Direct 2 Consumer (D2C)

Privacy Policy

1. Introduction
Welcome to Direct 2 Consumer (D2C) (“Company”, “we”, “our”, “us”). We are committed to protecting your personal information and your right to privacy. This Privacy Policy explains what information we collect, how we use it, and your rights regarding your information.

2. Information We Collect
We collect personal information that you provide to us voluntarily. This includes:

  • Client Details: Names, phone numbers, email addresses, country, and subject of enquiry.
  • Staff Details: Names, phone numbers, email addresses, country, and details related to job applications.

Additionally, we collect certain information automatically through our use of Google Analytics. This may include:

  • Usage Data: Information about your interaction with our website, such as pages visited, time spent on pages, and navigation paths.
  • Device Data: Information about your device, such as IP address, browser type, operating system, and device identifiers.

3. How We Use Your Information
We use the information we collect for the following purposes:

  • To respond to your enquiries and provide the services you request.
  • To manage job applications and staff details.
  • To communicate with you about updates, offers, and other relevant information.
  • To improve our website and services.
  • To analyse website usage and improve our website’s performance and user experience.

4. Sharing Your Information
We do not share your personal information with third parties except in the following cases:

  • With your consent.
  • For legal reasons, such as complying with legal obligations, protecting our rights and property, and enforcing our terms and policies.

5. Security of Your Information
We take reasonable measures to protect the personal information we collect from unauthorised access, disclosure, alteration, and destruction. However, no security system is impenetrable, and we cannot guarantee the security of your information.

6. Your Rights
You have the right to:

  • Access the personal information we hold about you.
  • Request corrections to any inaccuracies in your personal information.
  • Request deletion of your personal information.
  • Opt-out of receiving marketing communications from us.

To exercise these rights, please contact us using the information provided below.

7. Use of Google Analytics
We use Google Analytics to collect and analyse information about the use of our website. Google Analytics collects information such as how often users visit our site, what pages they visit, and what other sites they used prior to coming to our site. We use this information to improve our website and services.

Google Analytics collects only the IP address assigned to you on the date you visit our site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information.

Google’s ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt-out of Google Analytics tracking by using the Google Analytics Opt-out Browser Add-on.

8. Collection of Identity Documents and Sensitive Personal Information
As part of fulfilling certain promotions, prizes or travel experiences, we may collect identity documentation and sensitive personal information from you, including (but not limited to) passport details, passport scans, visa or ESTA information, date of birth, nationality, and other information required for booking flights, travel insurance, accommodation, transfers or event access.

We will only collect this information when you voluntarily provide it to us and when it is reasonably necessary for us to facilitate or deliver the prize or services you have won or requested.

9. Purpose of Collecting Identity Information
We collect, use and disclose Identity Information solely for the purpose of:

  • Verifying your identity
  • Booking flights, accommodation and travel insurance
  • Applying for or assisting with visa or ESTA requirements
  • Coordinating transfers, event entry, or prize fulfilment
  • Contacting you about travel arrangements
  • Meeting regulatory or airline security requirements

We will not use your Identity Information for any purpose unrelated to the fulfilment of your prize or travel arrangements unless required or authorised by law.

10. Consent to Collection and Use
By providing your passport details or other Identity Information, you:

  • Consent to our collection, use and disclosure of this information solely for the purposes described above
  • Acknowledge that failure to provide such information may impact our ability to fulfil your prize or travel arrangements
  • Agree that we may contact relevant third parties (such as airlines, travel insurers, accommodation providers and event partners) to complete required bookings

You may withdraw your consent at any time; however, doing so may result in us being unable to provide the prize or service.

11. Disclosure to Third Parties (including Offshore Recipients)
To fulfil your prize or travel arrangements, we may need to disclose your Identity Information to third parties such as:

  • Airlines
  • Travel insurers
  • Hotels and accommodation providers
  • Transfer operators
  • Event partners (including international partners)
  • Visa or ESTA processing agencies where applicable

Some of these third parties may be located outside Australia, including in the United States. Where we disclose your information overseas, we take reasonable steps to ensure that the overseas recipients comply with privacy and security standards similar to the Australian Privacy Principles.

12. Security of Identity Information
We take the protection of your Identity Information seriously. We apply strict safeguards including:

  • Secure encrypted transmission of documents
  • Secure storage on protected servers
  • Limited access on a need-to-know basis
  • Multi-factor authentication for staff access
  • Audit logs for document access where applicable
  • Strict internal procedures for handling and processing identity documents

We will never request passport details via unsecured channels such as standard email unless encrypted.

12. Retention and Destruction of Identity Information
We retain Identity Information only for as long as necessary to fulfil the prize or service and meet any legal or audit requirements.

Identity Information (including passport scans) will typically be securely deleted or destroyed within 90 days of the completion of your travel unless required for longer by law or exceptional circumstances.

Secure deletion methods may include:

  • Permanent digital deletion
  • Secure wiping of encrypted files
  • Secure shredding of any printed documents

You may also request deletion of your Identity Information at any time, subject to our need to retain it to fulfil any outstanding services.

13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on our website. Your continued use of our website after any changes indicates your acceptance of the new terms.

14. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:

Australia Head Office
76a Edinburgh Road
Marrickville, NSW 2204
info@d2c.com.au
(02) 9188 8765

New Zealand Office
92 Albert St
Auckland CBD,
Auckland 1010
info@d2c.co.nz
0800 536 349