from you. Cookies identify a particular computer to our server. We may use the information collected in this way to provide the user of that computer with a personalised experience of our website. Your browser may allow you to disable cookies. If you do this, your experience of our website will not be personalised.

ANONYMITY AND PSEUDONYMITY

You have the option of not identifying yourself, or using a pseudonym, when dealing with the Company in relation to a particular matter. However, this does not apply:
a. where the Company is required or authorised by or under Australian law, or a court/tribunal order, to deal with individuals who have identified themselves; or
b. where it is impracticable for the Company to deal with individuals who have not identified themselves or who have used a pseudonym.
However, in some cases if you do not provide the Company with your personal information when requested, the Company may not be able to respond to your request or provide you with the goods or services that you are requesting.

CHANGES TO OUR CUSTOMER PRIVACY STATEMENT

Our handling of any information we collect from you (including information previously collected) will be governed by the most current version of this Customer Privacy Statement. Please check this Customer Privacy Statement regularly.

FURTHER INFORMATION

Further information regarding the Act generally can be obtained from the Office of the Australian Information Commissioner located at www.privacy.gov.au or by calling the Privacy Hotline 1300 363 992 (local call charge).

COMPLAINTS

You have a right to complain about the Company’s handling of your personal information if you believe the Company has breached the APPs.
If you wish to make a complaint to the Company, you should first contact the Privacy Officer in writing. Your complaint will be dealt with in accordance with the Company’s complaints procedure and the Company will provide a response within a reasonable period.

If you are unhappy with the Company’s response to your complaint, you may refer your complaint to the Office of the Australian Information Commissioner.

PRIVACY OFFICER CONTACT DETAILS

If you have any queries or complaints about your personal information or this Customer Privacy Statement, please contact:

Cosmopolitan Hotel Privacy Officer
Address: 2-8 Carlisle Street, St Kilda Melbourne VIC 3182
Telephone: +61 3 8598 6700
Email: book@cosmostkilda.com

We welcome your feedback and will deal with your request or inquiry as soon as is reasonably possible.