PROTECTION OF PERSONAL INFORMATION ACT – POLICY DOCUMENT

1. COLLECTION OF INFORMATION

1.1. As part of your interactions with The Cliffside, The Cliffside collects various data from you, both by your providing it directly, and automatically from, amongst other things, browsing The Cliffside website. This Policy Document explains how The Cliffside collects your data and what can and cannot do with such information.

1.2. Personal information

1.2.1. Personal information includes:

1.2.1.1. certain information that The Cliffside collects automatically when you visit our website;
1.2.1.2. certain information collected on registration (see below);
1.2.1.3. certain information collected on submission; and
1.2.1.4. optional information that you provide to The Cliffside voluntarily (see below);

but excludes:

1.2.1.5. information that has been made anonymous so that it does not identify a specific person;
1.2.1.6. permanently de-identified information that does not relate or cannot be traced back to you specifically;
1.2.1.7. non-personal statistical information collected and compiled by The Cliffside; and
1.2.1.8. information that you have provided voluntarily in an open, public environment or forum including any blog, chat room, community, classifieds, or discussion board (because the information has been disclosed in a public forum, it is no longer confidential and does not constitute personal information subject to protection under this policy).

1.2.2. Sensitive personal information

Depending on the services that you require, The Cliffside may also collect sensitive personal information including your:
1.2.2.1. financial information – such as your bank account details;
1.2.2.2. biometric information – such as images of your face or fingerprints.

1.3. From Browsers
The Cliffside automatically receives and records Internet usage information on its server logs from your browser, such as your Internet Protocol address (IP address), browsing habits, click patterns, version of software installed, system type, screen resolutions, colour capabilities, plug-ins, language settings, cookie preferences, search engine keywords, JavaScript enablement, the content and pages that you access on the website, and the dates and times that you visit the website, paths taken, and time spent on sites and pages within the website (usage information). Please note that other websites visited before entering our website might place personal information within your URL during a visit to it, and we have no control over such websites. Accordingly, a subsequent website that collects URL information may log some personal information.

1.4. Cookies

1.4.1. The Cliffside may place small text files called ‘cookies’ on your device when you visit its website. These files do not contain personal information, but they do contain a personal identifier allowing The Cliffside to associate your personal information with a certain device. These files serve a number of useful purposes for you, including:

1.4.1.1. granting you access to age restricted content;
1.4.1.2. tailoring our website’s functionality to you personally by letting us remember your preferences;
1.4.1.3. improving how our website performs;
1.4.1.4. allowing third parties to provide services to our website; and
1.4.1.5. helping us deliver targeted advertising where appropriate in compliance with the applicable laws.

1.4.2. Your internet browser generally accepts cookies automatically, but you can often change this setting to stop accepting them. You can also delete cookies manually. However, no longer accepting cookies or deleting them will prevent you from accessing certain aspects of our website where cookies are necessary.

1.5. Third Party Cookies
Some of our business partners use their own cookies or widgets on our website. We have no access to or control over them. Information collected by any of those cookies or widgets is governed by the privacy policy of the company that created it, and not by us.

1.6. Optional Details
You may also provide additional information to us on a voluntary basis (optional information). This includes content or products that you decide to upload or download from our website or when you enter competitions, take advantage of promotions, respond to surveys, order certain additional services, or otherwise use the optional features and functionality of our website.

1.7. Purpose of Collection

1.7.1. The Cliffside may use or process any services information, or optional information that you provide to it for the purposes that you indicated when you agreed to provide it to The Cliffside. Processing includes gathering your personal information, disclosing it, and combining it with other personal information. We generally collect and process your personal information for various purposes, including:

1.7.1.1. services purposes – such as requests for and providing our services;
1.7.1.2. marketing purposes – such as pursuing lawful related marketing activities;
1.7.1.3. business purposes – such as internal audit, accounting, business planning, and joint ventures, disposals of business, or other proposed and actual transactions; and
1.7.1.4. legal purposes – such as handling claims, complying with regulations, or pursuing good governance.

1.7.2. We may use your usage information for the purposes described above and to:

1.7.2.1. remember your information so that you will not have to re-enter it during your visit or the next time you access the website;
1.7.2.2. monitor website usage metrics such as total number of visitors and pages accessed; and
1.7.2.3. track your entries, submissions, and status in any promotions or other activities in connection with your usage of the website.

