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11/1/2023

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PRIVACY POLICY


INTRODUCTION

Luxury Escapes Travel Pty Ltd (ACN 150 650 927) (Luxury Escapes) and each of its
Related Bodies Corporate (also referred to as “We” in this Privacy Policy)
respect your privacy. We have developed this Privacy Policy to inform you of how
we protect the Personal Information that we Collect, Use, Disclose and keep
secure. It also covers how Luxury Escapes makes the Personal Information it
holds available for access to and correction by you.

This Privacy Policy has been drafted having regard to our obligations under the
Privacy Act 1988 (Cth), the Privacy Amendment (Enhancing Privacy Protection) Act
2012 which includes the Australian Privacy Principles (collectively, the Privacy
Act), the Spam Act 2003 Cth (Spam Act) and the General Data Protection
Regulation (EU) (GDPR). This Privacy Policy is a public document and has been
prepared in light of Australian Privacy Principle 1 - Open and Transparent
Management of Personal Information.

Please take a few minutes to review this Privacy Policy. In dealing with Luxury
Escapes including but not limited to using the Luxury Escapes Website or
ordering products advertised by Luxury Escapes over the phone, you expressly
consent to the Collection, Use and Disclosure of your Personal Information as
set forth in this Privacy Policy.


1. COLLECTION OF PERSONAL INFORMATION

1.1 Luxury Escapes Collects Personal Information about customers, prospective
customers and Website users which is reasonably necessary for, or directly
related to, one or more its functions or activities. We Collect your Personal
Information in several ways, including but not limited to:

   (a) the registration process on our Website;

   (b) other instances in which you provide Personal Information via our
Website;

    (c) over the phone.

   (d) via data matching / enrichment activities conducted by us and/or by third
party service providers.

1.2 Generally, the type of personal information we collect about you is the
information that is needed to facilitate your travel arrangements, bookings and
to arrange travel-related services and products on your behalf. The information
we may collect may include, but is not limited to details such as your: name,
residential and/or mailing address, contact numbers, email address, passport
details, credit/debit card details (including card type, card number, security
number and expiry date), frequent flyer details, dietary requirements and any
health or lifestyle issues that may be relevant to your travel arrangements for
the purposes of Luxury Escapes and/or the travel service providers that we may
engage on your behalf (this may include but is not limited to: airlines,
insurance providers, hotels/resorts etc.) In some circumstances we may need to
collect sensitive personal information such as your religious beliefs, criminal
record and health information. We will only collect this information with your
consent and where it is reasonable in the circumstances for the purposes of
facilitating your travel arrangements. We will only use and disclose this
sensitive information in accordance with the purpose for which the information
is required.

1.3 If you wish to 'refer a friend' to Luxury Escapes that friend must register
themselves - we will not enter Personal Information on their behalf. You can
refer a friend to Luxury Escapes by clicking on the following link,
https://luxuryescapes.com/refer.

1.4 At or before the time, or, if that is not practicable, as soon as
practicable after, we Collect your Personal Information, we will notify you of
the matters required pursuant to Australian Privacy Principal 5 – Notification
of the Collection of Personal Information, by providing you with this Privacy
Policy, or by notifying you of how you may access this Privacy Policy.

1.5 Luxury Escapes will not sell your Personal Information to any third party.


2. HOW WE USE YOUR INFORMATION AND WHEN WE MAY DISCLOSE IT

2.1 Luxury Escapes holds Personal Information which it has Collected to Use
and/or Disclose for its Primary Purposes. You provide your consent to us Using
and/or Disclosing your Personal Information for the following Primary Purposes:

   (a) promoting daily deals to you;

   (b) answering your inquiry;

   (c) assisting us to process payment for the product or service purchased by
you;

   (d) sending you additional materials (or engaging in digital marketing to
you) relating to Luxury Escapes (or its Partner Brands) products and services
that may be of interest to you; and

   (e) providing you with effective customer service.

