Tourism Holdings Ltd (thl) Privacy Centre

This Privacy Policy explains how we process your personal data as well as your rights associated with that data.

This Privacy Policy is provided in a layered format so you can click through to the specific areas set out below. Alternatively, you can contact privacy@thlonline.com or visit our privacy centre here.

Tourism Holdings Limited (thl) is a global family of RV brands delivering the most enriching way to experience the world. We are listed on the New Zealand and Australian Stock Exchanges. We believe in championing a way of traveling that creates true value for the people, places, and environments we touch. Together, we are more vertically integrated, globally connected, and ambitious than anyone else in RV. We design and build. We rent. We sell. We deliver to hundreds of thousands of customers every year across our operations in New Zealand, Australia, United Kingdom & Europe, USA, and Canada; and franchises in Southern Africa and Japan. Amplified by our connections into the broader tourism industry and manufacturing sectors. Collectively we represent over 30 brands, each with strong brand equity and local heritage in the markets they operate. Details of our brands can be found here.

Together we are the data controllers for the purposes of this policy, which is issued on behalf of all brands and entities within the thl group of companies (thl group). When we mention "thl", "we", "us" or "our" in this privacy Policy, we are referring to the relevant entity in the thl group responsible for processing your data. For any privacy related enquiries contact our Chief Privacy Officer at privacy@thlonline.com.

We also use a network of independent agents and licensees when providing our services around the world. Please note that those agents and licensees are not covered by this Policy, and we are not responsible for the privacy practices of any agent, licensee or other third party with whom you may transact before or at the same time as using our products or services.

The data we collect will depend on how we have interacted with you and what services and products you have requested from us over time. We may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

1. Identity Data includes first name, last name, username or similar identifier, title, date of birth, age, gender, driver’s licence, passport details, security camera recordings and recordings of telephone conversations.
2. Contact Data includes address, telephone numbers and email address.
3. Financial Data includes payment card details. We do not store any customer credit/debit card information as this is managed by a payment gateway provider who are PCDI DSS compliant.
4. Transaction Data includes details of your previous bookings with us, payments to and from you and other details of products and services you have purchased from us.
5. Technical Data includes internet protocol (IP) address, your login data, 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 this website.
6. Location Data includes global position system vehicle tracking and diagnostics (telematics) and other location information obtained from smartphones, tablets, sat-navs or other devices that monitor your current and previous geographic locations.
7. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, and survey responses. Data related to any loyalty programme membership.
8. Usage Data includes information about how you use our website, products, and services.
9. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences. Data shared for any market research, surveys, or competitions.
10. Vehicle-sourced Data includes information collected by data systems within a vehicle about its condition and performance (including mileage, fuel, and other operational data) and your operation of the vehicle, including your speed, time, fuel consumption and distances travelled.

We also collect, use, and share Aggregated Data such as statistical or demographic data. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat that combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any information about criminal convictions and offences, although we may be required to briefly hold and pass on any driving infringements that you incur while renting our vehicles.

Refusal to provide your personal data: You do not have to provide your personal data when we request it, but if you choose not to, we may not be able to respond to your queries and perform any contract we have or are trying to enter into with you (for example, to provide you with a rental vehicle). That may mean we have to cancel a product or service you have with us. We will notify you at the time if that is the case.

We use different methods to collect personal data from and about you including through:

1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms on our websites and mobile applications, on third-party websites or in paper form or by corresponding with us by post, phone, email or otherwise. That includes personal data you provide when you:
1. make an inquiry or booking with us or otherwise apply for any of our products or services.
2. purchase a product or service from us.
3. create an account on our website or mobile applications.
4. subscribe to our services or publications.
5. request marketing to be sent to you.
6. enter a competition, promotion, or survey (including on third party social media platforms).
7. give us feedback or enter our premises on which security cameras are operating.
8. speak to us on the telephone.
2. Automated technologies or interactions. As you interact with our website and mobile applications, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy here for further details. We may combine Technical Data (some of which will be anonymous) with other personal data we have collected from you in order to understand and measure your online experiences and determine what products, promotions and services are likely to be of most interest to you.
3. Third parties or publicly available sources. We may receive personal data about you from various third parties and certain public and technical sources:
1. Technical Data from analytics providers such as Google and advertising networks such as Facebook and Identity, Location and Vehicle Sourced Data when using our vehicles.
2. Identity and Contact Data when you make a booking or apply for our products or services through a third party (such as a travel agent), through interactions (including transactions) with our service providers, business partners, agents, affiliates and subsidiaries (including other travel providers and insurance companies), from data brokers or aggregators such as Facebook and from publicly availably sources such as phone directories, membership lists, professional and trade associations, government, bankruptcy or court registry searches and electoral registers.
4. Unsolicited personal data. If we receive personal data that we have taken no active steps to collect (such as a customer complaint or testimony that has been sent with personal information), then we may keep that personal data if it is reasonably necessary for one or more of our functions or activities.

