Your Privacy Matters
Direct Hospitality Pty Ltd (ACN 600 668 602) ("Direct Hospitality") manages personal
information in accordance with the Privacy Act 1988 (Cth) ("Privacy Act") and the Australian
Privacy Principles as set out in Schedule 1 of the Privacy Act ("APP").
collects, holds, discloses and/or uses via https://www.directhospitality.com.au and any
related Direct Hospitality website, social media page, internal website or intranet
("Websites") or applications ("Applications").
We may change this Policy from time to time. You should check this webpage regularly to
ensure that you are at all times aware of the current policy. This Policy is effective from
01 September 2018.
Throughout this Policy we refer to "Personal Information" which is information or an opinion
about an identified individual, or an individual who is reasonably identifiable, whether the
information or opinion is true or not and whether the information or opinion is recorded in a
material form or not.
"Sensitive Information" is a subset of Personal Information, and includes information or an
opinion about a person’s racial or ethnic origin, political opinions, membership of a political
association, religious beliefs or affiliations, philosophical beliefs, membership of a professional
or trade association, membership of a trade union, sexual orientation or practices, criminal
record, or health, genetic or biometric information.
- WHAT KINDS OF PERSONAL INFORMATION IS COLLECTED AND HELD?
Examples of Personal Information that may be collected and held by Direct Hospitality includes
but is not limited to:
Your first and last name
Date of birth
Company name and details
Contact phone number
Mobile phone number
Direct Hospitality will not collect Sensitive Information unless the person to whom it relates
consents to the collection of that information, and the information is reasonably necessary for
one or more of Direct Hospitality's functions or activities, except where the collection is
required or authorised by law, is necessary to prevent or lessen a serious and imminent threat
to the person’s (or another person’s) life or health, or is necessary in relation to legal
proceedings (current, anticipated or potential), or another permitted exception in the Privacy
- HOW DO WE COLLECT AND HOLD PERSONAL INFORMATION?
Directly from customers when you provide Personal Information. For example when
purchasing goods from Direct Hospitality.
When you interact and/or browse the Website or any Application associated with it
application generally or for a specific purpose.
Directly from customers when you provide Personal Information to create an account
with Direct Hospitality.
Third party providers
Data is collected, processed and stored using third party analytics software that is to the best
of our knowledge secure and confidential. Analytical data is used to gain an understanding of
user behaviour, perform system critical operations, and in extraordinary circumstances, for
legal reasons. Anonymous user data is shared between third party services in order to gain
insight as to aggregate user behaviour.
Analytic data insights are also used to target users through remarketing, demographics,
interests and website behaviour. Third party vendors, including but not limited to Google and
Facebook may show our ads on sites across the internet. We and third party vendors, including
but not limited to Google, make use of third party cookies together in order to inform,
optimise and serve ads based on past visits to a website. We make use of demographic data
(such as age, gender and interests) obtained through third party tools in order to, but not
limited to: influence marketing spend and communicate internally and externally the
Combining/linking Personal Information
Other than as referred to elsewhere in this policy, we will not facilitate the merging of
personally identifiable information with non-personally identifiable information without prior
user consent to that merger to optimise our Website and Website marketing. For example,
we may collate Personal Information data and aggregate data for the purpose of comparing
marketing costs with revenue on a transactional basis.
Passive collection of information – Direct Marketing and Behavioural Advertising
As you navigate through our Websites and access our Applications, certain information can be
passively collected (that is, gathered without your actively providing the information) using
various technologies, such as cookies, Internet tags or web beacons, and navigational data
collection (log files, server logs, and clickstream data).
For example, we may collect information about matters including but not limited to the date,
time and duration of visits and which pages of a Website or Application are most commonly
accessed. This information is generally not linked to the identity of visitors, except where a
Website or Application is accessed via links in an email or another electronic message we have
sent or where we are able to uniquely identify the device or user accessing a Website or
Application, such as when you are logged into an account.
