Privacy Policy

Our privacy pledge to you

We understand that privacy is important to you – it is to us too. That’s why we respect your personal information and are committed to protecting it when providing products and services to you.

The purpose of this Privacy Statement

This Privacy Statement describes the personal information that may be collected by Villa Sintra Bali (‘VSB’, ‘we’ or ‘us’), comprising of Villa Sintra Bali and all of its owned or controlled Australian and Indonesian entities and businesses, including Villa Sintra Bali, Casa Sintra Bali. The choices you can make about your personal information and how we protect your information is also described within this Statement.

If you would like a printed version of this Statement, you can print this page using your browser, or contact us for a copy. Our contact details are listed at the end of this Statement.

Meeting our privacy obligations

Villa Sintra Bali complies with:

• Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Privacy Act);
• Australian Direct Marketing Association (ADMA) Code of Practice in relation to how we market to our customers;
• Spam Act 2003 in relation to electronic marketing; Do Not Call Register Act 2006 where we engage in telemarketing;
• and Telecommunication (Telemarketing and Research Calls) Industry Standard 2017 where we engage in telemarketing.

If you have any questions not addressed in this statement, please feel free to contact us using the methods at the end of this statement under the heading “How to contact Us”.

You acknowledge that you’ve had the opportunity to read and understood this Statement.

This Statement is intended to explain how we comply with the law not to expand your rights with us or our obligations to you beyond the laws listed above. If anything in this statement does not match the law (e.g. the law or the interpretation of the law changes) this Statement should always be interpreted to reflect and comply with the current law. This statement includes examples but is not intended to be restricted in its application to such examples. Where the word ‘including’ is used, it means ‘including without limitation’.

Our websites may contain links to non-Group websites. We are not responsible for the privacy policies of those other websites. We recommend you review the privacy policies of each site you visit.

‘Personal information’ means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether or not that information or opinion is true or recorded in a material form.

When you give us your personal information, it imposes a serious responsibility on us. Protecting your privacy when handling your personal information is very important to us and is fundamental to the way we serve you.

We may collect your personal information when you:

• deal with us over the telephone or over web chat;
• purchase a product or service on our website (villasintrabali.com or casasintrabali.com;
• register for, or use, our online products and services;
• email us;
• create an account with us;
• participate in an online promotion;
• provide us with feedback;
• complete an online survey;
• contact, register with, post to, like or follow any of our social media websites, pages, forums or blogs; and ask us to contact you.

We will collect personal information by lawful and fair means.

Depending on the product or service, if you choose to not provide your personal information when requested, we may not be able to deliver the product or service that you have requested. We will endeavour to make this as clear as possible for each product and service.

In some cases, where it makes sense and is lawful, you can interact with us anonymously or by using a pseudonym (an alias). We will endeavour to make this option clear when it is available to you.

Information collected

We collect different personal information depending on the product or service that you have requested. Some common examples include:

Unsolicited information

“Unsolicited” personal information is personal information about an individual that an organisation has unintentionally received. This is an uncommon occurrence for the Group, but when it does happen, we will protect your personal information with the same rigour as we treat personal information that we intended to collect. If we could not have collected this information through our normal processes, we will de-identify that information as soon as we can.

The primary reason we collect, use and share your personal information is to enable the delivery of our products and services to you and to conduct analysis to assist the design and improvement of our products and services

Product/Service notifications and messages

We may contact you periodically to advise you of new or enhanced functionality which is available in connection with our products and services. You will not be obliged to adopt any such functionality.

Where your personal information has been previously obtained by us through the course of providing you with our products or services (including when you make a purchase from a merchant who uses our services to deliver your order), we may: keep and use this information to provide you with service messages (e.g. tracking messaging telling you and merchants where your order is and where and when to expect delivery); in the course of improving our processes, products and services; and in keeping our people, you and the community safe.

We will only use this information to communicate directly with you where that communication is reasonably expected or necessary Third party disclosure

When we temporarily make your personal information available to companies who perform services for us – such as specialist information technology companies, cloud service providers, or other contractors to Villa Sintra Bali – we require those companies to protect your personal information as diligently as we do. Strict contractual and other quality assurance measures are used to ensure your personal information is protected.

We have a duty to maintain the privacy of all personal information we hold about you. However, certain exceptions apply – for example, where disclosure of your personal information is: authorised or required by law (e.g. disclosure to various government agencies such as the Australian Taxation Office, Centrelink, Child Support Agency, or disclosure to courts under subpoena). in the public interest (e.g. where a crime, fraud or misdemeanour is committed or suspected and disclosure in the circumstances is justified). For example, to AUSTRAC to satisfy anti-money laundering or counter-terrorism financing obligations, or to ACIC, State, Federal Police or Border Force for crime related investigations. with your consent – your consent may be implied or express and may be verbal or written.