2.2 Luxury Escapes also holds Personal Information which it Uses and/or
Discloses for purposes other than its Primary Purposes (Secondary Purposes). You
provide your consent to us Using and/or Disclosing your Personal Information for
the following Secondary Purposes:    (a) billing and account management;

   (b) business planning and product development;

   (c) enabling us to better understand your needs and interests;

   (d) improving the content, functionality and usability of our Website;

   (e) improving our marketing and promotional efforts;

   (f) displaying personalised advertising when you visit our Website;

   (g) for any other purpose identified in any other agreement between Luxury
Escapes and you;

   (h) issues, news or other information relevant to your dealings with Luxury
Escapes, or about Luxury Escapes generally, or the industries in which you or
Luxury Escapes operates;

   (i) the organisation has reason to suspect that unlawful activity has been,
is being or may be engaged in, and uses or discloses the personal information as
a necessary part of its investigation of the matter or in reporting its concerns
to relevant persons or authorities;

   (j) in order to re-engage with and send marketing material to you (including
via email, telephone, sms or Whatsapp) if your account has become inactive; and

   (k) as otherwise described in this Privacy Policy.

Use of Cookies 2.3 – In addition to the Secondary Purposes outlined above we use
Google Analytics (a web analytics services provided by Google) and data such as
age, gender and browsing activity to better understand the behaviour of our
customers and provide targeted advertising to suit customers interests and
preferences. Accordingly, when you visit our website, we, and/or a third party,
may place cookies on your browser to determine information including (but not
limited to) your computer's location, browsing activity and time spent on our
website. We use this information to help measure and research the helpfulness of
website features and offers, and serve relevant ads to our users. By using this
website and agreeing to this policy, you grant us permission to place and store
cookies on your browser. Cookies can be managed by accessing the individual
browser settings. You can also opt-out of receiving personalised ads by clicking
here or here. If you choose to opt-out, you will still see online
advertisements, but they will be less relevant to your interests.

2.4 Luxury Escapes may Use and/or Disclose your Personal Information for any
Secondary Purposes not included in this Privacy Policy if:

   (a) the Secondary Purpose is related to a Primary Purpose; and

   (b) you would have a Reasonable Expectation that we would Use the information
for that Secondary Purpose.

2.5 From time to time we may Disclose your Personal Information to organisations
outside of Luxury Escapes in order to deliver the services you require. Your
Personal Information is Disclosed to these organisations only in relation to us
providing our services to you. These organisations carry out, amongst other
services, our:

   (a) billing and debt- recovery functions;

   (b) customer inquiries;

   (c) information technology services;

   (d) marketing services (including market research);

   (e) website usage analysis; and

   (f) to support or facilitate any of those activities described in Points 2.1
and 2.2 of this Privacy Policy

We will take reasonable practicable steps to ensure that these organisations are
bound by confidentiality and privacy obligations in relation to the protection
of your Personal Information.

If you purchase a product, we will disclose your name, address and other
information necessary to complete the order to the merchant on whose behalf the
deal is advertised (the Merchant). We will use reasonable endeavours to make
sure that the Personal Information that we disclose to the Merchant on your
behalf is the minimum necessary to complete the order.

2.6 The Website uses plugins (hereinafter "Plugins") of the social network
Facebook, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto,
CA 94304, USA (hereinafter "Facebook"); Google Inc (hereinafter Google),
operated by Alphabet Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043;
and Apple Inc (hereinafter Apple), 1 Apple Park Way, Cupertino, CA 95014. The
plugins are marked by a Facebook logo, Google logo, Apple logo or the words
"Social Plug-in by [Company Name]" or "[Company Name] Social Plugin". If you
request a page of our website which contains a plugin, your browser will build
up a direct connection to the servers of that company. Facebook, Google and
Apple directly transmit the content of the plugin to your browser and from there
it is incorporated in the website. By integrating the plugin, Facebook, Google
or Apple receive the information that your browser has accessed the page of our
website, even if you do not have an account or if you are not logged into
Facebook, Apple or Google at the time. This information (including your IP
address) will be sent directly from your browser to Facebook, Google or Apple
servers in the U.S. and stored there. If you are logged into Facebook, Facebook
can assign your visit to our website directly to your Facebook account. If you
interact with the plugins, for example, by pressing the "Like" button or by
leaving a comment, the corresponding information is also transmitted directly to
a Facebook server and is stored there. The information is also posted on
Facebook and can be seen by your Facebook friends. Facebook, Google or Apple may
use this information for purposes of advertising, market research and
personalised design of website pages. For this purpose, Facebook, Google and
Apple create profiles regarding usage, interests and relationships, e.g. to
evaluate your use of our website with regard to the advertisements displayed to
you on their website, to inform other users of theirs about your activities on
our website and to provide further related services. If you do not want
Facebook, Google or Apple to allocate the collected data via our website to your
account with them, you must log out of Facebook, Google or Apple before you
visit our website. To find out more about the purpose and extent to which
Facebook, Google or Apple collects, processes and uses these data, your rights
and the settings available to protect your privacy, please read the Facebook
privacy policy; Google privacy policy; and the Apple privacy policy.