We may share hashed portions of your information with certain strategic partners to make
our business more responsive to your interests and/or those of like-minded consumers. For
example, we may aggregate your email address together with the email addresses of others
who place Enquiries on our Site, locally hash such data, and transmit the resulting hashed data
to third parties including but not limited to Facebook/LinkedIn/Google for the purpose of
creating “Custom Audiences” (where targeted ads are sent to people on Facebook who have
already been on our Site), and “Lookalike Audiences” (where targeted ads are sent to people
on Facebook/LinkedIn/Google who have similar characteristics to people on our Custom
Where we use Personal Information for promotional or direct marketing purposes, a person
may at any time request Direct Hospitality to not use their Personal Information for sending
direct marketing material to that person including if you wish to opt-out of the use of certain
hashed portions of your Personal Information. Such a request can be made by contacting
Direct Hospitality either in writing, by email or by telephone at the contact details below.
There is no fee for making such a request.
Direct marketing can include for example: Displaying an advertisement on a social media site
that an individual is logged into, using Personal Information, including data collected by
cookies relating to websites the individual has viewed. 1
Cookies & Web Beacons
store your preferences. Cookies, by themselves, do not tell us your e-mail address or other
personally identifiable information. However, once you choose to furnish the Websites with
personally identifiable information, this information may be linked to the data stored in the
We may use web beacons on the Websites from time to time. Web beacons or clear .gifs are
small pieces of code placed on a web page to monitor the behaviour and collect data about
the visitors viewing a web page. For example, web beacons can be used to count the users
who visit a web page or to deliver a cookie to the browser of a visitor viewing that page.
We have systems in place to ensure that information is accessible by our staff on a need-to-know
- THE PURPOSES FOR WHICH WE COLLECT, HOLD, USE AND DISCLOSE PERSONAL
Direct Hospitality collects this Personal Information in various ways in the course of
conducting its business, including for the purposes of:
Providing goods and services to customers
Providing newsletters and discounts to customers via e-mail
Responding to customer queries in relation to our products and services
Interaction with customers who utilise our Website
To better understand your needs, enabling us to improve our products and services
To customise our Websites according to your interests
To make improvements to the Websites to enhance the user experience
Direct Marketing and Behavioural Advertising
Promotional and marketing activities
Monitor the effectiveness of our advertising
- HOW CAN YOU CONTROL YOUR PERSONAL INFORMATION?
A person may request to access Personal Information about them held by Direct Hospitality.
Such a request must be made in writing via our contact details below.
Direct Hospitality will take reasonable steps to ensure the accuracy and completeness of the
Personal Information we hold. However, if a person believes that any Personal Information
that we hold about them is inaccurate or out of date, then they should contact Direct
Hospitality in writing via our contact details below.
Direct Hospitality will grant a person access to their Personal Information as soon as possible,
subject to the circumstances of the request.
Verification of identity is required with a request to access (or update) Personal Information
so that we can ensure your Personal Information is disclosed only to you.
An individual can contact Direct Hospitality in relation to lodging a complaint about a breach
of the APP or a binding registered APP code, via our contact details below.
Direct Hospitality will make an assessment of the complaint and will respond to you within a
reasonable timeframe. Any further action following this initial response will vary depending
on the nature of the complaint. If necessary, the complaint may be taken to the Office of the
Australian Information Commissioner or to another review body if an external review is
The opportunity to opt out of behavioural based digital advertising is available by visiting
If you wish to install an advertisement blocking program, an example is provided at:
You may also opt out of our direct marketing emails by clicking on the link contained in any
such emails or by writing to Direct Hospitality at firstname.lastname@example.org.
Freedom of Information Act 1982 (Cth)
An individual also has the right under the Freedom of Information Act 1982 (Cth) to request
access to documents that we hold and ask for information that we hold about that person to
be changed or annotated if it is incomplete, incorrect, out-of-date or misleading.
- DISCLOSURE OF PERSONAL INFORMATION
Personal Information will not be disclosed unless otherwise stated in this policy.
- DIRECT HOSPITALITY CONTACT DETAILS
Contact Person: Doug Shemilt
Postal Address: Direct Hospitality
PO Box 1113
SHEPPARTON VIC 3630
Phone: 1800 999 905