PRIVACY POLICY

This Privacy Policy applies to:

• Australian Tourist Park Management Pty Ltd ACN 061 270 513, trading as NRMA Parks and Resorts or its other business names;
• NRMA Holiday Parks Licensing Pty Ltd ACN 131 243 715; and
• NRMA Tasmania Pty Ltd ACN 648 516 876,

together NRMA Parks and Resorts, being members of the National Roads and Motorists’ Association Limited (ACN 000 010 506) (NRMA)* group of companies.

This Privacy Policy is effective from February 2024.

Our commitment to Privacy

NRMA Parks and Resorts is committed to treating the privacy of our guests and members with the utmost importance.

This Privacy Policy applies to any collection, use and disclosure of personal information by NRMA Parks and Resorts, including when it is operating or managing a park, resort or accommodation for a third party.

We may update this Privacy Policy from time to time. The most current version will be posted on the NRMA Parks and Resorts website and will be effective from the date of posting. We recommend that you check it regularly.  You can also obtain a copy of this Privacy Policy by contacting our Privacy Officer using the contact details at the end of this Privacy Policy.

The types of Personal Information we collect

The personal information that NRMA Parks and Resorts collects may include the following:

• name and signature;
• contact details, including physical address and postcode, email address, and phone number;
• communication, accommodation, activities and travel preferences;
• IP address and device information (including location data), for example for security and verification purposes or where you use our Wi-Fi services;
• date of birth (but only where required for an NRMA membership application or to participate in certain activities offered by NRMA Parks and Resorts);
• vehicle and caravan details including registrations and vehicle make and model;
• payment information (such as credit card, PayPal or bank details);
• financial and transaction details associated with bookings, products and services;
• membership details of, previous interactions with, and benefits from, NRMA Parks and Resorts, and/or your motoring, holiday park, caravan or camping club membership, or loyalty program;
• family details (such as name, number and age of children, and any other family information that you choose to provide to us);
• images obtained through CCTV;
• other information that you tell us (for example your gender);
• sensitive information, such as dietary, allergy or mobility information, where you choose to provide it to us, or health information where there has been a safety incident at the park, resort, or accommodation;
• photographic identification, but only where required by law (for example the Liquor Act 2007 (NSW) or equivalent);
• the names of those involved in, and details of, any safety or other incident that occurs in the park, resort, or accommodation (including photographs where appropriate);
• location data.

If you are one of our long-term guests or residential tenants, we may also collect information relating to your insurance and other information required by the legislation listed below.

If you are one of our suppliers or partners, we may also collect:

• contact details;
• references and information derived from those references;
• credit check information; and
• insurance, payment and incorporation information (including director information).

If you apply for a position with us as an employee, volunteer or contractor, we may also collect:

• criminal background, working with children and credit checks, insolvency or bankruptcy information (including as collected in the context of pre-employment screening/checks);
• CVs, references, immigration and citizenship status and documentation, application forms, details of education, job history and experience, areas of expertise, qualifications, licences to operate, interview notes, bank details, contracts of engagement and offer letters;
• other information derived from background checks, including previous address details;
• medical assessments or checks; and
• where you are a contractor, such other information as is specifically set out in your contract.

From time to time you may provide us, and we may collect from you, the personal information of a third party (such as a family member, friend, student or guests for whom you are organising accommodation or activities, or your employees if you are one of our contractors). Where you provide the personal information of third parties, you must ensure that you have their consent to provide that information to us, and that they are made aware of this Privacy Policy.

You do not have to provide us with any personal information however, if you do not do so, this will limit the services we are able to provide to you, or receive from you.  For example, we may not be able to provide a product or service you have requested, let you know about our products and services, consider or process an application you have made, receive products or services that you have offered to us or that we have requested of you, accept or validate your entry in a promotion, respond to your queries or complaints, or process your application for a position (as an employee or contractor).

