Our privacy commitment to you
Why you should read this
We are committed to looking after the Personal Information you have given us, making sure it's used only for the purposes for which it is provided, and that it is only shared (disclosed) in the ways you expect. Your Personal Information is in safe hands: we will only use your Personal Information for the purposes of providing our travel-related products and services ('services') to you, to improve the services we offer, and to provide you with our latest news and updates. We will never share (disclose) your personal details with other companies for marketing purposes unless you've given us explicit permission.
This Privacy Policy will inform you as to how we protect the Personal Information that you provide to us or we collect from you when you visit our Website, make an enquiry and/or purchase services from us. This Privacy Policy also tells you about how we collect, hold, use and disclose your Personal Information.
This is the full version of our Privacy Policy and forms part of your terms and conditions of reservation with us.
Who we are
It's important that you know who actually holds your Personal Information.
The "Globus family of brands" operates in the United States, United Kingdom, Australia, New Zealand, Canada, India and other Globus family of brands offices globally.
Circuit Travel Pty Ltd, our Australian company, is part of the Globus family of brands, an international group of companies providing escorted tours, vacation packages and river cruises to guests around the world.
In Australia, the Globus family of brands trades as Circuit Travel Pty Ltd (in this Privacy Policy described as ‘we’, ‘us’ or ‘our’).
The Globus family of brands comprises the Avalon Waterways, Globus and Cosmos brands. This Website is owned, managed and operated by the Globus family of brands.
Changes to the Privacy Policy and your duty to inform us of changes
This is the current version of our Privacy Policy updated on 20 September 2024.
We may make changes to this Privacy Policy from time to time to time. (Changes we make may apply to Personal Information of yours we already hold as well as any of your Personal Information that we receive in the future. Your continued use of the Website and/or services following any changes to the Privacy Policy (which will be notified to you as described above) signifies your acceptance of those changes.
It is important that the Personal Information we hold about you is accurate and current. Please keep us informed if your Personal Information changes during your relationship with us.
Definitions
"Disclose" in relation to Personal Information means to make accessible or visible to others outside the entity and to release the subsequent handling of that Personal Information from our effective control. This can be done orally, in writing, or by electronic or any other means to any person or entity.
"User" means an individual who has registered with the Application or who has provided Personal Information to us.
"Minor" means any individual under 18 years of age, or as defined under the laws of their jurisdiction or residence, including but not limited to the Children’s Online Privacy Protection Act (COPPA) in the US and Article 8 of the GPDR in the EU and UK.
"Personal Information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not. This information includes, for example, name, e-mail and mailing address, phone number, account and billing information, and other information provided by a user of the application or incidental to providing products and services to you.
“Sensitive Information” means:
- information or an opinion about an individual's racial or ethnic origin, political opinions, membership of a political association; religious beliefs or affiliations; philosophical beliefs; membership of a professional or trade association; membership of a trade union; sexual orientation or practices; criminal record, provided the information or opinion otherwise meets the definition of personal information;
- health information about an individual;
- genetic information about an individual that is not otherwise health information;
- biometric information that is to be used for the purpose of automated biometric verification or biometric identification;
- biometric templates.
"Application" means CosmosGO, AvalonGO or GlobusGO mobile app, and any domestic or internationally-owned or managed Website of the Globus family of brands that may be accessed through it. This includes on-trip service and provided devices.
What Personal Information do we collect about you?
We may collect, use, store and transfer different kinds of Personal Information about you which we have grouped together as follows:
- Identity Information includes first name, maiden name, last name, and marital status, and title, date of birth, gender and passport information.
- Contact Information includes billing address, email address and telephone numbers.
- Financial Information includes payment card details.
- Employment Information includes information that you may provide on a job application to us.
- Special Categories of Personal Information (sensitive information) may include any relevant information about your health, medical conditions and/or disabilities, religious beliefs, dietary or other requirements (if applicable).
- Transaction Information includes details about payments to and from you and other details of services you have purchased from us.
- includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Websites.
- Profile Information includes purchases made by you, your interests, preferences, and feedback and survey responses.
- Usage Information includes information about how you use our Website and services.
