PRIVACY POLICY

1. Welcome Hospitality and Privacy

Welcome Hospitality is one of Australia’s leading hospitality groups. In operating our restaurants, bars, events, and related hospitality businesses, Welcome Hospitality collects and handles personal information. Welcome Hospitality understands the importance of protecting the privacy of an individual’s personal information and being open and transparent in how we handle and deal with personal information. This privacy policy sets out how Welcome Hospitality aims to protect the privacy of your personal information, your rights in relation to your personal information managed by Welcome Hospitality, and how Welcome Hospitality collects, holds, uses, discloses, and otherwise manages your personal information. Welcome Hospitality will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on our website (https://welcomehospitality.com.au/) or can otherwise be obtained by contacting us and requesting a copy.

2. Definitions

In this privacy policy: (a) Privacy Act means the Privacy Act 1988 (Cth); (b) Welcome Hospitality means Welcome Hospitality  Pty Ltd, trading as Welcome Hospitality, and the other entities as set out in Annexure A to this privacy policy; (c) Welcome Hospitality Events means any public, corporate, private, or other events conducted or organised by Welcome Hospitality or any events sponsored by Welcome Hospitality; (d) Welcome Hospitality Venue means the hotels, bars, and other venues operated by Welcome Hospitality; (e) Together with Welcome Hospitality means Welcome Hospitality Pty Ltd, ABN 45 668 729 164, trading as Welcome Hospitality; and (g) We, us, our means Welcome Hospitality.

3. Compliance with Privacy Act

In collecting, holding, using, disclosing, and otherwise managing personal information, Welcome Hospitality will comply with the Privacy Act and the Australian Privacy Principles in the Privacy Act.

4. Collection of personal information

Under the Privacy Act, personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our hospitality and related services or as a result of our other interactions or dealings with you, Welcome Hospitality may collect your personal information. Welcome Hospitality provides a diverse range of hospitality services and experiences. As a result, the kinds of personal information that Welcome Hospitality collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Welcome Hospitality collects may include:

(a) contact and identification information such as your name, address, telephone number, and email address (for example, where you make a reservation at a Welcome Hospitality Venue or join one of our mailing lists);
(b) information regarding your ordering history, food or beverage, or other dining preferences, to assist us in providing a more customised dining experience;
(c) payment information, such as credit card or other payment details;
(d) where you organise or conduct an event using Welcome Hospitality, information regarding the event, your guests, and any relevant requirements;
(e) information regarding your experience at a Welcome Hospitality Venue (for example, as part of our guest feedback activities or where you contact us with feedback); and
(f) where you apply for employment with Welcome Hospitality (in addition to contact and identification information detailed above), information relevant to us considering your application for employment, including information in relation to your CV, employment history, qualifications, and references.

Depending on the Welcome Hospitality Venue you visit, we may also collect identification information, such as driver’s license or passport information. We generally collect this information because we are required to do so by law and/or for venue, patron, and employee security purposes. Specific information regarding the collection and handling of this type of personal information will be available at the relevant venue. Welcome Hospitality also collects CCTV footage at many of Welcome Hospitality Venues, including for venue, patron, and employee safety purposes. Details of suspected or actual illegal or improper conduct (including CCTV footage relating to that conduct) may be shared with relevant law enforcement or regulatory bodies. At some Welcome Hospitality Venues or Welcome Hospitality Events, we may also take photographs or other images or content (such as video or audio recordings). Where we do so, we will provide as much detail as possible regarding why the photographs, images, or other content are being taken and the purposes for which they are being used. By attending such a Welcome Hospitality Venue or Welcome Hospitality Event, you consent to us taking such photographs, images, or other content and using those photographs, images, or other content, including at the venue and on Welcome Hospitality websites and social media sites. Welcome Hospitality may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection. Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record, and religious or philosophical beliefs are all examples of sensitive information. There may be circumstances where Welcome Hospitality does collect sensitive information, for example where we need to collect health information regarding your allergies or in a medical emergency. If we do collect sensitive information about you, we will only do so with your consent or where we are required or authorised to do so by law.