We may also use the information you have provided us for a range of other purposes including: Product design, development and improvement

We are always seeking to improve the way our products and services are delivered and developed. We may use your personal information to help us: better understand the needs of our customers, the community and you through analysis so that we and third parties can develop better and more efficient products and services; conduct market research to ensure we are and continue to meet your needs; providing you with the information, products and services which are relevant and tailored to you; analyse, enhance, match and aggregate information to improve your user experience and to enable us to develop new or enhanced functionality for you; and enabling us, or our third-party business partners, to conduct identity assurance and verification services and identify and prevent fraud.

The insights or analysis products and services we develop may be shared with business and commercial partners. Where we share insights or analysis products and services outside of Villa Sintra Bali we endeavour to ensure these are non-identifiable and/or de-identified form. If we share information about you which identifies you as an individual we will only do so in compliance with the law and/or your consent.

Improving service to our customers

From time to time we use statistical and other scientific methods, processes and systems to extract knowledge and insights from information we hold in order to improve our services, services to our customers, for the prevention of fraud and breaches of law and to keep our people, the community and you safe.

The implementation of these techniques provide high level insights into performance, trends and patterns to improve:

• the safety for our people & the community;
• the customer experience and relevance of our services and products;
• service performance of our network, staff and business practices;
• and commercial outcomes for the business.

We use data aggregates, statistics and de-identified data and information from a variety of sources within the Group and outside Group to derive these insights.

Treatment of personal information with subsidiaries

The Group can disclose personal information (excluding sensitive information) between subsidiaries and controlled entities as long as the purpose for sharing is related to the reason the personal information was originally collected. This excludes subsidiaries that are outside of Australia. Under these same terms, subsidiaries can share personal information with Villa Sintra Bali.

Overseas use and disclosure

Villa Sintra Bali will take reasonable steps to protect your personal information no matter what country it is stored in or transferred to. We have procedures and data transfer arrangements in place as appropriate to help ensure this.

Villa Sintra Bali uses service providers in other countries, including: Indonesia, China, United States of America, New Zealand and Taiwan.

From time to time we may use the personal information we collect from you to identify particular Group products and services or non-Group products and offers which we believe may be of interest to you. We may contact you to let you know about these products and services and how they may benefit you.

You may give us your consent in a number of ways including by selecting a box on a form where we seek your permission to send you marketing information, or sometimes your consent is implied from your interactions or relationship with us. Where your consent is implied, it is on the basis that you would have a reasonable expectation of receiving a marketing communication based on your interactions or relationship with us.

Direct Marketing from the Group generally takes the form of direct mail, electronic marketing or telemarketing, but may also include other less traditional or emerging channels. These forms of contact will be managed by the Group, or by our contracted service providers with oversight by the Group.

Every directly addressed marketing form sent or made by Villa Sintra Bali or on Villa Sintra Bali’s behalf should include a means by which customers may unsubscribe (or opt out) of receiving similar marketing in the future.

You can ask us to remove or amend any previous consent you provided by directing your request to the Group Privacy Contact Officer via the channels provided under ‘How to contact us’.

You can ask us to give you access to your personal information other than where there is an exception at law.

Villa Sintra Bali will, upon your request, and subject to applicable privacy laws, provide you with access to your personal information that is held by us. However, we ask that you identify, as clearly as possible, the type (or types) of information requested. The Group will deal with your request in a reasonable time – usually within 30 days.

Exceptions

Your right to access your personal information is not absolute. In some circumstances, the law permits us to refuse your request to provide you with access to your personal information. For example, where giving access to your information would have an unreasonable impact on the privacy of other individuals, or would pose a serious threat to the life, health or safety of any individual or to public health or public safety.

Freedom of information laws

In addition to privacy laws, you may have rights to access your personal information contained in certain Group documents. Details on how to apply for access to these documents are contained in the Freedom of Information Act 1982.

More information is available at the Office of the Australian Information Commissioner’s freedom of information pages.

It is inevitable that some personal information which we hold will become out of date. We will take reasonable steps to ensure that the personal information which we hold remains accurate and, if you advise us of a change of details, we will amend our records accordingly.

Where your information has been disclosed to a third party, Villa Sintra Bali will take reasonable steps to notify the third party of the correction.

Where we are unable to update your information, we will provide an explanation in writing as to why the information cannot be corrected.

Villa Sintra Bali is committed to protecting and securing your personal information.