- Marketing and Communications Information includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Minors
We do not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via the Website. We do not knowingly collect Personal Information from any Minor and will not deliberately use such information. Generally, if you are under 18, you may use the Website only with the involvement of a parent or guardian. Our policy regarding minors encompasses compliance with particular laws in the United States, United Kingdom, Australia, New Zealand, Canada and India. We respect the privacy of minors and are committed to complying with COPPPA in the US. We do not intentionally collect Personal Information from children under the age of thirteen (13) and you may not register or transact on the Website if you are under 13. If we learn that a child under 13 has provided Personal Information to us without verification of parental consent, we will take commercially reasonable steps to delete that information. If you are under the age of sixteen (16) and reside in the European Union, you must provide an email address for your parent or legal guardian, and before you can access or use the Website, we must receive your parent’s or legal guardian’s express consent. You will not receive access or the ability to use the Website and we will not collect additional Personal Information from you, until we receive your parent’s or legal guardian’s consent. Your parent or legal guardian may revoke consent at any time and we will take reasonable steps to delete all Personal Information collected from you. We will also provide your parent or legal guardian with the ability to request to review your Personal Information, prohibit further collection of your Personal Information, and delete, or instruct the deletion of your Personal Information.
Aggregated Information
We routinely collect, use and share (disclose) Aggregated Information such as statistical or demographic information for multiple purpose. Aggregated Information may be derived from your Personal Information but is not considered Personal Information in law as this information does not directly or indirectly reveal an individual's identity or infringe upon their rights. For example, we may aggregate your Usage Information to calculate the percentage of users accessing a specific Website feature. However, if we combine or connect Aggregated Information with your Personal Information so that it can directly or indirectly identify you, we treat the combined information as Personal Information which will be used in accordance with this Privacy Policy.
How is your Personal Information collected?
Generally, we collect your Personal Information directly from you or via a registered travel agent, through completion of an online form, an interaction or exchange in person or by way of telephone, email or post or through the use of the Application or our Websites. Generally, we will only collect your Personal Information from sources other than you if it is unreasonable or impracticable to collect your Personal Information from you.
Third party Personal Information that we collect
When you book a trip with us, if we cannot collect it directly from the people you are travelling with, we will need to ask you for Personal Information (including Identity Information, Contact Information and Special Categories of Personal Information) of those people, and also Personal Information (including Identity Information and Contact Information) for your emergency / next of kin contacts for while you are your trip. We need this information to comply with our obligations in providing the trip you’ve booked. We assume that in providing us with Personal Information about third parties that you have their consent to provide it to us.
If someone books a trip on your behalf, we will need to ask them for certain of your Personal Information (including Identity Information, Contact Information and Special Categories of Personal Information) and also Personal Information (including Identity Information and Contact Information) for your emergency / next of kin contacts for while you are your trip. We need this information to comply with our obligations in providing the trip being booked.
If you fail to provide Personal Information
Where we need to collect Personal Information by law, or under the terms of a contract we have with you, and you fail to provide that Personal Information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a trip and related services). In this case, We may have to cancel the services you have booked with us (and our standard cancellation terms will apply) but we will notify you if this is the case at the time.
How we use your Personal Information
Information about our guests is an important part of our business, and we are not in the business of selling it to others. We will only use your Personal Information. including sharing your Personal Information with our authorized service providers that perform services or functions on our behalf.
We will only use your Personal Information where it is reasonably necessary for the purposes of:
- performing the contract we are about to enter into or have entered into with you;
- accounting, billing, or other internal administrative purposes;
- our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
- to comply with a legal or regulatory obligation; or
- sending direct marketing communications to you via email, text message, telephone or mail/post where you have provided your explicit consent to such processing of your Personal Information. You have the right to withdraw consent to such marketing at any time by contacting us.
We will only use your Special Categories of Personal Information where you have provided your explicit consent to such processing of that Personal Information. You have the right to withdraw your consent to such use at any time, but please be aware that this may mean that we are unable to provide some or all of the services that you have booked with us (and our standard cancellation terms will apply).
We do not sell or market products to Minors. Minors are not eligible to register with, use or purchase services via the Website. We do not knowingly collect Personal Information from any Minor and will not deliberately use such information. If you are under 18, you may use the Website only with the involvement of a parent or guardian.
We have set out, in a table format (PDF) below, a detailed description of all the ways we plan to use your Personal Information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may use your Personal Information on the basis of more than one lawful ground depending on the specific purpose for which we are using your information. Please contact us if you need details about the specific legal ground we are relying on to use your Personal Information.
Keeping your information safe
We promise we’ll do all we can to keep your information safe. We will store your information securely, encrypt it when we share (disclose) it, and only hold it for as long as We need to. In addition, we limit access to your Personal Information to those employees, agents, contractors and other third parties who have a business need to know. They will only access or use your Personal Information on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
When we have to share (disclose) your details
So that we can meet our obligations to you, such as sending you a brochure you’ve requested, a trip quote, or provide the trip you’ve booked, we will pass (disclose) your Personal Information onto our suppliers as we need to. This allows them to meet your requests, ensure you have a hassle-free trip, and that they can get in touch if you need assistance.