5. Collection of personal information by Welcome Hospitality

Generally, Welcome Hospitality collects your personal information directly from you. For example, Welcome Hospitality may collect your personal information where:

  • you make a reservation for a Welcome Hospitality Venue or a Welcome Hospitality Event;
  • you join one of our mailing lists, fill out a survey, enter a promotion, request services, or otherwise provide us with your details;
  • you dine at or attend a Welcome Hospitality Venue;
  • you stay at any Welcome Hospitality Venue that provides accommodation services;
  • you organise an event with Welcome Hospitality or participate in or attend an event organised by Welcome Hospitality;
  • you sign up to or participate in any Welcome Hospitality loyalty program;
  • you provide feedback to us regarding your experience at a Welcome Hospitality Venue or your other interaction with Welcome Hospitality;
  • you post information to any of our social media sites;
  • you attend a Welcome Hospitality Event; or
  • you apply for or express an interest in employment with us.

We generally collect personal information directly from you. However, there may be occasions when Welcome Hospitality collects your personal information from someone other than you, for example from:

  • other entities within Welcome Hospitality;
  • our service providers or contractors (for example where we appoint a service provider/contractor to assist with conducting an event);
  • an information services provider; a publicly maintained record or other publicly available sources of information, including social media and similar websites; ora referee or previous employer where you apply for employment with Welcome Hospitality.

6. Purposes for which personal information is used

Generally speaking, Welcome Hospitality collects and uses personal information so that we can provide our hospitality services, interact with you in relation to our services and venues, and administer and manage our business and our venues. Some examples of the purposes for which Welcome Hospitality collects, holds, uses, and discloses your personal information include to:

  • take bookings for Welcome Hospitality Venues or Welcome Hospitality Events;
  • provide dining and other hospitality experiences at Welcome Hospitality Venues;
  • provide our event services to you;
  • manage and administer the provision of our services and our relationship with you;
  • maintain venue, patron and employee safety;
  • enable us to supply you with information you request from us;
  • conduct promotions, competitions, giveaways and events;
  • contact you to obtain your feedback regarding our products or services or to conduct other market research;
  • provide you with marketing information regarding Welcome Hospitality and our venues (as further detailed in paragraph 7 below);
  • analyse information we collect so that we can administer, support, and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities using your personal information;
  • comply with the obligations of Welcome Hospitality under any applicable laws; and
  • consider any application you make for employment with us.

In addition to the purposes listed above, Welcome Hospitality may use your personal information for other purposes which we notify you of when we collect the information and for other purposes permitted or required by law. Where personal information is used or disclosed, Welcome Hospitality takes reasonable steps in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed. You are under no obligation to provide your personal information to Welcome Hospitality. However, without certain information from you, Welcome Hospitality may not be able to provide services or information to you or may be limited in how we can interact with you.

7. Direct marketing

In addition to the purposes outlined in item number 6 above, Welcome Hospitality may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products, or services that may be of interest to you. Where you make a booking at a particular Welcome Hospitality Venue or sign up for the mailing list of a particular Welcome Hospitality Venue, this may include sending you information about that Welcome Hospitality Venue or other Welcome Hospitality Venues, Welcome Hospitality Events, or services that may be of interest to you. In doing so, Welcome Hospitality may disclose your personal information to the companies within Welcome Hospitality or other entities with which Welcome Hospitality has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes. These communications may be sent using email, telephone, SMS, social media, or other similar forms of communication. If you do not wish to receive such communications, you can opt-out at any time by contacting Welcome Hospitality via the contact details set out in paragraph 12 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.

8. Disclosure of personal information

Welcome Hospitality discloses your personal information for the purpose for which Welcome Hospitality collects it. As a result, generally Welcome Hospitality will only disclose your personal information for a purpose described in this privacy policy. This may include disclosing your personal information to:

  • the companies or other entities within Welcome Hospitality;
  • our service providers and contractors and other third parties that provide products or services to us (including our technology service providers, data analytics service providers, bookings or reservation systems providers, event service providers, or other business or administration service providers);
  • Welcome Hospitality’s auditors, tax, insurance, legal, or other professional advisors;
  • persons or entities considering acquiring an interest in Welcome Hospitality’s business or assets; or
  • Welcome Hospitality’s insurance providers.

