LuggageShares

Privacy Policy

Seatfrog Privacy Policy

Last update: May 2016

Your privacy is important to us.
Seatfrog Pty Ltd (ABN 36 605 390 261) (Seatfrog, we or us) takes such steps as are reasonable in the circumstances to protect and maintain your privacy.  Seatfrog takes its obligations under the Privacy Act 1988 and the Australian Privacy Principles (APPs) seriously.

Consent

Our Privacy Policy explains how we handle your personal and sensitive information and, in particular, details how we collect, use, disclose, store and enable you to access your personal and/or sensitive information. Our Privacy Policy applies to your personal and sensitive information regardless of the way in which we collect it, for example, whether it is collected via the Seatfrog App or website www.seatfrog.com (Website), when you contact our Customer Service team, when you submit a job application to Seatfrog or when you use one of our services.

By providing us with your personal and/or sensitive information, by downloading our App, or by visiting and using our Website, you confirm your acceptance of the terms of this Privacy Policy and consent to the handling of your information in the manner set out in this Privacy Policy and in accordance with any other explanation you may be given at the time of providing the information. If you do not agree with the terms of this Privacy Policy, please do not provide us with your information.

Minors

Seatfrog’s services, including but not limited to those provided via the Seatfrog App or the Website, are not intended for minors under 18 years of age. No one under the age of 18 may provide personal information to or through the Seatfrog App or the Website (collectively the Seatfrog Services). We do not knowingly collect personal information from minors under 18. If you are under 18, please do not create a Seatfrog account or send us any information about you.

Personal Information and Sensitive Information

"Personal information" is any information about an identified individual or an individual who is reasonably identifiable, regardless of whether the information is true or not.

"Sensitive information" includes, for example, the following:

  • health information about an individual; and
  • information or an opinion about an individual’s racial or ethnic origin, membership of a professional association, trade association or trade union (which is also personal information).

What personal information and sensitive information do we collect?

The type of information we collect from you will depend upon the type of interaction you have with us.

Broadly speaking, the types of personal and/or sensitive information that we collect may include:

  • if you are a customer – your first and last name email address; details of transactions which you conduct using the Seatfrog Services;
  • if you are a supplier or service provider – your full name, employer name, work contact details (including address, phone number, fax number and email address); and
  • if you are a job applicant, employee or contractor – your full name, contact details (including address, phone number and email address), driver’s licence details, job title, passport details, employment history and education details, names and contact details of referees, next of kin details (in the event of an emergency).

We may collect personal and/or sensitive information from you in a variety of ways, including the following:

  • when you create a Seatfrog customer account;
  • when you participate in an auction using the App, for example, when you enter your booking reference details or when Seatfrog accesses your itinerary details via our partner Global Distribution Systems (GDS)
  • automatically when you navigate through the Seatfrog Services. Information collected automatically may include usage details, geo-location data, IP addresses and information collected through cookies, and other tracking technologies (which may not be information which identifies you);
  • content and other information you provide when you use the Seatfrog Services or post on our social media accounts;
  • when you:
    • arrange payment for use of our services;
    • visit our Website and any other webpage that we own and manage;
    • when you manage/change your customer and/or supplier account information;
    • contact us by phone, email, post or via the Website;
    • attend onsite pilot programmes;
    • subscribe to receive our newsletter or promotional materials or sign up to a mailing list; and/or
    • participate in surveys, or competitions or other promotional activities.

Seatfrog may also collect your personal information from third parties. This may include (but is not limited to) the collection of your personal and/or sensitive information from:

  • other users of the Seatfrog Services;
  • our business partners, such as airlines, car rental operators and accommodation service providers;
  • someone duly authorised to act on your behalf (such as your next of kin);
  • recruiters we have retained and from referees you have provided in support of a job application.

From time to time, you may be able to visit our Website and deal with us anonymously or by pseudonym. However, please be aware that, if you do not provide us with certain information that we require, we may not be able to provide you with the products and/or services that you seek. For example, if we do not have your first and last names and reservation number you will not be able to participate in an auction using the App.

How do we use your personal and/or sensitive information?

The personal and sensitive information we collect may be used in a number of ways including:

  • to provide the Seatfrog Service, for example, enabling you to participate in auctions, including sending you notifications when bidding has opened/closed in an auction and allowing you to participate in interactive features of the Seatfrog Services, when you choose to do so;
  • liaising with Amadeus, airlines, travel agents, and our other partners;
  • to provide you with information or services that you request from us;
  • generating bills, managing accounts and carrying out debt-recovery functions;
  • providing customer and supplier technical support and other customer/supplier relationship management functions;
  • dealing with enquiries or complaints;
  • collecting and analysing product performance, service and reliability data;
  • carrying out market research and product analysis and development;
  • complying with our obligations under the law;
  • training our staff;
  • to notify you of changes to the Seatfrog Services;
  • in any other way we may describe when you provide the information;
  • in the event of a change of business ownership, merger, sale or other business transaction, transferring your information to a successor entity;
  • for various communications and marketing purposes;
  • conducting our internal business and management processes, for example accounting or auditing purposes; and
  • for any other purposes that would be reasonably expected.

How to opt-out of marketing materials?

From time to time, we may use your personal information for the purposes of marketing our services or to inform you of new services, promotions or events. If you no longer wish to receive our marketing communications, you can opt out by:

  • writing to us at the Contact Details below and informing us that you no longer wish to receive these marketing materials; or
  • in relation to any direct marketing email, clicking the "unsubscribe" link at the bottom of each email.