Some of these suppliers will be outside the United States, United Kingdom, Australia, New Zealand, Canada, South Africa, Asia and European Economic Area (‘EEA’). We require all of our suppliers outside the US, Canada and EEA to work to the same privacy protection standards we do, and a full list of our suppliers online can be provided.
In addition, we may also share (disclose) your Personal Information with the following third parties in the following circumstances:
- With third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Information in the same way as set out in this Privacy Policy.
- If we are under a duty to disclose your Personal Information in order to comply with any legal or regulatory obligation or request;
- To enforce or apply the Terms and Conditions or to investigate potential breaches; and/or
- To protect the rights, property or safety of Globus family of brands, our guests or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions.
International Transfers
Many of our external third parties are based outside the United States, United Kingdom, Australia, New Zealand, Canada, South Africa and Asia and European Economic Area (“EEA”), so their processing of your Personal Information will involve a transfer of Personal Information outside the United States, United Kingdom, Australia, New Zealand, Canada, South Africa and Asia and EEA. Organizations that are based outside the United States, United Kingdom, Australia, New Zealand, Canada, South Africa and India and EEA may not be subject to privacy protection laws which offer the same rights and protections to you as is the case within the United States, United Kingdom, Australia, New Zealand, Canada, South Africa and Asia and the EEA.
Therefore, wherever we transfer your Personal Information out of the United States, United Kingdom, Australia, New Zealand, Canada, South Arica and Asia and EEA, we take reasonable steps as required by applicable laws and regulations to safeguard your Personal Information, including using specific contracts and contractual language for service providers. For further details, please see information regarding the CCPA in the United States, Canadian Privacy Laws, Australian Privacy Principles, New Zealand Privacy Act, UK General Data Protection Regulations and the GDPR within the EU.
Please contact us if you want further information on the specific mechanism used by us when transferring your Personal Information out of the United States, United Kingdom, Australia, New Zealand, South Africa, Canada and Asia and EEA.
Your personal details when you book through a reseller
If you have booked through a travel agent or reseller, they may have separately asked for your permission for them to contact you or send you marketing information. Please refer to the reseller’s privacy policy to understand how they process your Personal Information. If you believe a reseller is using your information in a way you have not consented to, you should contact them directly.
How long will you use my Personal Information for?
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your Personal Information can be provided. For further information, please contact us.
How is information stored and processed?
Personal Information collected on our Website, or received by us from you or third parties, may be stored and processed in Australia, the US or any other country where we or our service providers maintain facilities.
The servers and databases in which information is stored may be located outside the country from which you accessed the Website, and in a country that does not have the same privacy laws as your country of residence. The Personal Information you provide to us may be transmitted abroad for the purpose described in this Privacy Policy, but we will collect, hold, use, and disclose your Personal Information only in accordance with this Privacy Policy.
Analytics and Targeted Advertising
We, as well as third-party vendors acting on our behalf (such as Google or Facebook), may use first-party cookies, third-party cookies, tracking pixels, and scripting techniques to gather anonymous analytics and statistics about our services and how they are being used by our visitors so we can improve our services. Our web server storage logs may collect the domain names, internet protocol addresses, the types of web browsers, and certain information of visitors to the Website.
Information about your activities online may be collected for use in providing advertising tailored to your individual interests, either by us, our affiliates, or third parties. We may work with third parties such as network advertisers and ad exchanges to serve advertisements across the internet and may use third party analytics service providers to evaluate and provide us and/or third parties with information about the use of these ads on third party Websites and viewing of ads and of our content.
We and these third-party vendors, including Google, may use third-party technologies (such as a Facebook Custom Audience Pixel) together with Our own first party technologies in order to analyse ad impressions, your use of ad services, and interactions with these ad impressions and ad services. The information collected may also include information about your visits to Our Website, including the pages you have viewed and what content you have seen. These third-party tracking technologies may be set to, among other things: (a) help deliver advertisements to you that you might be interested in; (b) prevent you from seeing the same advertisements too many times; and (c) understand the effectiveness of the advertisements that have been delivered to you.