Welcome Hospitality may also disclose your personal information for other purposes where we notify you of the disclosure at or about the time of collecting the information, with your consent or if the disclosure is required or authorized by law. Examples of disclosure that may be required or authorized by law include disclosure to law enforcement bodies, liquor and gaming regulators, or under Anti-Money Laundering and Counter-Terrorism Financing laws. If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

9. Overseas disclosures

Some of the parties that Welcome Hospitality discloses your personal information to may be located outside Australia. We take reasonable steps to ensure that any such overseas recipients do not hold, use, or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.

10. Links to other websites

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website may have its own privacy practices, as described in that site’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party and cannot and are not responsible for any information that you may submit to that site.

11. Cookies and website statistical information

Welcome Hospitality may collect statistical information when you access and use our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser, including cookies and pixel tags. We use this information to analyse how our websites and other online services are being used and seek to improve our websites and other online services and provide more user-friendly and customised websites and online services. These features and technologies do not specifically identify you unless you expressly provide to us personally identifiable information. You may also elect to turn off the internet browser features that allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you.

12. Security of personal information

Welcome Hospitality takes the security and protection of the personal information we hold seriously. We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference, and loss and from unauthorized access, modification, or disclosure. Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorized personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access-restricted premises which only authorized personnel or contractors will be permitted to access. Welcome Hospitality will destroy or de-identify personal information in circumstances where it is no longer required unless Welcome Hospitality is otherwise required or authorized by law to retain the information.

13. Access and correction

Welcome Hospitality takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant, and not misleading. In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Welcome Hospitality. If at any time you would like to access or correct the personal information that Welcome Hospitality holds about you, or you would like more information on Welcome Hospitality’s approach to privacy, please contact Welcome Hospitality Privacy Compliance Officer using the details set out in paragraph 14 below. Welcome Hospitality will grant access to the extent required or authorized by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate. To obtain access to your personal information: * you will have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected; * Welcome Hospitality requests that you be reasonably specific about the information you require; and * Welcome Hospitality may charge you a reasonable administration fee, which reflects and will not exceed the cost to Welcome Hospitality for providing access in accordance with your request. Welcome Hospitality will endeavor to respond to your request to access or correct your personal information within 30 days from your request. If Welcome Hospitality refuses your request to access or correct your personal information, Welcome Hospitality will provide you with written reasons for the refusal and details of complaint mechanisms. If you are dissatisfied with Welcome Hospitality’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

14. Contacting Welcome Hospitality

For further information or enquiries regarding your personal information or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Welcome Hospitality’s Privacy Compliance Officer using any of the following contact details:

Privacy Compliance Officer

Email: info@welcomehospitality.com.au
Phone: 02 9241 2711
Post: Level 4, 189-197 Kent Street Sydney, NSW 2000

15. Privacy complaints

Please direct all privacy complaints to Welcome Hospitality’s Privacy Compliance Officer. At all times, privacy complaints: * will be treated seriously; * will be dealt with promptly; * will be dealt with in a confidential manner; and * will not affect your existing obligations or affect the commercial arrangements between you and Welcome Hospitality. Welcome Hospitality will acknowledge your complaint within 7 days of receipt and endeavor to resolve it within 30 days, unless Welcome Hospitality informs you otherwise and seeks your agreement in writing. Welcome Hospitality will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint or an extension to the time in which Welcome Hospitality will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.

Annexure A: Welcome Hospitality Entities

  • The Trustee for Glenmore Trading Unit Trust – ABN 48394934225, trading as Glenmore Hotel
  • The Trustee for Toormina Hotel Operations Trust – ABN 72612590566, trading as Toormina Hotel
  • The Trustee for Redfern & Co Operations Unit Trust – ABN 42750703203, trading as The Redfern
  • The Trustee for Sawtell Operations Unit Trust – ABN 14743143584, trading as Sawtell Hotel
  • Moonee Beach Hotel Operations Pty Ltd – ABN 16 649 737 342 trading as Moonee Beach Hotel