Privacy Policy

1. Scope and introduction

This Privacy Policy explains how Pauls Travel Solutions Pty Ltd (ABN 26 624 441 416) and its brands – Pauls Travel, Pauls Holidays, trvlr, and flyght – collectively referred to as “Pauls Travel”, “we”, “us”, or “our” – handle your personal information.

We operate from Melbourne, Victoria, Australia, and we are committed to protecting your privacy in accordance with the Privacy Act 1988 (Cth) Australian Privacy Principles (APPs) and, where applicable, the General Data Protection Regulation (GDPR) and Spam Act 2003 (Cth).

We recommend you review this policy regularly, as we may amend it to reflect our current practices and legal obligations. We will notify you of significant changes.

This policy does not apply to our employee or contractor records.

By providing personal information to us (directly or through a third party on your behalf), you consent to this policy applying to how we handle your information.

Who this policy applies to

This policy applies to all individuals who interact with us, except:

• Residents of California (refer to our separate CCPA Privacy Notice)
• Employees and contractors (separate policies apply)

Specific situations

If you are:

• Travelling for work with a corporate, business, or government client
• Based in the European Economic Area (EEA)

2. What personal information do we collect?

Types of information

The personal information we collect depends on your relationship with us. It generally includes:

Identity & contact details

• Name, title, date of birth, gender
• Residential/mailing address, phone number, email address
• Social media handles

Travel arrangements

• Flight, hotel, and holiday itineraries
• Seat preferences, meal requests, baggage details
• Loyalty program or frequent flyer account numbers
• Passport and national ID details (including expiry dates)
• Visa and travel permit information
• Nationality

Health & special needs

• Dietary requirements (e.g., religious, allergies, vegan)
• Disability or accessibility needs requiring special assistance
• Health information provided voluntarily (e.g., fitness to travel, COVID-19 status)
• Collected only where necessary for your travel arrangements and with your consent

Payment & financial

• Credit/debit card details, expiry date, security codes
• Billing address and payment history

Online & device

• IP address, device type, operating system, browser
• Geo-location data
• Website/app usage data (pages visited, search terms, booking history)
• Cookies and tracking data (see our Cookies Policy)

Usage & feedback

• Booking and purchase history
• Competitor pricing and offers
• Market surveys, feedback, complaints
• Incident reports (e.g., lost baggage, delays)

Sensitive information (collected with your explicit consent where required)

• Health conditions, allergies, disabilities
• Religious or philosophical beliefs (e.g., for dietary/holiday requests)
• Racial/ethnic origin
• Biometric data (e.g., facial recognition if used on partner systems)
• Criminal convictions information (if disclosed for travel security)

Why it’s needed

Certain information (e.g., full name, contact details, passport number, credit card) is required to complete bookings. Without it, we cannot provide services. If you decline to provide required information, we may be unable to process your request.

3. How do we collect your personal information?

Directly from you

We collect information when you:

• Complete online booking forms on paulstravel.com.au, flyght.com.au, paulsholidays.com.au, or trvlr.com.au
• Call us or email us
• Visit us in person
• Download and use our mobile apps
• Connect via social media (e.g., Facebook, Instagram)
• Subscribe to newsletters or marketing
• Enter competitions or provide feedback
• Participate in surveys or reviews

Indirectly from third parties

We may collect information about you from:

• Travel agents or booking agents who make inquiries on your behalf
• Other travellers on a group or family booking (with their authority)
• Airlines, hotels, and travel suppliers to facilitate your bookings
• Government agencies (immigration, customs, security) for travel compliance
• Your employer (if you’re a corporate client travelling for work)
• Other Pauls Travel brands (within our group)
• Marketing partners who provide leads or referrals
• Public sources (e.g., publicly available data for research)

Call recording & monitoring

We may record phone calls with you for quality assurance, training, dispute resolution, and security purposes. We will inform you when recording begins. If you prefer not to be recorded, please let us know.

We may also monitor, record, or copy information transmitted through our website, email, or phone for similar purposes.

Cookies & tracking

When you visit our websites or apps, our servers record data about your device, network, and how you interact with us (e.g., pages viewed, links clicked). See our Cookies Policy for details and how to manage your preferences.

Your responsibility

If you provide information about other travellers (e.g., family members), you are responsible for:

• Obtaining their voluntary consent
• Informing them of this privacy policy and where to find it
• Ensuring the information is accurate

If you book on someone else’s behalf, we rely on your authority to provide their information.

4. How do we use your personal information?

We use your information for:

To provide services

• Complete your travel bookings (flights, holidays, accommodation, car hire, travel insurance)
• Process payments and manage billing
• Contact you about your bookings, itinerary changes, and travel arrangements
• Provide customer support and respond to queries or complaints
• Verify your identity and prevent fraud

Marketing & communication (with your consent)

• Send you promotional offers, newsletters, and information about new products/services
• Inform you of special deals relevant to your travel interests
• Notify you of loyalty program benefits
• Conduct surveys or market research
• Personalise your experience on our websites/apps based on your interests and browsing

Compliance & safety

• Comply with immigration, customs, and security laws (including providing information to authorities)
• Detect and prevent fraud, unauthorised access, or illegal activity
• Respond to legal requests from courts, police, or regulators
• Manage incidents (e.g., lost luggage, travel emergencies)

Business operations

• Improve our services and websites through analytics
• Identify errors and troubleshoot systems
• Train our staff and test our systems
• Generate reports and insights (anonymised where possible)
• Manage loyalty programs and partnerships

Legal basis

We use your information where:

• You’ve given explicit consent
• It’s necessary to perform a service you’ve requested
• We’re legally required (e.g., immigration, anti-fraud laws)
• It’s in our legitimate interests (e.g., business improvement, marketing) and your interests don’t override ours

5. Who do we disclose your information to?

Travel service providers

To fulfil your bookings, we disclose your information to:

• Airlines (name, contact, ID, frequent flyer details—required for ticketing and to notify you of disruptions/cancellations)
• Hotels, car rental, tour operators, and ground services
• Travel insurance providers
• Loyalty program operators (with your consent)
• Airport lounges and hospitality partners

These providers operate under their own privacy policies. We encourage you to review them.

Our service providers & business partners

We disclose information to contractors and suppliers who help us operate, including:

• IT & Data: Cloud hosting, booking systems (GDS like Amadeus), data storage, cybersecurity
• Payment Processing: Banks, credit card processors, fraud detection services
• Marketing & Communications: Email platforms, printing/mailing houses, market research firms, advertising partners
• Customer Support: Call centres, chatbots, feedback systems
• Professional Services: Accountants, lawyers, auditors, recruitment consultants

Related entities

We may share information between Pauls Travel brands (flyght, trvlr, Pauls Holidays, Pauls Travel) to:

• Unify your bookings and preferences across brands
• Enable single sign-on (one login for all)
• Provide better service coordination

Corporate & government clients

If you’re travelling under a corporate, business, or government client program, we may disclose your travel details (itinerary, incidents, spending) to your employer or program administrator.

Legal & regulatory

We disclose information where required or authorised by law, including to:

• Government agencies (customs, immigration, tax authorities)
• Law enforcement (police, fraud prevention agencies)
• Courts and regulators
• Creditors, insolvency practitioners (if our business is sold or restructured)

Without consent (exceptional cases)

We may disclose information without your consent if we reasonably believe it’s necessary to:

• Prevent a threat to life, health, or safety
• Prevent or detect crime
• Comply with a legal obligation
• Protect our legal rights

No selling or renting

We do not sell, rent, trade, or disclose your information for profit. Any disclosure is for legitimate service delivery, legal compliance, or your benefit.