Why we collect Personal Information

The primary use for obtaining personal information is to:

• contact and respond to guests and members;
• assist us with providing services to cater to special needs;
• arrange and book accommodation, tours and other services on a guest’s or member’s behalf;
• regulate entrance into our park, resort, or accommodation, to locate the driver of a vehicle that needs to be moved, or to ensure space for caravans;
• provide tourism information and bookings;
• effectively administer records (including those relating to guest and member records and history), accounts and financial transactions;
• assist our internal administration and operations including accounting, risk management, record keeping, archiving, systems development and testing, staff training and management of our facilities;
• evaluate any assets or business and use your information after any transfer of those assets or business;
• verify and manage membership particulars and subscriptions (for example, with the NRMA);
• establish residential tenancy agreements;
• improve services and facilities to meet guest and member preferences and needs;
• provide opportunities for future sales and marketing;
• provide goods and services in connection with NRMA Parks and Resorts business or undertaking;
• assist in managing risks associated with staying at a park, resort, or accommodation, including responding to and managing emergencies and safety concerns (both current and anticipated);
• understand the demographics of existing and future guests and members; and
• offer marketing material to guests and members.

Some personal information obtained is required by the following legislation:

• Code of Conduct for the short-term rental accommodation industry (NSW)
• Food Act 2003 (NSW)
• Holiday Parks (Long Term Casual Occupation) Act 2002 (NSW)
• Innkeepers Act 1968 (NSW)
• Liquor Act 2007 (NSW)
• National Parks and Wildlife Act 1974 (NSW)
• Residential (Land Lease) Communities Act 2013 (NSW)
• Residential Tenancies Act 2010 (NSW)
• Retail Leases Act 1994 (NSW),

and equivalent legislation in other states and territories.

How we collect personal information

Generally, we collect personal information directly from you, such as when you request a product or service, in the course of providing you with that product or service, or when you have other dealings with us.

We may collect and update that information over the phone (including SMS), over the internet, in person, when you participate in our marketing campaigns, surveys or competitions, and when you otherwise communicate with us.

We may also collect personal information through third parties such as:

• our related companies;
• affiliated interstate motorists’ clubs;
• Insurance Australia Limited*(trading as NRMA Insurance) and its related entities;
• social media (including your image, social media handle and other publicly available biographic material in conjunction with your image and associated content – please see our User Generated Content Policy);
• travel and booking agencies;
• our park, resort and accommodation managers;
• organisers of school, special interest, wedding, holiday and other group functions and activities;
• third party service providers such as campaign and survey agencies;
• third parties that provide activities, experiences or services to our guests and members;
• government databases (such as ASIC); and
• any third party from whom we are intending to acquire business or assets.

When we disclose personal information

We may disclose personal information to:

• our related companies;
• affiliated interstate motorists’ clubs;
• holiday parks, caravan, camping and other clubs or loyalty programs where you are a member of those parks, clubs or loyalty programs;
• Insurance Australia Limited*(trading as NRMA Insurance) and its related entities;
• our park, resort and accommodation managers and staff;
• local councils or other third parties where the local council or third party owns the park or resort that we manage;
• state governments where required for funding and management purposes;
• postal service providers;
• marketing, campaign and survey providers;
• third parties that provide services to us, including auditors;
• organisers of school, special interest, wedding, holiday and other group functions and activities;
• third parties that provide activities, services or experiences to our guests and members when those activities, services or experiences have been booked through us;
• third parties to whom we are intending to transfer our business or assets;
• other parties when requested or authorised by you; and
• our insurers or enforcement bodies where there has been an incident at our park, resort or accommodation.

Direct Marketing

We may use and disclose the personal information we collect for the purpose of providing you with tailored marketing communications about our goods and services, or to conduct market research. We may send these communications to your email address, phone, or mailing address.

NRMA Parks and Resorts will also provide options for a person to opt out of receiving marketing material.

We may also collect certain demographic information and behavioural information from social media platforms to better serve consumers with more targeted advertising.

Opting out of direct marketing

If you do not wish to receive direct marketing information from NRMA Parks and Resorts, please use the contact details below to update your preferences, or follow the opt out instructions in the marketing communication.

Please note that if you make such a request, we may still need to use and disclose your personal information to provide you with the services and products you have requested.