We employ technical, administrative and physical procedures to protect personal information from unauthorised disclosure, loss, misuse or alteration.

We limit access to your personal information to individuals with a business need consistent with the reason the information was provided. We keep personal information only for as long as it is required for business purposes or by law.

The Group protects your personal information by complying with Information Security Standards, Industry Schemes and statutory obligations. We regularly conduct targeted internal and external audits on our security systems to validate the currency of our security practices.

We understand that you may be concerned about the security of the personal information we collect from you online.

Accordingly, we have systems in place to ensure our online dealings with you are as secure as your dealings with us in person, or on the telephone.

In those instances where we secure your personal information in transit to us and upon receipt, we use industry standard encryption software, Secured Socket Layer (SSL) 128 bit encryption. The URL in your browser will change to “HTTPS” instead of “HTTP” when this security feature is invoked. Your browser may also display a lock symbol on its bottom task bar line to indicate this secure transmission is in place.

We employ security programs and services to monitor network traffic in order to identify attempts to breach our security.

Information collected on our websites

We may collect non-personal information from you such as browser type, operating system, and web pages visited to help us manage our web site.

We use cookies (see below) and other internet technologies to manage our website and certain online products and services. We do not use these technologies to collect or store personal information unless you have opted into such a feature. Where you’ve logged into our website we may reflect the products and services you use with your on-line behaviour to provide content that is of more interest to you.

Our internet server logs the following information which is provided by your browser for statistical and content optimisation and personalisation purposes:

• the type of browser and operating system you are using
• your Internet Service Provider and top level domain name (for example – .com, .gov, .au, .uk)
• the address of any referring website (for example – the previous web site you visited),
• and your computer’s IP (Internet Protocol) address (a number which is unique to the machine through which you are connected to the internet).

Cookies

A “cookie” is a packet of information stored on your computer that allows the Villa Sintra Bali server to identify and interact more effectively with your computer.

Our websites use two different kinds of cookies:

• Session cookies – temporary cookies that only last until you close your browser
• Persistent cookies – cookies that are stored for a longer term on your computer.

Session cookies

When you access our web site, we send you a temporary cookie that gives you a unique identification number. A different identification number is sent each time you use our website. Cookies do not identify individual users, although they do identify a user’s internet browser type. When you close your browser, the cookie is deleted and no longer exists on your computer.

You are free to disable cookies in your browser (see details below). If you have disabled cookies you may not be able to take full advantage of all of our website features.

We use session cookies in the following manner:

Log-on and log-off administration – Session cookies help with the log-on and log-off processes for those users who have decided to register to use one of our online services. The cookies enable us to recognize your user ID when you log on so that we do not establish a duplicate registration record for you. Transactions and site usability – We use session cookies to improve how you navigate through our website and conduct transactions. As examples, session cookies are used to maintain your online session as you browse over several pages; to store and pre-populate information so that you do not have to re-enter the same information twice. Session cookies may also be used to collect referral statistics when you click on a link or ad banner to or from villasintrabali.com, and associated websites.

Persistent cookies

The Group may also use “persistent cookies”. A persistent cookie is a small piece of text stored on your computer’s hard drive for a defined period of time, after which the cookie is erased.

We use persistent cookies as follows:

• Site usage measurement – Our site measurement tool uses a persistent cookie to assist us in measuring how and when our web site and its various components are used. It functions as a “visit cookie,” so we can determine if you are a repeat visitor to our site. This allows us to know if we are attracting new visitors and what aspects of the site seem most useful. The cookie will expire 30 days after your last visit.
• Log-off safety function – Villa Sintra Bali uses a persistent cookie to automatically log you off certain Villa Sintra Bali sites if there has been no activity for 15 minutes. This is done for your safety to ensure that, if you have finished using our site but have forgotten to log off, no one else can use your computer via your log on and password. The cookie is permanently removed from your computer when you log off, or, if you have closed the browser without logging off, it is removed within 15 minutes from your last activity.
• Longer-term cookies – Persistent cookies allow us, at your request, to recognise you when you return to villasintrabali.com or to remember certain information that you have provided us. The recognition feature allows you to log on to certain Villa Sintra Bali sites automatically, without having to enter your name and password each visit. The cookie assigns a random number to you, and allows us to track your site activity, but this is not linked to personal information. This allows us to personalise the site for you and tailor the content to your needs, for instance to show you banner ads about products you may be interested in.
• Click stream data – “Click stream data” is information which is derived from an analysis of your website activity based on the sequence of links which you click on while browsing our Website. When you visit the Website or use our products and services, we will collect this information for analysis, maintenance or reporting purposes and to improve the performance of our Website. This can include information such as your IP address, the duration of your visit and the date and time of your visit.
• Other cookies allow us to remember certain information related to prior transactions, such as package tracking numbers, or mailing or address lists, so we may pre-populate those fields for you on return visits.