We will use your personal data when the law allows us to and in the circumstances and for the purposes set out in the table below.

We aim to provide you with choices about how your personal data is used for marketing and advertising purposes.

You will only receive marketing communications from us if you have opted in or consented to receiving those communications. We may use your personal data collected in those circumstances to contact you and keep you up to date with the latest news, events, special offers and promotions of our brands, including by email, text messages or post.

You can update your subscription preferences or unsubscribe from marketing communications at any time by following the update preferences or unsubscribe instructions provided in each such communication. Alternatively, you can contact us at privacy@thlonline.com or by clicking here. Once you do this, we will update our records to ensure that you do not receive further marketing messages.

We may display advertising for you to see on third party websites, including social media sites such as Facebook. We do this by matching information about your activity on thl group websites with information collected on third party sites. That may involve using your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider we need to use it for another reason directly related to and/or compatible with the original purpose, and such secondary purpose is permitted under law. If you wish to get an explanation as to how the processing for the secondary purpose is directly related to and/or compatible with the original purpose, please contact us.

Please note that we may process your personal data without your knowledge or consent, in compliance with the terms of this Privacy Policy, where this is required or permitted by law.

We may have to share your personal data with the following parties for the purposes set out in the table in section 4.1 above or for other purposes directly related to the purpose for which the information was collected.

1. thl group companies: Other companies in the thl group acting as controllers or processors and who are based in Australia, New Zealand, the United States, and the United Kingdom and provide IT, storage and system administration services and undertake leadership reporting.
2. Service providers: Contracted third parties providing the following services:
1. data processing
2. IT and system administration
3. marketing, market research and communication
4. printing and distribution of marketing materials
5. mailing, freight, and courier
6. price comparison websites
7. Professional advisers acting as processors or joint controllers, including lawyers, bankers, auditors, consultants, insurers, and recruiters.
3. Other third parties: 
1. regulators and other authorities acting as processors or controllers who require reporting of processing activities in certain circumstances and/or where disclosure is required by law.
2. 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 data in the same way as set out in this privacy policy.
3. other entities in the same or similar industries to us, for reasons of public safety
4. where the law requires or authorises us to do so
5. other third parties that you have been informed of at the time any information is collected from you.

As a global company we operate our business in multiple regions and countries. This means we collect, store, process and transfer personal information across borders including countries outside your region or the European Economic Area, Switzerland, and the United Kingdom (EEA+). For the most part, your personal data is collected, stored, and processed outside the EEA+ with datacentres in Australia, Canada and USA

Certain entities in the thl group may collect personal data inside the EEA+.

If we transfer your personal data out of the EEA+, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented.

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the relevant EEA+ body.
2. Where we have entered into approved standard contractual clauses with the recipient to give personal data the same protection it has in the EEA+.
3. Where we use providers based in the US, we may transfer data to them if they are part of the EU-U.S. Data Privacy Framework, the UK Extension to the EU-US Data Privacy Framework, or the Swiss-US Data Privacy Framework which requires them to provide similar protection to personal data shared between the EEA+ and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA+ as per contact details in section 12.1

For individuals residing outside of the EEA+, if we disclose any of your personal data to a foreign entity established outside of the jurisdiction in which the personal data is collected, we will comply with any applicable laws relating to the offshore disclosure of such personal data.

Depending on the privacy laws applicable in the jurisdiction in which you reside, you may have the following rights in relation to your personal data.

