Privacy Policy

In this Privacy Policy (“Policy”), ‘us’ ‘we’ or ‘our’ means Spencer Group of Companies Pty Ltd ABN 97 083 694 704. We are committed to respecting your privacy. Our Policy sets out how we collect, use, handle, store and disclose your personal information. We are bound by the Australian Privacy Principles contained in the Privacy Act and by various other state and territory privacy and data protection legislation, to the extent that they apply to us.

By providing personal information to us (or allowing another person to do so on your behalf), you consent to our collection, use and disclosure of your personal information in accordance with this Policy and any other arrangements that apply between us. We may change our Policy from time to time by publishing changes to it on our website. We encourage you to check our website periodically to ensure that you are aware of our current Policy.

If you do not agree with any part of this Policy, you must not provide your personal information to us, but this may affect the services we can provide to you.

In this Policy, where we say “disclose”, this includes, without limitation, to transfer, share, send, or otherwise make available or accessible your personal information to another person or entity.

What is personal information?

Personal information includes information or an opinion about an individual that is reasonably identifiable. 

How do we collect personal information?

We may collect personal information directly from you, or from third parties. This collection may occur when you, or another person on your behalf:

  • enquire about or sign up for our services;
  • communicate with us through correspondence, chats, email, or when you share information with us from other social applications, services or websites; or
  • interact with our sites, services, content and advertising.

Where a third party discloses your personal information to us we will assume that you have consented to this disclosure and to your personal information being handled in accordance with this Policy. You should let us know immediately if you become aware that your personal information has been provided to us by another person without your consent.

What personal information do we collect?

Generally, the type of personal information we collect is the information we need to facilitate your travel arrangements and bookings and to arrange travel-related services and products on your behalf. For example, we may collect the following types of personal information:

  • name;
  • residential address;
  • mailing address;
  • telephone number;
  • email address;
  • credit/debit card details (including card type, card number, security number and expiry date);
  • age or date of birth;
  • sex or gender;
  • passport details;
  • frequent flyer details;
  • dietary requirements and health issues (if any);
  • device ID, device type, geo-location information, computer and connection information, statistics on page views, traffic to and from the sites, ad data, IP address and standard web log information;
  • details of the products and services we have provided to you or that you have enquired about, including any additional information necessary to deliver those products and services and respond to your enquiries;
  • any additional information relating to you that you provide to us directly through our website, any software we may provide or indirectly through your use of our website, services or online presence or through other websites or accounts from which you permit us to collect information;
  • information you provide to us through customer surveys; and
  • any other personal information that may be required in order to facilitate your dealings with us and our related entities.

We may also collect sensitive information from you. Sensitive information includes types of personal information such as your racial or ethnic origin, religious beliefs or affiliations, criminal record and health information. We will only collect sensitive information with your consent and where reasonably necessary . For example, if you provide health information to us in connection with a travel insurance application you would like to make, you consent to us using and disclosing that health information in connection with arranging that travel insurance on your behalf.

In addition, when you apply for a job or position with us we may collect certain information from you (including your name, contact details, working history and relevant records checks) from any recruitment consultant, your previous employers and others who may be able to provide information to us to assist in our decision on whether or not to make you an offer of employment or engage you under a contract. This Policy does not apply to acts and practices in relation to employee records of our current and former employees, which are exempt from the Privacy Act.

When we act as agent

When we provide services to you, we usually do so as agent for or on behalf of third parties, such as travel service providers. This means that we usually collect personal information about you for our internal purposes (e.g. to process your booking), and on behalf of third parties, for whom we act as agent, for their internal purposes (e.g. to provide the booked services). Accordingly, the consent you provide under this Policy to the collection and use of personal information by us, applies equally to the parties whose products and services we provide. For example, if you purchase a flight from us, then under this Policy you will have consented to us providing your personal information to the airline to enable your flight to be booked.

It is not practical for us to set out in this Policy all of the third parties for whom we act as agent nor exactly how each of these third parties may use your personal information. If you wish to contact us for further information regarding the third parties for whom we act as agent, please contact us using the details in the Contact Us section below.

Why do we collect, use and disclose personal information?

We may collect, hold, use and disclose your personal information for the following purposes:

  • to enable you to access and use our website and/or services;
  • to operate, protect, improve and optimise our website and/or services, our business, and our users’ experience, such as to perform analytics, conduct research and for advertising and marketing;
  • to send you service, support and administrative messages, reminders, technical notices, updates, security alerts, and information requested by you;
  • to send you marketing and promotional messages and other information that may be of interest to you, including information sent by, or on behalf of, our business partners that we think you may find interesting;
  • to administer rewards, surveys, contests, or other promotional activities or events sponsored or managed by us or our business partners;
  • to comply with our legal obligations, resolve any disputes that we may have with any of our users, and enforce our agreements with third parties;
  • to consider your employment application;
  • identification of fraud or error; regulatory reporting and compliance; and
  • Any other purposes as permitted or required by law (e.g. to prevent a threat to life, health or safety).