2.7 If you contact us to purchase a product over the phone and you wish to pay
by credit card, you consent to us processing any credit card payment in your
capacity as purchaser of the product notwithstanding whether the credit card
details that you provide to us are your own. If, at your direction, we process a
credit card payment using the credit card details of any third party who is not
the purchaser of the product (the Third Party Payment), you indemnify us for all
liability including all claims, demands or actions the third party may take
against us with respect to the processing of the Third Party Payment.

2.8 Where you use your credit card to purchase an offer on another members
Luxury Escapes account, you take full responsibility for being able to retrieve
and redeem the package, and acknowledge that Luxury Escapes holds no
responsibility in providing the credit card holder their booking confirmation,
without written instructions by the account holder.


3. DIRECT MARKETING

3.1 You consent to Luxury Escapes Using and/or Disclosing any Personal
Information Collected from you for Direct Marketing purposes, whether Collected
via telephone, the Website, or otherwise, but subject to the terms of this
Privacy Policy.

3.2 Unless otherwise provided in this Privacy Policy and in accordance with the
Privacy Act and the Spam Act, Luxury Escapes retains the right to Use and
Disclose your Personal Information for Direct Marketing purposes:

   (a) that has been Collected from you in circumstances where:

   (i) you have provided consent to do so; or

   (ii) it is within your Reasonable Expectations; or

   (iii) where it is impracticable to obtain your consent;

   (b) that has been Collected from any third party in circumstances where:

   (i) you have provided consent to do so; or

   (ii) it is impracticable to obtain your consent.

3.3 In each Direct Marketing communication, we will include a:

   (a) prominent statement appearing on the relevant piece of marketing material
notifying you of your right to Opt Out from further Direct Marketing; and

   (b) simple means for you to Opt Out of receiving further Direct Marketing
communications of that kind.

3.4 Should you Opt Out, we will stop Using and/or Disclosing your Personal
Information for Direct Marketing purposes.

3.5 Luxury Escapes will not Use your Sensitive Information for Direct Marketing
purposes.


4. ENSURING INFORMATION IS ACCURATE AND UP-TO-DATE

We take reasonable precautions to ensure that the Personal Information we
Collect, Use and Disclose is complete, relevant and up-to-date.

However, the accuracy of that information depends to a large extent on the
information you provide. That's why we recommend that you:

   (a) let us know if there are any errors in your Personal Information; and

   (b) keep us up-to-date with changes to your Personal Information such as your
name or address. You may change your personal details by using the relevant
facility on our Website or by contacting the Data Protection Officer as
described in Point 12.


5. HOW WE PROTECT YOUR INFORMATION AND DATA RETENTION

5.1 Luxury Escapes will take reasonable steps to protect the Personal
Information from misuse, interference, loss and unauthorised access or
disclosure. This may include taking reasonable steps to destroy or permanently
de-identify Personal Information once it is no longer needed for any purpose for
which it may be Used or Disclosed in accordance with Australian Privacy
Principal 11.2, subject to the exceptions contained therein.

5.2 Luxury Escapes requires employees and contractors to perform their duties in
a manner that is consistent with Luxury Escapes legal responsibilities in
relation to privacy, including those in this Privacy Policy.

5.3 will take reasonable steps to ensure that Personal Information is only
accessible by people who have a genuine "need to know" as well as "right to
know."

5.4 We keep your Personal Information while your account is in existence or as
needed to provide you with Primary and/or Secondary Purpose. This includes data
you provide to us and data generated or inferred from your use of the Primary
and/or Secondary Purpose.


6. HOW YOU CAN ACCESS, CORRECT OR CONTROL YOUR INFORMATION

6.1 Luxury Escapes will permit its records containing your Personal Information
to be accessed by you when required by the Privacy Act (or General Data
Protection Regulation or other legislation / regulation as applicable). We may,
however, refuse to provide you with access to your Personal Information if one
or more of those matters contained in Australian Privacy Principle 12.3 - Access
to Personal Information – applies, including but not limited to instances in
which:

   (a) we reasonably believe that giving you access to your Personal Information
would pose a serious threat to the life or to the health and safety of any
individual (including you);

   (b) giving access to the information would have an unreasonable impact on the
privacy of any other individual;

   (c) your request for access is frivolous or vexatious or giving such access
will be unlawful

6.2 If Luxury Escapes is satisfied that:

   (a) having regard to the purpose for which the information is held, the
information is inaccurate, out of date, incomplete or irrelevant or misleading;
or

   (b) you (as the person to whom the Personal Information relates) request that
we correct the information;

we will take reasonable steps to correct our records containing your Personal
Information as soon as practically possible in accordance with the Privacy Act.

6.3 If we have refused to grant you access to your Personal Information in
accordance with Point 6.1 above, we will still take all reasonable steps to
provide you with access to your Personal Information in a way that meets both
your needs and our needs.

6.4 If you:

(a) wish to lodge a request for access and/or a copy of your Personal
Information;

(b) wish to correct, edit or update some of your Personal Information in your
account;

   (c) object to the use of or wish to limit the use of some of your Personal
Information;

   (d) wish for us to delete some or all of your Personal Information (i.e. if
it is no longer necessary to provide the Primary or Secondary Purpose); or

(e) otherwise wish for us to withdraw your consent for us to store or your
Personal Information for any reason;

you may do so by contacting Luxury Escapes Data Protection Officer as per the
details in in Point 12.

6.5 Where Luxury Escapes offers online account management facilities, customers
can use this capability to control aspects of their account, including amending
or updating certain Personal Information.


7. OPENNESS

7.1 Luxury Escapes' Data Protection Officer will be the first point of contact
for inquiries about privacy issues. If you wish to make an inquiry or complaint
regarding privacy you should do so by contacting this office as per the details
in Point 12.

7.2 You will find that Luxury Escapes Website contains a prominently displayed
privacy statement and will include a copy of this Privacy Policy.


8. STAYING ANONYMOUS

8.1 Luxury Escapes will not make it mandatory for visitors to its Website to
provide Personal Information unless such Personal Information is required to
answer an inquiry or provide a service. Luxury Escapes may however request
visitors to provide Personal Information voluntarily to Luxury Escapes (for
example, as part of a competition or questionnaire).

8.2 Luxury Escapes will allow its customers to transact with it anonymously or
by using a pseudonym wherever that is reasonable and practicable.


9. TRANSFERRING INFORMATION OVERSEAS

9.1 If we send Personal Information overseas, Luxury Escapes will take steps
which are both reasonable and practicable to ensure that the overseas recipient
handles such information in accordance with the Privacy Act.

9.2 Luxury Escapes may disclose Personal Information to an overseas recipient
without complying with 9.1 if:

   (a) you are Expressly Informed of the intended disclosure of your Personal
Information to the overseas recipient, and you provide consent accordingly; or

   (b) we reasonably believe that the overseas recipient is subject to a law or
a binding scheme that has the effect of protecting the information in a way
that, overall, is at least substantially similar to the way in which the Privacy
Act seeks to protect same and you can access mechanisms to enforce the
protection of your Personal Information under that law or that scheme; or

   (c) the Disclosure is required or authorised by an Australian court or
tribunal or under Australian law.


