Privacy Policy

1. Introduction

Travelogica Pty Ltd ("we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you access or use our AI-powered software services for travel professionals (e.g., itinerary planning, customer personalisation, data analysis) and our consulting services related to AI implementation and travel strategies (collectively, the "Services"), including through our website, applications, or other interactions.

We are an Australian-incorporated company based at Melbourne, Victoria, Australia. Our practices comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth). If you are located outside Australia, please note that your information may be processed in Australia, and additional laws (such as the EU General Data Protection Regulation or UK GDPR) may apply depending on your location. By using the Services, you consent to the practices described in this Policy.

If you do not agree with this Policy, please do not use the Services. We may update this Policy from time to time and will notify you of material changes via email, through the Services, or on our website. Your continued use after such changes constitutes acceptance.

2. Types of Information We Collect

We collect personal information that can identify you, either alone or in combination with other data. This may include:

• Account and Contact Information: Name, email address, phone number, business name, job title, and other details provided during registration, inquiries, or service engagements.
• User Content and Data Inputs: Information you provide for AI processing, such as travel data, customer profiles, itineraries, preferences, or datasets (which may include personal information of third parties like travelers).
• Usage and Technical Data: IP address, browser type, device information, access times, pages viewed, interactions with the software (e.g., AI queries, outputs), and log data.
• Payment Information: Billing details, such as credit card information or bank details (processed securely via third-party gateways; we do not store full payment details).
• Consulting-Related Data: Notes, reports, or communications from consulting sessions, including business strategies or AI integration details.
• Other Information: Feedback, survey responses, or any information you voluntarily provide, including through support queries or marketing opt-ins.

We may also collect non-personal information, such as aggregated analytics or anonymized AI training data.

Sensitive information (e.g., health data in travel preferences, racial or ethnic origin) may be collected if relevant to the Services (e.g., for personalised travel recommendations). We only collect sensitive information with your explicit consent or as permitted by law, and you are responsible for ensuring any third-party data complies with privacy laws.

3. How We Collect Information

• Directly from You: When you register for an account, use the software, engage in consulting, submit data for AI analysis, or contact us.
• Automatically: Through cookies, web beacons, or similar technologies that track your interactions with the Services. We may use analytics tools (e.g., Google Analytics) to collect usage data.
• From Third Parties: From integrated services (e.g., travel APIs like Amadeus or payment processors), with your authorization. During consulting, we may receive data from your business systems.
• From Public Sources: Publicly available information (e.g., business directories) to enhance Services, but only with consent where required.

We will notify you if collection is not obvious and seek consent where required by law.

4. How We Use Your Information

We use your personal information for the following purposes:

• To provide and improve the Services, including AI-driven analysis, software functionality, consulting advice, and custom integrations.
• To process and fulfill requests, such as generating travel recommendations, optimizing strategies, or delivering reports.
• To manage accounts, authenticate users, and communicate (e.g., service updates, notifications, or marketing with your consent).
• To process payments and manage billing.
• To analyse usage, detect biases in AI models, and enhance performance (e.g., training AI on anonymized data).
• To comply with legal obligations, prevent fraud, or enforce our Terms.
• For internal research, development, and quality assurance, in anonymized or aggregated form where possible.

We will only use sensitive information with your explicit consent or as permitted by law (e.g., for health-related travel accommodations).

5. Disclosure of Your Information

We may disclose your personal information:

• To third-party service providers (e.g., cloud hosting like AWS, AI tools, payment processors, or analytics services) who assist us, subject to confidentiality and data protection agreements.
• To travel industry partners or APIs as necessary for Service delivery, with your authorization.
• If required by law, such as in response to a court order, regulatory request, or for tax purposes.
• In the event of a business transaction (e.g., merger, acquisition), where your information may be transferred.
• With your consent, or to protect our rights, safety, or property.

We do not sell your personal information. Disclosures to overseas recipients (e.g., international cloud providers) are made in compliance with APP 8, ensuring reasonable steps for protection (e.g., contractual clauses or binding corporate rules).

6. Storage and Security

Your information is stored on secure servers in Australia or with reputable providers meeting Australian standards. We implement industry-standard security measures, including encryption, access controls, firewalls, regular audits, and AI-specific safeguards (e.g., data anonymization).

However, no system is infallible, and we cannot guarantee absolute security. Retention periods are as long as necessary for the purposes outlined, or as required by law (e.g., 7 years for financial records under tax laws). After that, data is securely deleted or anonymized.

In the event of a notifiable data breach, we will notify affected individuals and the Office of the Australian Information Commissioner (OAIC) as required.

7. Your Rights: Access, Correction, and Deletion

Under the Privacy Act, you have the right to:

• Access your personal information (subject to exceptions, e.g., commercial sensitivity).
• Request correction if it is inaccurate, incomplete, or outdated.
• Request deletion in certain circumstances (e.g., if no longer needed), though we may retain copies for legal or archival reasons.

To exercise these rights, contact us at privacy@travelogica.ai. We will respond within a reasonable time (usually 30 days) and may charge a fee for access if permitted. If we refuse a request, we will provide reasons.

For users in the EU/UK, additional GDPR rights (e.g., data portability, objection to automated processing) may apply; contact us for details.

8. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance functionality, remember preferences, and analyse usage. You can manage cookies via browser settings, but disabling them may affect Service features.

Third-party tools may set cookies; their policies apply. We obtain consent for non-essential cookies where required.

9. Children's Privacy

The Services are not intended for children under 13 (or 16 in some jurisdictions). We do not knowingly collect information from children. If we become aware of such collection, we will delete it promptly.

10. Complaints and Contact Information

If you have a privacy concern or complaint, contact our Privacy Officer at privacy@travelogica.ai or at our Melbourne office. We will investigate and respond within 30 days.

If unsatisfied, you can complain to the OAIC at www.oaic.gov.au or the equivalent authority in your jurisdiction.

11. Changes to This Policy

We may amend this Policy to reflect changes in our practices, technology (e.g., AI advancements), or legal requirements. Updates will be posted with the revised effective date. For significant changes, we will provide prominent notice.

By continuing to use the Services, you agree to the updated Policy.

This Policy is governed by the laws of Victoria, Australia.