We may also disclose your personal information to a trusted third party who also holds other information about you. This third party may combine that information in order to enable it and us to develop anonymised consumer insights so that we can better understand your preferences and interests, personalise your experience and enhance the products and services that you receive.

We only store your personal information for as long as necessary. We may delete your personal information after a reasonable period of time and, if you have not used our services for some time, you may have to re-enter or re-supply your personal information to us.

Do we use your personal information for direct marketing?

We and/or our carefully selected business partners may send you direct marketing communications and information about our services and products. This may take the form of emails, SMS, mail or other forms of communication, in accordance with the Spam Act and the Privacy Act. You may opt-out of receiving marketing materials from us by contacting us using the details set out below or by using the opt-out facilities provided (eg an unsubscribe link).

To whom do we disclose your personal information ?

We may disclose personal information for the purposes described in this Policy to:

  • our employees and related bodies corporate;
  • third party suppliers and service providers (including providers for the operation of our websites and/or our business or in connection with providing products and services to you, such as travel service providers, including travel wholesalers, tour operators, airlines, hotels and car rental companies);
  • professional advisers, dealers and agents;
  • payment systems operators (eg merchants receiving car payments);
  • our existing or potential agents, business partners or partners;
  • our sponsors or promoters of any competition that we conduct via our services;
  • anyone to whom our assets or businesses (or any part of them) are transferred;
  • specific third parties authorised by you to receive information held by us; and/or
  • other persons, including government agencies, regulatory bodies and law enforcement agencies, or as required, authorised or permitted by law.

Third parties to whom we disclose your personal information may also be taken to have collected your personal information in their own right, for their internal use. For more information in relation to collection by travel service providers, see the heading above titled “When we act as agent”. Where we engage travel service providers to perform services for us, those travel service providers may be required to handle

your personal information. Where we disclose your personal information to such travel service providers, you agree that we will not be required to ensure their compliance with applicable privacy laws or otherwise be liable or accountable for how they handle your personal information.

Disclosure of personal information outside Australia

When you provide us with, or otherwise allow us to collect, your personal information, you consent to your personal information being disclosed outside of Australia to third parties we do business with. Where we disclose your personal information to an overseas recipient, you agree that we will not be required to ensure the recipient’s compliance with Australian Privacy Laws or otherwise be liable or accountable for how the recipient handles your personal information.  

Security of information

We may hold your personal information in either electronic or hard copy form.  We have implemented various physical, electronic and managerial security procedures in order to protect personal information from loss and misuse, and from unauthorized access, modification, disclosure and interference.

We regularly review security and encryption technologies and strive to protect your personal information as fully as we protect our own confidential information. However, we cannot guarantee the security of your personal information.

Access to and correction of personal information

Subject to any exceptions set out in applicable privacy laws, you can access any personal information we may hold about you. Where personal information we hold about you is not accurate, complete, up-to-date or relevant, you may ask us to correct that personal information, and we will respond to your request within a reasonable time. We reserve the right to confirm the identity of the person seeking access or correction to personal information before complying with such a request. If we deny access or correction, we will provide you with the reason for such denial. You must always provide accurate information and you agree to update it whenever necessary. You also agree that, in the absence of any update, we can assume that the information submitted to us is correct. If you wish to access or seek correction of any personal information we hold about you, please contact us using the details in the Contact Us section below.


A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We may link the information we store in cookies to any personal information you submit while on our website. Cookies save data about individual visitors to the website, such as the visitor’s name, password, username, screen preferences, the pages of a site viewed by the visitor, and the advertisements viewed or clicked by the visitor. We use cookies to identify a visitor’s browser, to anonymously track visits or to enhance the experience of our website. We will handle any personal information collected by cookies in the same way that we handle all other personal information as described in this Policy.  You can disable cookies through your internet browser but our websites may not work as intended for you if you do so..

3rd Party Tracking

The use of cookies by our partners, affiliates, tracking utility company or service providers is not covered by our Policy. We do not have access or control over these cookies. We do not tie the information gathered to our customers’ or users’ personal identifiable information.

Linked Sites

Our website may contain links to third party sites over which we have no control. We are not responsible for the privacy practices or the content of such web sites. We encourage you to read the privacy policies of any linked sites you visit as their privacy policy and practices may differ from ours.

Feedback / Complaints / Contact

If you have any enquiries, comments or complaints about this Policy or our handling of your personal information, please contact your consultant or email us at

Please include your name, email address and/or telephone number and clearly describe your enquiry, comment or complaint.

We will respond to any complaints received as soon as practicable.

Effective: 24 April 2024