You can opt out of certain advertising by visiting the Network Advertising Initiative consumer opt out page at http://optout.networkadvertising.org/, by using the Google Analytics Opt-out Browser Add-on available at https://tools.google.com/dlpage/gaoptout, or by visiting the Digital Advertising Alliance's opt-out page at https://www.aboutads.info/choices. For more information on the privacy practices of Google, please visit Google's Privacy & Terms web page: https://policies.google.com/privacy?hl=en. Please note, at this time we do not respond to browser based “do not track” signals.
Third-party links
Our Website may include links to third-party Websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share (disclose) information about you. We do not control these third-party Websites and are not responsible for their privacy statements. When you leave Our Website, we encourage you to read the privacy notice of every Website you visit.
Social Media Sites
When you interact with an account on or through a social media platforms, such as Facebook, YouTube, Pinterest, Instagram, or Travel Blog, we collect the Personal Information that you make available to us on that page or account, including your user ID and/or username, and any information you have made public in connection with that social media service. Please note, however, that We will comply with the privacy policies of the corresponding social media platform and We will only collect and store such Personal Information that we are permitted to collect by these social media platforms.
Our Website includes social media widgets, such as Facebook, YouTube, Pinterest, Instagram, and Travel Blog widgets. These features collect information about your IP address and which page you’re visiting on our Website, and they set a cookie to make sure their features function properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. Your interactions with those features are governed by the privacy policies of the companies that provide them.
Payments and Financial Information/Credit Card Information Security
We may use third-party services for payment processing (e.g., payment processors). We will not store or collect your complete payment card or banking details. Information may be provided directly to our third-party payment processors whose use of your personal information is governed by their respective Privacy Policy.
We use 3DES encryption and the https security protocol to communicate with your browser software. This method is the industry standard security protocol, which makes it extremely difficult for anyone else to intercept the credit card information you send to Us. Companies We work with to process credit card transactions also use 3DES encryption and security protocols. We collect credit card information solely to complete a single transaction. We do not store complete credit card information.
Tailoring your communications
We always want our communications to be relevant, useful and inspiring, to help you choose your next dream trip.
That’s why we ask you up-front if and how you’d like to receive marketing information from Us. We know you don’t like receiving unwanted mail or emails, and We don’t want to send them either.
We will get your consent before we send you direct marketing by email, text message, post or telephone and before We share (disclose) your Personal Information with any company outside the Globus family of brands for marketing purposes.
We also use the information you have provided and that we collect about you, such as the destinations you prefer to travel to, where you live and your age, to tailor communications we send you. We do this to ensure you always get a great service fully tailored to your preferences.
We do not sell your Personal Information. This includes our partners and vendors. We only retain your information for the specific purpose of performing specific services offered by us. You can opt-out from receiving communications from us via any email sent (look for the unsubscribe option).
We require all third parties to respect the security of your Personal Information and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Information for their own purposes and only permit them to process your Personal Information for specified purposes and in accordance with our instructions. If you are a California resident and have an established business relationship with us, you can request a notice disclosing the categories of Personal Information we have shared (disclosed) with third parties, if any, for the third parties’ direct marketing purposes, during the preceding calendar year. To request a notice, please submit your request to privacy@globusfamily.com.au. You may choose to opt-out of the sharing of your Personal Information with third parties for marketing purposes at any time by submitting a request in writing to the contact information at privacy@globusfamily.com.au. Please note that this opt-out does not prohibit disclosure made for non-marketing purposes.
Access and correction
You have a right to request access to Personal Information we hold about you.
You have a right to request that Personal Information we hold about you is corrected.
No fee usually required
You will not have to pay a fee to access your Personal Information (or to exercise any of the other rights set out above). However, we may charge a reasonable fee for giving you access if your request is excessive, frivolous or vexatious. Alternatively, we may refuse to comply with your request in these circumstances or for any other reason allowed by law.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Information (or to exercise any of your other rights). This is a security measure to ensure that Personal Information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within 30 days. Occasionally it may take us longer than 30 days, for example if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Making a complaint
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 contractual arrangements between you and us.
Contact details
We’re always happy to answer any questions as well. If you have any concerns or would like questions answered, then get in touch. If you have any questions about your personal information we hold, we will do our best to answer them.
If you want to make a privacy complaint, have a specific enquiry about your Personal Information we hold, or want to access your Personal Information please write to or call our Privacy Officer at:
Postal address: Level 6, 68 Pitt St, Sydney NSW 2000, Australia
Email address: privacy@globusfamily.com.au
Telephone number: 1300 230 234
To find out more about information protection and your privacy, the Office of the Australian Information Commissioner’s website has information on all current information protection laws and your rights. Find out more at https://www.oaic.gov.au/privacy
Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when Websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly.
