Privacy Policy

Privacy policy – Sonnel Hospitality

Sonnel Hospitality and privacy

This privacy policy applies to the handling of personal information by the following entities, (collectively, Sonnel Hospitality ):

  • Nelmeer Hoteliers Pty Ltd ABN 15 060 977 022
  • Nelmeer Ashfield Pty Ltd ATF Nelmeer Ashfield Trading Trust ABN 24 087 218 896
  • Traclon (No.13) Pty Ltd ABN 20 002 960 394
  • Golden Corridor Management Pty Ltd ATF Golden Corridor Hotel Trust No.2 ABN 23 870 685 587
  • Golden Corridor Management Pty Ltd ATF Oasis Hotel Trust No. 2 ABN 42 856 743 073
  • Meerlen Pty Ltd ABN 49 089 981 304

(Sonnel Hospitality, we, us, our).

In operating our hotels, bars, bistros, accommodation and related venues and otherwise operating our business, Sonnel Hospitality collects and handles personal information.

Sonnel Hospitality understands the importance of protecting the privacy of an individual’s personal information. This privacy policy sets out how Sonnel Hospitality aims to protect the privacy of your personal information, your rights in relation to your personal information managed by us and how we collect, hold, use, disclose, and otherwise manage, your personal information.

In collecting, holding, using, disclosing and otherwise managing your personal information, Sonnel Hospitality will comply with the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles in the Privacy Act.

Sonnel Hospitality will regularly review its policies and procedures regarding personal information and may therefore update and amend this privacy policy from time to time. Any updated privacy policy will be made available on the website at guildfordhotel.com.au or can otherwise be obtained by contacting us and requesting a copy.

Collection of personal information

Under the Privacy Act, personal information is information or an opinion about an identified, or reasonably identifiable, individual. During the provision of our hospitality and related services or as a result of our other interactions or dealings with you, Sonnel Hospitality may collect your personal information.

The kinds of personal information that Sonnel Hospitality collects will vary depending on our particular interaction or dealing with you. However, generally speaking, the kinds of personal information Sonnel Hospitality collects may include:

  • contact and identification information such as your name, photograph, date of birth, address, telephone number and email address (for example where you make a reservation at a Sonnel Hospitality venue or join one of our mailing lists);
  • information regarding your transactions with us, including reservations, accommodation and ordering history, food or beverage or other dining preferences across our venues;
  • where you organise or conduct an event, information regarding the event, your guests and any relevant requirements;
  • payment information, such as credit card, bank account or other payment details;
  • information regarding your experience at a Sonnel Hospitality venue (for example as part of our guest feedback activities or where you contact us with feedback); and
  • where you apply for employment with Sonnel Hospitality (in addition to contact and identification information detailed above) information relevant to us considering your application for employment including information in relation to your CV, employment history, qualifications and references.

Depending on the Sonnel Hospitality venue you attend, we may also collect identification information, such as drivers licence, Medicare, tax-file number or passport information and biometric information (for example face scanning). We generally collect this information because we are required to do so by law and/or for venue, patron and employee security purposes. Specific information regarding the collection and handling of this type of personal information may be available at the relevant venue.

Sonnel Hospitality also collects CCTV footage at Sonnel Hospitality venues, including for venue, patron and employee safety purposes. This may be captured in a manner which enables facial or vehicle recognition technology to identify you or your vehicle. Details of suspected or actual illegal or improper conduct (including CCTV footage relating to that conduct) may be shared with relevant law enforcement or regulatory bodies.

At some Sonnel Hospitality venues or events, we may also take photographs or other images or content (such a video or audio recordings). Where we do so, we will provide as much detail as possible regarding why the photographs, images or other content are being taken and the purposes for which they are being used. By attending such a Sonnel Hospitality venue or event, you consent to us taking such photographs, images or other content and using those photographs, images or other content, including at the venue and on Sonnel Hospitality websites and social media sites.

Sonnel Hospitality may also hold other kinds of personal information as permitted or required by law or other kinds of personal information that we notify you of at or about the time of collection.

Generally, we do not collect sensitive information about individuals. Information about your health, racial or ethnic origin, political persuasions, criminal record and religious or philosophical beliefs are all examples of sensitive information. There may be circumstances where Sonnel Hospitality does collect sensitive information, for example where we need to collect health information regarding your allergies or in a medical emergency. If we do collect sensitive information about you, we will only do so with your consent or where we are required or authorised to do so by law.