10. CHANGES TO THE PRIVACY POLICY

Luxury Escapes may, in its sole discretion, update this Privacy Policy at any
time and from time to time. Any changes will be effective when posted on the
Website. Your continued use of the Website will indicate your acceptance of any
changes to the Privacy Policy. All Personal Information, Collected both before
and after any changes take effect, will be subject to the terms of the revised
policy (for which you will be taken to have provided consent) unless you
indicate otherwise by contacting Luxury Escapes' Data Protection Officer as per
the details in in Point 12. We urge you to refer back to this page regularly and
especially prior to providing us with any Personal Information.


11. GLOSSARY

"Collect" means gather, acquire or obtain by a lawful and fair means,
information in circumstances where the individual is identifiable or identified.

"Direct Marketing" involves the Use and/ or Disclosure of Personal Information
to communicate directly with an individual to promote goods or services through
written, verbal or electronic means of communication (including without
limitation communication by email, telephone, SMS or Whatsapp). The goods or
services which are marketed may be those of Luxury Escapes or a Related Body
Corporate or those of an independent third party organisation.

"Disclosure" generally means the release of information outside Luxury Escapes,
including under a contract to carry out an "outsourced function."

"Express Consent Consequences" includes the fact that that we will not be
accountable under the Privacy Act and you will not be able to seek redress under
the Privacy Act in the event that you provide consent to the disclosure of your
Personal Information by us to an overseas recipient and the overseas recipient
handles your Personal information in breach of the Privacy Act.

"Expressly Informed" means the circumstance where we have provided you with a
clear statement (either verbal or in writing) of the Express Consent
Consequences.

"Opt Out" means an individual's expressed request not to receive further Direct
Marketing communications.

"Personal Information" means information that is not Sensitive Information,
including information or an opinion (whether information or an opinion forming
part of a database), whether true or not and whether recorded in a material or
data form or not, about an individual whose identity is apparent, or can
reasonably be ascertained from the information or opinion. This includes, but is
not limited to, an individual's name, address, telephone number and email
address or any other information as set out in this policy.

"Primary Purpose" is the main reason for the Collection of any Personal
Information as described in clause 2.1 of this policy.

"Reasonable Expectation" means a reasonable individual's expectation that their
personal information might be Used or Disclosed for the relevant purpose.

"Related Body Corporate" is given its meaning in the Corporations Act 2001
(Cth).

"Secondary Purpose" means a purpose of Use or Disclosure other than a Primary
Purpose as described in clause 2.2 of this policy.

"Sensitive Information" is given its meaning in section 6(1) of the Privacy Act
1988 (Cth).

"Use" means the handling of Personal Information within Luxury Escapes.

"Website" means the website of LuxuryEscapes.com and related webpages as well as
any website and related webpages of any other website owned or operated by
Luxury Escapes.


12. CONTACTING LUXURY ESCAPES

If you have any questions about this privacy policy, any privacy related
dealings with us or a possible breach of your privacy or would like further
information about our information management practices, you can contact the Data
Protection Officer of Luxury Escapes, care of the following details:

Data Protection Officer Luxury Escapes Travel Pty Ltd Level 4, 68 Clarke Street,
Southbank, VIC 3006 Email: data.protection.officer@luxuryescapes.com

Effective 25 May 2018


THIRD PARTY SOCIAL ASSET USAGE TERMS AND CONDITIONS

Thank you for allowing Luxury Escapes to use your social content. By including
#luxuryescaping or tagging @luxury.escapes you consent for us to repost and
share your social content via other social channels.

Otherwise rights will be requested by Luxury Escapes via commenting on your
Instagram or Facebook and require a response to approve use of your content. To
agree to Luxury Escapes reusing your content simply reply using the hashtag
#YesLuxuryEscapes.

When accepting rights requests you are providing Luxury Escapes or its nominees
with non-exclusive, royalty-free, unlimited rights to use this content in any
manner in which we may decide, including but not limited to social media,
electronic communications, website, blog posts, banners, print material and
other miscellaneous sales and marketing communications and materials.

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