We utilise email tracking systems that provide us with information such as who opened or forwarded an email, the time it was opened, and whether the reader clicked certain links within the email.
What is a cookie?
A cookie is a small text file, which often includes a unique identifier that is sent to your computer or mobile phone (referred to here as a "device") browser from a website's computer and is stored on your device's hard drive. There are various types of cookies which perform different functions, such as remembering which items you have placed in your shopping basket or recording your browsing habits. The information recorded by the cookie is retrieved on your next visit to our sites. For more information about cookies, visit www.aboutcookies.org
The cookies We use don't detect any information – including personal information such as credit/ debit card details that you may have stored on your computer. Cookies cannot harm your computer or access information saved on your hard drive.
How do we use cookies?
We use a number of cookies on websites for a variety of reasons. Some cookies are essential to be able to provide our services to you, such as purchasing a holiday. Others help Us provide a better service to you, such as providing you with relevant prices and offers through our marketing activity or allowing you to share holidays through social media channels.
We currently use the following types of cookies on our sites.
Strictly necessary or functional cookies: these cookies are essential to allow you to fully use our website and its full features, such as buying a holiday. These cookies do not gather information about you that could be used for marketing.
Performance or analytics cookies: these cookies collect information about how our visitors use our website, to help us understand what sections of our site are popular, and help us fix errors on any of our web pages.
Marketing and targeting cookies: these collect information about your browsing habits and are placed by third-party providers and ourselves. The information in these cookies is anonymized but they contain a unique key that is able to distinguish individual browsing habits, or if an individual user has clicked on an advert We have placed. We use these cookies to understand if Our marketing is effective, and if our recommendations for you are a good fit. We use the following third-party cookies to do this: , Google Ads, Facebook, and Bing.
How to manage cookies
Most web browsers will accept cookies, but if you would rather that We did not collect your information in this way you can choose to accept all or some or reject cookies in your browser's privacy settings. Rejecting all cookies means that certain features cannot be provided to you - for example, you may not be able to book a holiday on Our website. Each browser is different, so check the 'Help' menu of your browser to learn how to change your cookie preferences.
How to check cookies are enabled on a PC
Google Chrome
1. Click on 'Tools' at the top of your browser window and select Options
2. Click the 'Under the Hood' tab, locate the 'Privacy' section, and select the 'Content settings' button
3. Now select 'Allow local data to be set'
Microsoft Internet Explorer
1. Click on 'Tools' at the top of your browser window and select 'Internet options', then click on the 'Privacy' tab
2. Ensure that your Privacy level is set to Medium or below, which will enable cookies in your browser
3. Settings above Medium will disable cookies
Mozilla Firefox
1. Click on 'Tools' at the top of your browser window and select Options
2. Then select the Privacy icon
3. Click on Cookies, then select 'allow sites to set cookies'
Safari
1. Click on the Cog icon at the top of your browser window and select the 'Preferences' option
2. Click on 'Security', check the option that says 'Block third-party and advertising cookies'
3. Click 'Save'
How to check cookies are enabled on a Mac
Google Chrome
1. Click on 'Chrome' at the top of your browser window and select 'Preferences' options
2. Click the 'Under the Hood' tab, locate the 'Privacy' section, and select the 'Content settings' button
3. Now select 'Allow local data to be set'
Safari
1. Click on 'Safari' at the top of your browser window and select the 'Preferences' option
2. Click on 'Security' then 'Accept cookies'
3. Select the 'Only from site you navigate to'
Mozilla Firefox
1. Click on 'Firefox' at the top of your browser window and select 'Preferences' options
2. Then select the Privacy icon
3. Now select 'Accept cookies from sites'
Microsoft Internet Explorer 5.0 on OSX
1. Click on 'Explorer' at the top of your browser window and select 'Preferences' options
2. Scroll down until you see 'Cookies' under Receiving Files
3. Select the 'Never Ask' option
Site Security
All of the personal information you give Us is protected by a secure server. The secure server software SSL (Secure Socket Layer) encrypts all information you enter before it is sent to Us. The information is only de-encrypted when it reaches our server.
We also have a ‘Firewall’ in place to protect our internal information from the Internet. If you make payment on-line all of your personal information is encrypted using SSL ("Secure Sockets Layer"). SSL is an industry-standard protocol for encryption over the internet. This prevents your personal information from being read by anyone else. This security layer is 128bit encrypted and protects your personal information from unauthorized access and malicious attack.