Cookie Management

You can configure your internet browser to accept all cookies, reject all cookies or notify you when a cookie is sent. Most browsers accept cookies by default. To learn more about cookies, including how to refuse cookies on your computer, click these links:

• Microsoft Internet Explorer
• Mozilla FireFox
• Google Chrome
• Apple Safari
• Links to other sites

The Villa Sintra Bali site contains links to other sites. We are not responsible for the privacy practices or the content of such websites. We encourage you to read and understand the privacy policies on those websites prior to providing any information to them.

Some of the content appearing on the Villa Sintra Bali website may be supplied by third parties, for example, by framing third party web sites or the incorporation through “framesets” of content supplied by third party application service providers. In such cases, Villa Sintra Bali will ensure that our contractual arrangements with these third parties protect your personal information in compliance with privacy laws.

Searches

Search terms that you enter when using our search engine are collected, but are not associated with any other information that we collect. We use these search terms for the purpose of aggregated statistical analyses so we can ascertain what people are looking for on our website, and to improve the services that we provide.

We may use external entities to provide us with detailed aggregate statistical analyses of our website traffic. At no time is any personal information made available to these entities, nor is the aggregate information ever merged with personal information such as your name, address, email address or other information you would consider sensitive or would compromise your privacy.

Geolocation

GeoLocation is used on our Shopping Cart checkout tool located on our website. When a user engages with Geolocation (opt in) via a browser notification, we retain basic information such as IP address, which translates to a location, browser version and device. No identifiable personal information is captured through this process. Users of the Shopping Cart tool on will be asked, via their individual browser, if they are willing to allow villasintrabali.com to know their location. If users do not accept, then no data is shared.

Despite our every effort to protect your personal information, there remains the possibility that a privacy related incident could occur. In the event of loss of personal information Villa Sintra Bali will:

• seek to rapidly identify and secure the breach to prevent any ongoing breaches;
• assess the nature and severity of the breach including the type of personal information involved and the risk of serious harm to affected individuals;
• notify the affected individuals directly if appropriate;
• notify the Privacy Commissioner (at the OAIC) if the breach is significant;
• engage the appropriate authorities where criminal activity is suspected;
• and if appropriate, put a notice on our website advising our customers of the breach

Villa Sintra Bali believes it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to participate in and monitor their online activity.

When we provide a product or service that intentionally collects personal information from children, we will give a notice specifying what information we are requesting, how we will use it, whether it will be shared with a third party, and a contact at Villa Sintra Bali for questions. We will utilise the information only for the particular purpose for which it was given to us.

We will use reasonable efforts to determine parental consent prior to the collection and use of personal information from children under 16. The method of verification may vary according to the information, product, service or event in which the child wishes to participate. Consent may take a variety of forms including offline consent such as printing and submitting a permission form by mail or fax, or online consent such as by ticking an online check box that parental or guardian consent has been obtained.

We do not require parental or guardian consent in order to collect and use online or offline contact information to:

• respond directly to a child’s request on a one-time basis, or to answer a specific request, where the information is not intended to be used to re-contact the child for other purposes
• request the name or on-line contact information of a parent/guardian for the sole purpose of obtaining verifiable parental consent or providing parental notification
• respond directly more than once to a specific request from a child and the information is not intended to be used to recontact the child beyond the scope of the request

Villa Sintra Bali will allow parents or guardians to review any personal information collected from their children, subject to verifying the identity of the consenting parent/guardian.

Parents/guardians may, at their discretion, revoke their consent and delete information collected from their children.

To contact us with a compliment or complaint or a privacy question, you can:

write to us at:
Villa Sintra Bali Privacy Contact Officer
PO Box 319
Labrador QLD 4215

call us at our Customer Contact Centre on +61 7 5655 4376 between 10:00am and 4:00pm AEST Monday to Friday.

We may change this Privacy Statement from time to time. If we do we will post changes to the Privacy Statement and publish the effective date when this statement is updated.

The one you are now reading was updated in October 2021

Further information on privacy

You can obtain further general information about your privacy rights and Commonwealth privacy law from the Office of the Australian Information Commissioner by:

calling their Privacy Hotline on 1300 363 992
visiting their web site at http://www.oaic.gov.au/
writing to:
The Australian Information Commissioner
GPO Box 5218
Sydney NSW 1042