Last Updated: June 12, 2020
A. Privacy Overview
Tourist Tracka takes privacy seriously. We only work with anonymised data sources which are aggregated for additional privacy protection. We further analyse and aggregate data prior to reporting or delivery to customer dashboards.
These guidelines apply to Tourist Tracka, Pty Ltd . (“Tourist Tracka”).
Tourist Tracka provides its customers and their agencies, with insights generated from data provided from website and app publishers and other ad inventory providers and data vendors (its “Business Partners”). Tourist Tracka’s technology, from time to time also helps its partners collect and manage data generated by advertisements .
Tourist Tracka collects and uses data to help customers and business partners better understand the domestic and international tourism industry by providing insights into tourists in Australia and New Zealand. These insights do not include any personally identifiable information (PII). Our Business Partners are contractually obliged to ensure no PII is passed to Tourist Tracka for analysis..
These privacy guidelines explain the various ways individuals may interact with Tourist Tracka and its technology and the ways in which individuals may exercise control over the use of information collected by Tourist Tracka.
B. Tourist Tracka Advertising Technology
B(1). Technology Overview
Tourist Tracka advertising technology collects and uses data to help make online advertising more relevant and for ad delivery and reporting purposes. This plays an important role in improving the relevancy of advertisements displayed throughout the Internet.
Here’s how it works: Tourist Tracka and it’s Business Partners technologies collects data about the websites and apps that a user interacts with and the advertisements that a browser or app displays. This information cannot be used by Tourist Tracka to identify a particular individual, so it is called non-personally identifiable information (“non-PII”). This information may include non-PII identifiers (such as mobile device advertising identifiers, IP address or your browser’s user agent string) specific to the user’s browser or device as well as non-PII demographic and interest information provided by third parties.
An individual’s non-PII may be collected by Tourist Tracka advertising technology when:
- Tourist Tracka or a business partner purchases online advertisements on a website that the individual visits or an app that the individual uses.
- Tourist Tracka or a business partner places a web pixels on a website that the individual visits or uses.
- A user interacts with an app from which Tourist Tracka collects data.
Customers or Business Partners may submit lists to Tourist Tracka of pseudonymized e-mail addresses or pseudonymized postal codes; in some places postal codes are considered personally identifiable information (“PII”). Tourist Tracka cannot use the lists to identify particular individuals because Tourist Tracka does not have access to the e-mail addresses or postal codes once they have been pseudonymized. Thus the lists constitute non-PII. “Pseudonymization” means replacing any identifying characteristics of data with a pseudonym, or, in other words, a value which does not allow the data subject to be directly identified.
Tourist Tracka also offers services which connect customers to data from Business Partners. In these cases customer data wold be connected directly and securely to the Business Partner. Tourist Tracka does not exercise control over the manner in which its Business Partners control, store or label their data segments. Each Business Partner adheres to their own self regulatory codes and/or certain other industry standards.
Tourist Tracka’s business intelligence product uses data from a variety of sources to provide agencies and advertisers with a broad understanding of consumer sentiment. The business intelligence product does not use such data to target advertisements to the users to whom the data pertains.
B(2). What Information Is Collected and How It Is Collected
Tourist Tracka’s technology collects and/or uses only non-PII, including: information about the device and its IP address; the browser or application used; which and how many, business partner web pages have been viewed by a browser or application; search terms entered on business partner websites; referring and exit pages; the date and time an advertisement was viewed; precise geolocation data from third parties; location data; browser or device-specific identifiers (such as mobile device advertising identifiers or your browser’s user agent string); and other similar information. In certain instances, Tourist Tracka may collect and match this non-PII across devices, browsers, or to other data sources such as non-PII credit card transactions through deterministic methods or statistical correlation for the purposes of generating insights about the behaviour of aggregated groups of tourists.
Tourist Tracka’s product uses information from Business Partners, including Internet traffic data, public social media posts, mobile device and location data, basic and aggregated consumer information such as demographics and types of websites visited. and the aforementioned information from the Partner Carriers.
B(4). How the Collected Information Is Used
Tourist Tracka uses the non-PII it collects to deliver Tourist Tracka Services including:
- Analytics services to help customers understand the volume, value and movement of domestic and international tourists in Australia and New Zealand.
- To identify the audience most likely to respond to a particular ad, to serve those ads and to analyze trends. Tourist Tracka may also share this information with its affiliates and Business Partners.
Tourist Tracka an their Business Partners enables Tourist Tracka’s Customers to use advertising segments to deliver relevant advertising tailored to consumers’ interests. An advertising segment is defined by non-PII attributes, which often includes combinations of information such as geography, age range, gender, activities and/or interests.
Tourist Tracka uses business intelligence data to give market insights to agencies and advertisers.
B(3). Cross-App and Cross-Device Advertising, Ad Delivery and Reporting
Tourist Tracka may collect and use the information and the data segments described above for cross-app advertising, i.e., advertising across browsers and apps on a single device, as well as cross-device advertising, i.e., advertising across multiple devices. Tourist Tracka also collects and uses cross-app and cross-device information for ad delivery and reporting purposes. As described elsewhere in these privacy guidelines, Tourist Tracka does not collect PII via its advertising technology, including across apps and devices.