Collection of personal information by Sonnel Hospitality

Generally, Sonnel Hospitality collects your personal information directly from you. For example, Sonnel Hospitality may collect your personal information where:

  • you make a booking for or attend a Sonnel Hospitality venue or event;
  • you join one of our mailing lists, fill out a survey, enter a promotion, request services or otherwise provide us with your details;
  • you stay at any Sonnel Hospitality venue that provides accommodation services;
  • you sign up to or participate in any Sonnel Hospitality rewards or loyalty program;
  • you participate in a gaming self-exclusion program or scheme which we also participate in;
  • you provide feedback to us regarding your experience at a Sonnel Hospitality venue or your other interaction with Nelson Meers;
  • you post information to any of our social media sites;
  • we need to make a payment to you, for example gaming jackpots; or
  • you apply for or express an interest in employment with us.

We generally collect personal information directly from you. However, there may be occasions when Sonnel Hospitality collects your personal information from someone other than you, for example from:

  • other entities within Sonnel Hospitality;
  • our service providers or contractors (for example, where we appoint a service provider/contractor to assist with conducting an event);
  • our technology providers (for example, providers of our reservation, ordering, payments or booking systems);
  • an information services provider;
  • a gaming self-exclusion scheme provider;
  • a publicly maintained record or other publicly available sources of information including social media and similar websites; or
  • a referee or previous employer where you apply for employment with Nelson Meers.

Purposes for which personal information is used

Generally speaking, Sonnel Hospitality collects and uses personal information so that we can provide our hospitality and accommodation services, interact with you in relation to our services and venues and administer and manage our business and our venues.

Some examples of the purposes for which Sonnel Hospitality collects, holds, uses and discloses your personal information include to:

  • take bookings for Sonnel Hospitality venues or events;
  • provide food, beverage and other hospitality experiences at Sonnel Hospitality venues;
  • manage and undertake events conducted at our venues;
  • manage and administer the provision of our services and our relationship with you;
  • verify your identity;
  • to make a payment to you, for example gaming jackpots;
  • maintain venue, patron and employee safety;
  • enable us to supply you with information you request from us;
  • conduct promotions, competitions, giveaways and events;
  • contact you to obtain your feedback regarding our products or services or to conduct other market research;
  • provide you with marketing information regarding Nelson Meers, our venues and information about our partners (as further detailed in paragraph 5 below);
  • analyse information we collect so that we can administer, support and improve and develop our business and the products and services we offer, including by undertaking data analytics and related activities using your personal information;
  • comply with the obligations of Sonnel Hospitality under any applicable laws; and
  • consider any application you make for employment with us.

In addition to the purposes listed above, Sonnel Hospitality may use your personal information for other purposes which we notify you of when we collect the information and for other purposes permitted or required by law.

Where personal information is used or disclosed, Sonnel Hospitality takes steps reasonable in the circumstances to ensure it is relevant to the purpose for which it is to be used or disclosed.

You are under no obligation to provide your personal information to Sonnel Hospitality. However, without certain information from you, Sonnel Hospitality may not be able to provide services or information to you or may be limited in how we can interact with you.

Direct marketing

In addition to the purposes outlined in paragraph 4 above, Sonnel Hospitality may use and disclose your personal information in order to inform you of promotions, competitions, giveaways, events, products or services that may be of interest to you. Where you make a booking at a particular Sonnel Hospitality venue or sign up for the mailing list or rewards program of a particular Sonnel Hospitality venue, this may include sending you information about that Sonnel Hospitality venue or other Sonnel Hospitality venues or events, or third party services that may be of interest to you.

In doing so, Sonnel Hospitality may disclose your personal information to the companies within theSonnel Hospitality or other entities with which Sonnel Hospitality has a commercial relationship or arrangement for the purpose of the other entity contacting you for such direct marketing purposes.

These communications may be sent using email, telephone, SMS, social media or other similar forms of communication.

If you do not wish to receive such communications, you can opt-out at any time by contacting Sonnel Hospitality via the contact details set out in paragraph 12 of this privacy policy or through the opt-out mechanism contained in a marketing communication to you.

Disclosure of personal information

Sonnel Hospitality discloses your personal information for the purpose for which Sonnel Hospitality collects it. As a result, generally, Sonnel Hospitality will only disclose your personal information for a purpose described in this privacy policy. This may include disclosing your personal information to:

  • the companies or other entities within Sonnel Hospitality;
  • our service providers and contractors and other third parties that provide products or services to us (including our technology service providers, data analytics service providers, bookings or reservation systems providers, event service providers, marketing agencies or other business or administration service providers);
  • Nelson Meers’ auditors, tax, insurance, legal or other professional advisors;
  • persons or entities considering acquiring an interest in Nelson Meers’ business or assets; or
  • Nelson Meers’ insurance providers.

Sonnel Hospitality may also disclose your personal information for other purposes where we notify you of the disclosure at or about the time of collecting the information, with your consent or if the disclosure is required or authorised by law. Examples of disclosure that may be required or authorised by law include disclosure to law enforcement bodies, liquor and gaming regulators or under Anti-Money Laundering and Counter-Terrorism Financing laws.

