Privacy Policy

1. WHO WE ARE

1.1 Entrada Travel Group is New Zealand’s leading tourism and transport company. In New Zealand we operate under the InterCity, GreatSights, Gray Line New Zealand, Auckland Explorer Bus and awesomeNZ transport and sightseeing brands.

In Australia we own and operate Tusa Dive, Spirit of Freedom, Spirit of Cairns and Cairns Tourist Information Centre brands.

Details of our legal entities can be found here.

1.2 Together we are the data controllers for the purposes of this policy, which is issued on behalf of all brands and entities within the Entrada Travel Group. When we mention “Entrada Travel Group”, “we”, “us” or “our” in this privacy Policy, we are referring to the relevant entity in the Entrada Travel Group responsible for processing your data.

Here is a list of the legal entities that Entrada Travel Group operates from:

Fully owned:

  • Entrada Travel Group
  • Fullers Bay of Islands Ltd
  • Auckland Explorer Bus Ltd
  • Divers Den Investments Pty Ltd
  • ICG Holdings Australia Pty Ltd
  • Yambay Pty Limited
  • ICG Australia Pty Limited as trustee for SOF Unit Trust
  • Blue Gum Pty Limited

1.3 We also use a network of independent agents and licensees when providing our services around the world. Please note that those agents and licenses are not covered by this Policy and we are not responsible for the privacy practices of any agent, licensee or other third party with whom you may transact before or at the same time as using our products or services.

 

2. THE DATA WE COLLECT ABOUT YOU

2.1 We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

  • Identity Data includes first name, last name, username or similar identifier, title, date of birth, age, gender, dive certification number, security camera recordings and recordings of telephone conversations.
  • Contact Data includes address, telephone numbers and email address.
  • Financial Data includes payment card details.
  • Transaction Data includes details of your previous bookings with us, payments to and from you and other details of products and services you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Location Data includes global position system vehicle tracking and diagnostics (telematics) and other location information obtained from smartphones, tablets, sat-navs or other devices that monitor your current and previous geographic locations.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

2.2 We also collect, use and share Aggregated Data such as statistical or demographic data, which may be derived from your personal data but is not personal data as it does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat that combined data as personal data which will be used in accordance with this Privacy Policy.

2.3 We do not collect any Sensitive Data about you (such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). We do not collect any information about criminal convictions and offences.

2.4 Refusal to provide your personal data: You do not have to provide your personal data when we request it, but if you choose not to, we may not be able to respond to your queries and perform any contract we have or are trying to enter into with you (for example, completing pre dive safety registrations). That may mean we have to cancel a product or service you have with us. We will notify you at the time if that is the case.

 

3. HOW WE COLLECT YOUR PERSONAL DATA

3.1 We use different methods to collect personal data from and about you including through:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our websites and mobile applications, on third-party websites or in paper form or by corresponding with us by post, phone, email or otherwise. That includes personal data you provide when you:
    • make an inquiry or booking with us or otherwise apply for any of our products or services
    • purchase a product or service from us
    • create an account on our website or mobile applications
    • subscribe to our services or publications
    • request marketing to be sent to you
    • enter a competition, promotion or survey (including on third party social media platforms)
    • give us feedback
    • enter our premises on which security cameras are operating
    • speak to us on the telephone
  • Automated technologies or interactions. As you interact with our website and mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy here  for further details. We may combine Technical Data (some of which will be anonymous) with other personal data we have collected from you in order to understand and measure your online experiences and determine what products, promotions and services are likely to be of most interest to you.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties and certain public and technical sources:
    • Technical Data from analytics providers such as Google and advertising networks such as Facebook and Identity, Location and Vehicle Sourced Data when using our vehicles.
    • Identity and Contact Data when you make a booking or apply for our products or services through a third party (such as a travel agent), through interactions (including transactions) with our service providers, business partners, agents, affiliates and subsidiaries (including other travel providers and insurance companies), from data brokers or aggregators such as Facebook and from publicly availably sources such as phone directories, membership lists, professional and trade associations, government, bankruptcy or court registry searches and electoral registers.
  • Unsolicited personal data. If we receive personal data that we have taken no active steps to collect (such as a job application sent to us by an individual on their own initiative, rather than in response to an advertisement), then we may keep that personal data if it is reasonably necessary for one or more of our functions or activities. We will destroy it or ensure it is de-identified, provided it is lawful and reasonable to do so.

 

4. How and why we use your personal data

We will only use your personal data when the law allows us to and typically only in the circumstances and for the purposes set out in the table below. Please see the Glossary for an explanation of the expressions used in the table.

Purpose/Activity Type of data Lawful basis for processing
New customers: To register you as a new customer and to respond to your inquiries and any complaints (a) Identity
(b) Contact
(c) Profile
Performance of a contract with you
Facilitate bookings: To provide and store quotes for retrieval and to process bookings including:

  • managing payments, fees and charges
  • collecting and recovering money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
Provide services: To provide our services to you, including:

  • operating bus and ferry services
  • operating guided tours and cruises
  • operating snorkeling and dive tours
(a) Identity
(b) Contact
(c) Medical
(d) Profile
(e) Financial Transaction
(f) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
(c) Perform safety checks prior to dive or snorkel activity
Relationship management: To manage our relationship including:

  • notifying you about changes to our terms or Privacy Policy
  • asking you to leave a review or take a survey
  • keeping you up to date with our latest news
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
Improve services: To constantly improve our products and services, tailor them to your needs, develop new product/service ideas and inform you of any changes to our products/services (a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to keep developing and improving our products/services in line with customer expectations)
Promotions:
To enable you to:

  • participate in prize draws, competitions and giveaways
  • know about special offers and promotions, including on social media
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
Technical maintenance:
To administer and protect our business, content, websites and mobile apps including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data and monitoring for unauthorised use
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Marketing and Communications
(f) Transaction
(g) Location
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and to prevent fraud)
(b) Necessary to comply with a legal obligation
(c) Performance of a contract with you
Advertising:
To deliver relevant website content and advertising to you and measure the effectiveness of our advertising
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
Necessary for our legitimate interests (to define types of customers for our products/services, to keep our website updated and relevant, to develop business and to inform our marketing strategy)
Data analytics:
To perform data analysis to:

  • improve and personalise your experience on our platforms
  • improve our products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
(c) Identity
(d) Profile
(e) Marketing and Communications
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
Promote our products and services:
To make suggestions and recommendations to you about goods or services that may be of interest to you
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Location
(g) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
Provide location information: to enable realtime vehicle location information relative to your position (Passenger App) (a) Identity
(b) Contact
(c) Technical
(d) Location
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation