Privacy Policy and Cookies
We respect and are committed to protecting your privacy, and that is why we have created this Privacy Policy.
Smartie is the Data Controller of the information you provide us.
By using our Website (Platform), registering and subscribing to our services or entering into an agreement with us in relation to the Website or our service, you are taken to have read, and agreed to the collection, use, disclosure and handling of your Personal Information in accordance with this Privacy Policy.
This Privacy policy applies to online travel-related services via our website, mobile application or social media and also to such services by our partners.
For more information about our services, please read the Terms and Conditions.
You can contact us for general data protection queries by email to the Data Protection Officer at sales@smartie.com.
We reserve the right to modify this Policy at any time by notifying site users in this section of our site. You agree that such notification will constitute sufficient and adequate notice to you of the changes. You agree that your continued use of our services after such amendment will constitute your acceptance of and agreement to be bound by the amended policy.
Last updated: January 15th, 2019
What kinds of personal information do we collect?
We collect information about you when you provide it to us, including when you create an online account, register, subscribe, respond to one of our promotions, order, use or register your interest in one of our service. This could be via your computer browser, via an app, by telephone, or by email.
When you make a reservation or use our service we can collect and use: name, email address, home address, telephone number, payment information, location, the names of guests travelling with you and your personal information related to certain social media.
We collect information from and about the device you are using when you interact with our website, apps or other services. This may include: device type, device operations, unique identifiers (device IDs), device settings, network/connections (your IP address).
Use of Personal Information
We collect personal information about you for the purpose of delivering and improving the website and the services we provide and to improve and develop our relationship with you.
We use the personal information we collect:
• to send you emails, notices, information, appreciation, promotions and updates including marketing and advertising materials in relation to our services and those of third party organizations/partners selected by us;
• to assist in providing our services: reservations, customer service, guest reviews, user account administration and fraud detection and prevention;
• to promote, improve and facilitate our services via social media, including registration on our website with your social media account;
• to verify and process payment when you purchase services from us;
• for verification of your identity and assisting you in case you forget your password or login details for our subscription services; and
• for any other uses that you authorise or request.
Disclosure of Information
We may disclose your personal information in order to complete our services or in other specific circumstances:
- to the accommodation providers, subsidiaries of the Smartie corporate family, our parent company (Jasons.com) and the other members of the Jasons and Explore corporate group (Jasons.com, Jasons.co.nz, Jasons.com.au).
- to the Third-party service providers for purposes such as facilitating reservation payments, sending out marketing material or for analytical support services. These processors are limited by confidentiality clauses and are not allowed to use your personal information for their own purposes or any other purpose.
- to our Business partners whose services are integrated into our website or they have been enabled to show a customised advertisement on our website. When you make a reservation on a business partners’ website, please read the privacy policies on these business partners’ websites for more information.
- to any organisation for any authorised purpose with your express consent;
- to other registered users of our Website, regarding the provision of our services;
- to third parties when we believe in good faith that we are required to do so by law (competent authorities, law enforcement and other governmental authorities).
After your stay at any accommodation related to our service, you can submit a guest review about the accommodation, the surrounding areas, and the destination. When submitting guest review you can use your name, nickname or you can remain anonymous. By completing a guest review, you are agreeing that it can be published on the connected accommodation information page on our websites, in our mobile apps, in our social media accounts and in social apps, or on the website of the connected accommodation or on our partner’s website. Purpose of submitting guest reviews is to inform other visitors about the quality and services at the accommodation you stayed in.
How is your information protected?
We will take reasonable steps to ensure that personal data are protected from unauthorized access, misuse of personal data and other similar risks.
All information gathered by Smartie is stored in systems that may only be accessed by authorised staff.
We review and update our security measures in light of current technologies. Unfortunately, no data transmission over the internet can be guaranteed to be absolutely secure.
Cookies
We may also collect your personal data through the use of cookies and other tracking devices and similar technologies (hereafter together referred to as “cookies”). When you access our website, we may send a “cookie” (small summary file containing a unique ID number) to your device. This helps us to recognise your device and greet you each time you visit our website, without bothering you with a request to register or log-in. It also helps us keep track of services you view, so that we can send you news about those services. We also use cookies to measure traffic patterns, to determine which areas of our websites have been visited, and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our online services.
If you do not wish to receive (certain) cookies, you can set your browser so that your device does not accept them.
Also, Smartie use third-party marketing and analytics cookies. If you wish to manage the collection of information for analytical purposes by Google Analytics, please visit the following link: Google Analytics Opt-out Browser Add-on.
In order to optimise and improve the travel-related services we may also use "Web beacons" that monitor your use of our website. Web beacons (or Web bugs) are one-pixel transparent images, although they can be visible images as well, located on a Web page or in an e-mail or other type of message, and are hosted on a server enabling the verification of a user's viewing or receipt of a Web page or message.
Legal bases for processing
We collect and process data about you only where we have legal bases for doing so under applicable laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
Personal data of persons under 18 years of age
The services we provide are not intended for persons under 18 years of age. For persons under 18 years of age the use of any of our services is only allowed with the valid consent of a parent or a guardian. Smartie may collect and use information of persons under 18 years of age only as provided by the parent or guardian or with their consent. If we become conscious that we process information of a persons under 18 years of age without the valid consent of a parent or guardian, we reserve the right to delete it.
Data Subject Rights
Each Data Subject has eight rights. These are:
- The right of access; your right to see what data is held about you by a Data Controller.
- The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- The right to rectification; the right to have your data corrected or amended.
- The right to erasure; you can ask for your personal data to be deleted ( ‘the Right to be Forgotten’).
- The right to restrict processing; the right to ask for a temporary halt to processing of personal data.
- The right to data portability; a Data Subject has the right to ask for any data supplied directly to the Data Controller by him or her, to be provided in a structured, commonly used, and machine-readable format.
- The right to object; the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected.
Rights in relation to automated decision making and profiling; the right not to be subject to a decision based solely on automated processing.