It may not be possible for us to immediately action a request to cease receiving any or all direct marketing material, but we will respond to such requests as soon as practicable and will make all reasonable efforts to promptly activate a change in preference or an opt-out of receiving future direct marketing material.

Protection of personal information

All information stored electronically is protected by unique password and network protection.  Physical records are kept in secure (locked) locations to prevent unauthorised access or disclosure.

When the opportunity arises, NRMA Parks and Resorts will take steps to confirm or update the personal information and contact particulars to ensure currency is maintained as is practicable.

Website cookies and digital services

Information is also generated and collected whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance. We may also record such information against your profile.

Some parts of our websites also use data tracking such as “cookies”.  A “cookie” is a small text file that is placed on your computer’s hard drive by a web page server. Cookies store information about the use of our website and are used to identify new or previous visitors to the website and what pages have been accessed. Most web browsers are set to accept cookies, but this function can usually be disabled if you wish. Please note that if you do disable cookies or other data tracking, not all functionality on our websites will be available to you. If you log in through your profile, data tracking will still be active even if you disable cookies.

Overseas disclosure of personal information

Parks and Resorts is likely to disclose some of your personal information, for marketing, support and maintenance purposes, to organisations in the United States of America, India and the Philippines.  We will take reasonable steps that are practicable in the circumstances to ensure that those organisations maintain the security of that personal information.

Location-Based Services

We may collect, use and disclose location data, including the real-time geographic location of your mobile device, solely for security purposes or with your express consent.

CCTV

NRMA Parks and Resorts may collect closed circuit television footage (CCTV footage) when you enter, access or use facilities at NRMA owned, leased or operated sites including but not limited to parks, resorts, accommodation and/or carparks.

NRMA Parks and Resorts may disclose CCTV footage (including where it contains personal information that is not de-identified) to the following parties for the following purposes:

• our related companies for internal reporting and operational reasons;
• to third party security providers for the purpose of security and surveillance of NRMA Parks and Resorts sites;
• our insurer for the purpose of investigating incidents and/or defending claims; and
• to law enforcement agencies for the purpose of investigating and/or prosecuting criminal activity, locating missing persons, or as otherwise required or permitted by law.

We may also provide de-identified CCTV footage to research partners for the purpose of research and analysis projects to improve NRMA security operations and guest and member experience.

It is your responsibility to inform any guests travelling with you or visitors that you may invite to our sites or facilities of our collection and disclosure of CCTV footage.

Access and Correction

NRMA Parks and Resorts will provide access to personal information held by us on you, according to our obligations under the Privacy Act.   We may charge a fee for retrieving this information, in which case we will inform you of the fee in advance of providing the information. Prior to information being released, precautions will be taken to confirm the person’s identity by reference to information held and other unique information held.

If your personal details change, such as your address or phone number, please contact us on NRMA Parks and Resorts Head Office on (07) 5607 1405 or info@nrmaparksandresorts.com.au to update your details.

Raising concerns

If you wish to raise any concern about our handling of your personal information, please send your written concerns to the NRMA Parks and Resorts Privacy Officer – compliance@nrmaparks.com.au or Suite L218A, The Strand, 72-80 Marine Parade, Coolangatta QLD 4225.

We will promptly acknowledge and investigate any concerns about the way we manage personal information. If you are dissatisfied with the outcome of our investigation, you may take your privacy complaint to the Office of the Australian Information Commissioner (OAIC). For information in making a complaint to the OAIC, please visit the OAIC’s website http://www.oaic.gov.au/privacy/privacy-complaints, or phone 1300 363 992.

Contacting NRMA Parks and Resorts

Any queries relating to this policy, enquiries about the personal information held, requests to update personal information, or requests to be excluded from receiving marketing communications may be directed to the NRMA Parks and Resorts Head Office on (07) 5607 1405 or info@nrmaparksandresorts.com.au.

*Insurance Australia Limited (trading as NRMA Insurance) and its related entities are separate and unrelated to National Roads and Motorists’ Association Limited.