Please be aware that we may still need to send you essential information in relation to your account (rather than marketing information) from time to time.

Is personal and/or sensitive information disclosed to third parties?

Seatfrog may disclose personal and/or sensitive information to third parties in certain circumstances including (but not limited to) the following:

  • to fulfil the purposes for which you provided your information;
  • to selected third parties to contact you about goods and services that may be of interest to you;
  • to other third parties we engage to help us run our business - such as contractors couriers; pay roll service providers; debt collection agencies and other parties that assist with debt-recovery functions;
  • to our professional advisors, including lawyers, accountants, tax advisors and auditors;
  • law enforcement bodies, Courts of law or as otherwise required or authorised by law;
  • regulatory or government bodies for the purposes of resolving complaints or disputes both internally and externally or to comply with any investigation by one of those bodies;
  • if our business is sold, restructured or integrated with another group of companies, to the new owner, to be used in the same ways set out in this Privacy Policy;
  • any other person or for any other purposes that would be reasonably expected.

We may transfer your personal and sensitive information to overseas recipients for business purposes and operational, support and continuity purposes, for example, when we use IT service providers or data storage services which are located overseas. Currently, Seatfrog’s data is stored in the Australia.

Before Seatfrog does disclose any personal and/or sensitive information to a third party, we take reasonable steps to ensure that the third party will protect your personal and sensitive information in accordance with Australian privacy laws and in a manner consistent with this Privacy Policy. Third parties are required to restrict their use of this information to the purpose for which it was provided. Please note that third parties, such as airlines, may be located anywhere in the world.

We may also provide our partners, such as airlines with aggregated information about the users of the Seatfrog Services, for example, the winning bid amounts, the location of bidders, the number of bids placed etc...

Does the Website use "Cookies"?

Yes, our Website uses cookies.

Cookies are small text files that may be placed on your computer or other device by websites when you visit them.  Cookies enable Seatfrog to recognise your device on a subsequent visit by that device to our Website and allow us to deliver a more personalised experience by providing information to us. Cookies are essential for some website functions and these functions will not work in the absence of those cookies.

You can use the browser privacy functions to clear the cookies already on your computer or to block cookies in the future by altering the browser privacy settings. However, please note this may cause some of the functionality of the Website to not work correctly.

If you continue to use our Website, you are agreeing to the use of cookies.

How accurate is the personal information we hold about you?

We take reasonable steps to ensure that the personal information we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of the information we hold depends to a large extent on the information you provide. To ensure that we have your most current personal information, please update your information within the settings section of the Seatfrog app or contact privacy@seatfrog.com.

What security measures do we use to protect your personal information?

The security of your personal information is given a high priority. We take such steps as are reasonable to securely store your personal information so that it is protected from unauthorised use or access, misuse, loss, modification or unauthorised disclosure. This includes both physical and electronic security measures. Examples include the use of passwords, locked storage cabinets and secured storage rooms. Other features include:

  • storing information on secured networks consistent with industry standards, which are only accessible by those employees who have special access rights to such systems;
  • using industry-standard encryption technologies when transferring or receiving sensitive information, such as SSL technology;
  • restrictions are placed on the electronic transfer of files; and
  • our IT networks undergo necessary vulnerability testing to continually identify and remediate potential opportunities for unauthorised data access.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Seatfrog Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Seatfrog Services. Any transmission of personal information is at your own risk.

Seatfrog takes such steps as reasonable, in the circumstances, to destroy or de-identify personal and sensitive information when the information is no longer required for any purpose for which it may be used or disclosed by Seatfrog and Seatfrog is no longer required by law to retain the information.

Can you access the personal and/or sensitive information we hold about you?

Yes, however there are some exceptions by law, which we will explain to you if relevant to your request. To request access to your information, send an email to privacy@seatfrog.com. To protect your privacy, we will take reasonable steps to verify your identity before providing you with access to your information. We may charge reasonable costs for responding to your request and will respond to your request within a reasonable time.

If we refuse to grant you access, we will provide you with a written notice setting out the reasons for our refusal and the mechanisms you may use to complain about our decision.

Can you seek correction of the personal information we hold about you?

If you think your personal information may be inaccurate, incomplete or out of date, you can request it to be updated or corrected by sending an email to privacy@seatfrog.com. We will respond to your request within 30 days and we will not charge a fee for responding to your request. Seatfrog may need to flag your records with a suitable explanation rather than changing or deleting the information. To protect your privacy, we will take reasonable steps to verify your identity before correcting or adding notes to our records. If we refuse to correct your information, we will provide you with a written notice setting out the reasons for our refusal and the mechanisms you may use to complain about our decision.

How can you report a breach of your privacy?

If you have any concerns or complaints about a breach of your privacy or the way we have handled your personal information, please contact us by sending an email to privacy@seatfrog.com.

We will then investigate your complaint and endeavour to provide you with our response within a reasonable time after receiving your complaint. If, after receiving our response, you still consider your privacy complaint remains unresolved, you may then, for example, refer your concern to the Australian Privacy Commissioner.

Changes to our Privacy Policy

Seatfrog reviews its Privacy Policy from time to time and reserves its right to modify its Privacy Policy at any time without notice. We will publish any changes to our Privacy Policy on our Website. By continuing to use the Seatfrog Services, or by continuing to provide us with your personal and/or sensitive information after the updated Privacy Policy has been published on our Website, you confirm your acceptance of these amendments.

Contact Us

For any other questions regarding privacy, please send an email to privacy@seatfrog.com.

Seatfrog Pty Ltd
Level 5
155 Clarence Street
Sydney NSW 2000
Australia