If you post information or other content to public sections of our websites or to our social media sites, you acknowledge that the information or content may be viewed by the public and/or users of the relevant website or social media site.

Overseas disclosures

Some of the parties that Sonnel Hospitality discloses your personal information to may be located outside Australia, including technology service providers located in China, India and Canada. We take reasonable steps to ensure that any such overseas recipients do not hold, use or disclose your personal information in a way that is inconsistent with the obligations imposed under the Privacy Act and the Australian Privacy Principles in the Privacy Act.

Links to other websites

When you access our websites or other online services, we may provide as a convenience to you links to other websites, including sites operated by our partners, associates, or independent third parties. These links are provided as a convenience to you. Each website may have its own privacy practices, as described in that site’s privacy policy. Those practices may be different than the practices described in this privacy policy, and we encourage you to read each website’s privacy policy carefully before you use or submit information to that site. Additionally, to the extent that you follow a link to a website operated by an independent third party, please be aware that we exercise no authority or control over that third party, and cannot and are not responsible for any information that you may submit to that site.

Cookies and website statistical information

Sonnel Hospitality may collect statistical information when you access and use wifi located at our venues, our websites and any online platforms available via our websites, by utilising features and technologies of your internet browser or device, including cookies and pixel tags. We use this information to analyse how our wifi, websites and other online services are being used and seek to improve our websites and other online services and provide more user friendly and customised websites and online services. These features and technologies do not specifically identify you unless you expressly provide to us with personally identifiable information. You may also elect to turn off the internet browser features which allow us to collect statistical information by selecting certain options on your browser. However, this may slow down or cause certain web pages to be inaccessible to you. Cookies and pixel tags may be used to send targeted advertising or promotional messages but will not be used to identify you.

Security of personal information

Sonnel Hospitality takes the security and protection of the personal information we hold seriously.

We take steps reasonable in the circumstances to ensure that the personal information we hold is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

Your personal information will be kept on databases held on servers kept in a physically and technologically secured environment, accessed only by authorised personnel or contractors. Where personal information is held in hard copy, it will be held in controlled, access restricted premises which only authorised personnel or contractors will be permitted to access.

Sonnel Hospitality will destroy or de-identify personal information in circumstances where it is no longer required, unless Sonnel Hospitality is otherwise required or authorised by law to retain the information.

Access and correction

Sonnel Hospitality takes steps reasonable in the circumstances to ensure personal information it holds is accurate, up-to-date, complete, relevant and not misleading.

In addition, under the Privacy Act, you have a right to seek access to and correction of your personal information that is collected and held by Sonnel Hospitality. If at any time you would like to access or correct the personal information that Sonnel Hospitality holds about you, or you would like more information on Sonnel Hospitality’s approach to privacy, please contact Sonnel Hospitality using the details set out in paragraph 12 below. Sonnel Hospitality will grant access to the extent required or authorised by the Privacy Act or other law and take steps reasonable in the circumstances to correct personal information where necessary and appropriate.

To obtain access to your personal information:

  • you may have to provide proof of identity to ensure that personal information is provided only to the correct individuals and that the privacy of others is protected;
  • Sonnel Hospitality requests that you be reasonably specific about the information you require; and
  • Sonnel Hospitality may charge you a reasonable administration fee, which reflects and will not exceed the cost to Sonnel Hospitality for providing access in accordance with your request.
  • Sonnel Hospitality will endeavour to respond to your request to access or correct your personal information within 30 days from your request.

If Sonnel Hospitality refuses your request to access or correct your personal information, Sonnel Hospitality will provide you with written reasons for the refusal and details of complaint mechanisms.

If you are dissatisfied with Sonnel Hospitality’s refusal to grant access to, or correct, your personal information, you may make a complaint to the Office of the Australian Information Commissioner.

Contacting Sonnel Hospitality

For further information or enquiries regarding your personal information, or if you would like to opt-out of receiving any promotional or marketing communications or make a privacy complaint, please contact Sonnel Hospitality’s using any of the following contact details:

[email protected]

Privacy complaints

Please direct all privacy complaints to Sonnel Hospitality. At all times, privacy complaints:

  • will be treated seriously;
  • will be dealt with promptly;
  • will be dealt with in a confidential manner; and
  • will not affect your existing obligations or affect the commercial arrangements between you and Sonnel Hospitality.

Sonnel Hospitality will acknowledge your complaint within 7 days of receipt and endeavour to resolve it within 30 days, unless Sonnel Hospitality informs you otherwise and seeks your agreement in writing.

Sonnel Hospitality will commence an investigation into your complaint. You will be informed of the outcome of your complaint following completion of the investigation. In the event that you are dissatisfied with the outcome of your complaint, or an extension to the time in which Sonnel Hospitality will resolve it, you may refer the complaint to the Office of the Australian Information Commissioner.