Tourist Tracka uses certain techniques to enable its advertising technology to serve meaningful advertising content on behalf of its customers and Business Partners across apps and devices, including cookie and ID Syncing and similar practices.
B(4). Third-Party Links and Websites
C. Tourist Tracka’s Corporate Website and Information Collected Directly from Tourist Tracka’s Customers
C(1). What Information Is Collected and How It Is Collected
Tourist Tracka collects PII through its corporate website or when a prospective business partner directly contacts Tourist Tracka. PII is collected through Tourist Tracka’s corporate website only when an individual chooses to provide it to Tourist Tracka through a contact form for the purpose of receiving more information about Tourist Tracka’s products and services. Examples of PII which an individual may provide to Tourist Tracka are that individual’s first and last name, physical address, telephone number or e-mail address. Tourist Tracka also collects PII from Tourist Tracka Business Partners in the ordinary course of business, including, for example, e-mail addresses, telephone numbers and billing details. Tourist Tracka uses this information for its business purposes, such as to maintain customer and supplier accounts, billing, password management and to service other customer needs.
C(2). Links on Tourist Tracka’s Corporate Website to Third Party Websites
C(3). Retention of Business Partner Data
Tourist Tracka stores business partner PII as long as relevant for record keeping, business and compliance purposes. The information that Tourist Tracka stores may be deleted as space requires or in the normal course of business. To opt-out of receiving more information about Tourist Tracka’s products and services, you may send an e-mail to unsubscribe@Tourist Tracka.com.au
If Internet browser settings are used to “clear” or delete cookies, this may inadvertently delete cookies that have been set by websites to honor an “opt-out” status (including the Tourist Tracka opt-out cookie).
If you delete Tourist Tracka cookies from your browser, that action only deletes the cookies in your browser and does not send any information to Tourist Tracka. The next time Tourist Tracka is provided the opportunity to set cookies in your browser or app (usually when Tourist Tracka places an ad), it will do so. The Tourist Tracka ID associated with one or more of the Tourist Tracka cookies may or may not be different than the Tourist Tracka ID associated with previously deleted Tourist Tracka cookies.
If you delete Tourist Tracka cookies from your browser, that action also has no impact on the non-PII previously collected and stored by Tourist Tracka. Tourist Tracka will retain the information as described in the Data Retention for Tourist Tracka Advertising Technology section. If Tourist Tracka is able to associate one Tourist Tracka ID with other Tourist Tracka IDs (for example, through the receipt and use of a separate identifier, such as a mobile device advertising identifier, browser’s IP address and user agent string and/or ID syncing), Tourist Tracka may transfer the non-PII associated with one Tourist Tracka ID to the other Tourist Tracka IDs. Thus, Tourist Tracka uses non-cookie technology as well as cookie-based technology to make online advertising more relevant and for ad delivery and reporting purposes.
Tourist Tracka also uses web pixels, in combination with cookies, to analyze usage patterns on its website and through Tourist Tracka advertising technology. The use of a pixel allows Tourist Tracka to record that a particular device, browser, or application has visited a particular webpage, along with additional non-PII that the website may choose to include with the pixel.
D. Security, Integrity, Disclosure
D(1). Disclosure of Information to Third Parties, Onward Transfer
Tourist Tracka may share information, including any PII collected via its website, with Google Cloud and Amazon Web Services who provide cloud computing services for Tourist Tracka. Tourist Tracka uses Google Analytics to collect information about visitors to the Tourist Tracka corporate website. These third parties are prohibited from using the information Tourist Tracka provides for purposes other than performing services for Tourist Tracka or as contractually agreed. Tourist Tracka may also share non-PII, including data collected across applications or devices, with Business Partners (including third-party DSPs and DMPs used by Tourist Tracka’s Business Partners) to carry out advertising campaigns and analysis. Similarly, Tourist Tracka may enhance the non-PII collected via its advertising technology with non-PII collected from Business Partners.
If Tourist Tracka uses your PII for a purpose that is materially different from the purposes for which it was originally collected or subsequently authorized, or if Tourist Tracka discloses it to a third party acting as a controller not previously disclosed to you, Tourist Tracka will offer you the opportunity to opt out of such uses and/or disclosures where it involves non-sensitive information or opt in where sensitive information is involved.
Tourist Tracka may be required to disclose information, including any PII collected via its website, to third parties when Tourist Tracka reasonably believes it is obligated to do so by law (including to meet national security or law enforcement requirements) and to investigate, prevent, or take action regarding suspected or actual prohibited activities, including but not limited to, fraud and situations involving potential threats to the physical safety of any person.
Finally, Tourist Tracka may transfer information, including any PII collected via its website, to a successor entity in connection with a corporate merger, consolidation, sale of assets, bankruptcy, or other corporate change.
D(2). Information Relating to Children
Tourist Tracka’s corporate website, advertising technology, business intelligence product and e-mail channel are designed for individuals who are 13 years of age and older. Tourist Tracka does not knowingly collect PII from anyone under the age of 13 on its website or via its advertising technology. If Tourist Tracka were made aware that it had received PII from someone under 13, Tourist Tracka would use reasonable efforts to remove that information from its records.