1. Access: you can request access to a copy of the personal data we hold about you and to check that we are lawfully processing it.
2. Rectification: you can request that any incomplete or inaccurate data we hold about you is corrected, though we may need to verify the accuracy of the new data you provide to us
3. Erasure: when your data is no longer needed for the purposes for which it was provided, we will delete it. You can ask us to delete or remove your personal data where there is no good reason for us continuing to process it, where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
4. Object to processing: where we are relying on a legitimate interest (or those of a third party) and you believe our processing of your personal data impacts your fundamental rights and freedoms, you may object to such processing for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms.
5. Restrict processing: you can ask us to suspend the processing of your personal data: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
6. Data portability: you can request that your personal data is transferred to you or a third party. We will provide you or a third party you have chosen with your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information that you initially provided consent for us to use or where we used the information to perform a contract with you.
7. Withdraw consent: you may withdraw your consent to our processing of your personal data. If you do so, we may not be able to provide certain products or services to you. We will advise you if that is the case when you withdraw your consent.
8. Opt-out: In some states in the United States, you may have the right to opt out of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. To provide you with more interesting and customized information, promotions, and advertising, we disclose personal data to thirdparty providers of advertising services who may use such personal data for their own purposes or to serve other customers, including to display our advertisements to you on sites and services that we do not operate. If you reside in certain states in the United States, you have or will soon have the right to opt out of the use of your personal data for these targeted advertising or crosscontext behavioral advertising purposes. To submit such a request, please click the following link: Do Not Sell or Share My Personal Information: Your Opt-Out Rights, in which case we will respond to your request in accordance with applicable law.

The rights and options described above are subject to limitations and exceptions under applicable law. We will respond to your requests to exercise your privacy rights in accordance with applicable law. We may request additional information from you to verify your identity and complete your request. If we deny your request, we will explain why. In some states in the United States, you have the right to appeal our denial of your request, which you may exercise by responding to the message we send to you communicating our denial stating that you appeal our decision. In these cases, we will reconsider your request and then notify you of our decision.

If you wish to exercise any of the rights set out above, please contact our Data Protection Officer (see section 12.1 below)

No fee usually required: You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive and it is permissible under local law to do so. Alternatively, we may refuse to comply with your request in these circumstances if permitted by applicable local law. If we choose to deny your request, we will inform you of the decision and your right to complain to the supervisory authority within the statutory deadlines, which is generally 1-month from the date of the request.

What we may need from you: We may need to request specific information from you to help us confirm your identity and ensure that personal data is not disclosed to any person who has no right to receive it.

Time limit to respond: We respond to all legitimate requests without undue delay and at the latest within one month. Occasionally, if your request is particularly complex or you have made a number of requests, we may need to extend this by up to a period of two months or such other timeframe as may be permitted by applicable law, in which case we will notify you and keep you updated.

We have put in place security measures to protect your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We regularly review our security procedures to consider new technologies and methods.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

We will only retain your personal data 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 data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

EEA Supervisory Authorities: If you are an European Economic Area data subject and feel that your personal data has been processed in a way that does not comply with the General Data Protection Regulation (GDPR), you may lodge a complaint with the relevant supervisory authority in your country. We would, however, appreciate the chance to deal with your concerns before you approach them, so please contact us in the first instance.

Data Protection Steward: Tourism Holdings Limited have appointed a data protection steward who is responsible for overseeing privacy issues for the thl group. If you have any questions or complaints about this Privacy Policy, including any requests to exercise your rights in relation to your personal data, please contact the steward using the details set out below.

1. Email address: privacy@thlonline.com
2. Postal address: Private Bag 92133, Auckland, New Zealand 1142

EU Representative: Tourism Holdings Limited have appointed an EU Representative whose tasks are to serve as a contact person for supervisory authorities and data subjects and can be contacted as follows:

1. Name: Stephen Hart
2. Email address: eu.gdpr@thlonline.com

This version was last updated on 27th February 2024.

We reserve the right to update and change this Privacy Policy at any time by posting changes on this webpage or applicable mobile apps. Changes will take effect from the time they are posted. We will use reasonable endeavours to communicate those changes to you on our website and mobile apps or via other channels that we think are suitable.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Comply with a legal or regulatory obligation means processing your personal data where that is necessary for compliance with one of more of our legal or regulatory obligations.

Data controller means whomever determines the purposes and means of processing personal data. Legitimate Interest means our interests in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Performance of Contract means processing your data where that is necessary under a contract with you or to take steps at your request before entering into such a contract.

Personal data means any information about an individual that can be used to identify that person directly or indirectly by reference to a range of identifiers. It does not include anonymous data where the identity of the individual has been removed.

Processing means any operation or set of operations performed on personal data.

Processor means the entity that processes personal data on behalf of the controller.