1.8. Consent to Collection

1.8.1. The Cliffside will obtain your consent to collect personal information:

1.8.1.1. in accordance with applicable law;
1.8.1.2. when you provide The Cliffside with any registration information or optional information voluntarily.

1.9. Objection
If you believe we have processed you personal information improperly or without your consent, you are entitled to request that we delete and/or destroy any personal information which we have on file by contact us directly and by completing Form 1 attached to this policy document.

2. USE

We may use your personal information to fulfil our obligations to you, specifically short term accommodation and related services.

3. DISCLOSURE

3.1. Sharing
The Cliffside may share your personal information with:

3.1.1. other divisions or companies within the group of companies to which The Cliffside belongs so as to provide joint content and services like registration, for transactions and customer support, to help detect and prevent potentially illegal acts and violations of its policies, and to guide decisions about its products, services, and communications (they will only use this information to send you marketing communications if you have requested their services);
3.1.2. an affiliate, in which case The Cliffside will seek to require the affiliates to honour this privacy policy;
3.1.3. The Cliffside services providers under contract who help provide certain services or help with parts of our business operations, including fraud prevention, bill collection, marketing, technology services (The Cliffside contracts dictate that these services providers only use your information in connection with the services they supply or services they perform for The Cliffside and not for their own benefit);
3.1.4. credit bureaus to report account information, as permitted by law;
3.1.5. banking partners as required by credit card association rules for inclusion on their list of terminated merchants (in the event that you utilise the services to receive payments and you meet their criteria); and
3.1.6. other third parties who provide The Cliffside with relevant services where appropriate.

3.2. Regulators
The Cliffside may disclose your personal information as required by law or governmental audit.

3.3. Law enforcement
The Cliffside may disclose personal information if required:

3.3.1. by a subpoena or court order;
3.3.2. to comply with any law;
3.3.3. to protect the safety of any individual or the general public; and
3.3.4. to prevent violation of our customer relationship terms.

3.4. No selling
The Cliffside will not sell personal information. No personal information will be disclosed to anyone except as provided in this privacy policy.

3.5. Marketing purposes
The Cliffside may disclose anonymous aggregate statistics (information about the customer population in general terms) about the personal information to advertisers or business partners.

3.6. Employees
The Cliffside may need to disclose personal information to our employees that require the personal information to do their jobs. These include our responsible management, human resources, accounting, audit, compliance, information technology, or other personnel.

3.7. Change of ownership
If The Cliffside undergoes a change in ownership, or a merger with, acquisition by, or sale of assets to, another entity, The Cliffside may assign its rights to the personal information it processes to a successor, purchaser, or separate entity. The Cliffside will disclose the transfer on the website. If you are concerned about your personal information migrating to a new owner, you may request The Cliffside to delete your personal information.

4. SECURITY

4.1. Protocols
The Cliffside adheres to strict security protocols in respect of data protection laws. The Cliffside’s website is hosted in a secure server environment that uses a firewall in addition to other advanced security measures aimed to prevent any interference or access from unwarranted outside third parties.

4.2. Access
Access to any personal information is only authorised for employees who require such information in order to fulfil their employment responsibilities.

5. ACCURACY OF INFORMATION

5.1. The Cliffside aims to ensure that all personal information collected is accurate, complete and up to date as is necessary for the purposes defined in this policy. In order to maintain accurate information, The Cliffside may request that you update your information on our website.

5.2. Updating Information
You are able to review and update any personal information that may be held by The Cliffside by accessing your account online, emailing The Cliffside with the relevant Form 2 completed and signed (which Form is attached to this Policy), or phoning The Cliffside. The identity of any person wishing to update any information is required to be verified prior to the granting of any access to the respective person’s account or making any changes to any personal information.

6. RETENTION OF INFORMATION

6.1. Period of Retention
The Cliffside will only retain personal information for as long as it is necessary to fulfil the purposes explicitly set out in this policy, unless:

6.1.1. retention of the record is required or authorised by law; or
6.1.2. consent for the retention of the record is given to The Cliffside.

6.2. Obligations
During the period of retention, The Cliffside will continue to abide by all its obligations stipulated in this policy. The Cliffside reserves the right to retain information in physical or electronic records at its discretion.

7. TRANSFER OF INFORMATION

The Cliffside undertakes not to transfer any personal information across any country border without prior written consent.

8. LIMITATION OF LIABILITY

The Cliffside is not responsible for, gives no warranties and makes no representations whatsoever in respect of any privacy policy and/or practice belonging to linked or third-party websites.