GDPR Compliance

Your rights under the General Data Protection Regulation

Introduction

This page provides information about how snug-basin complies with the General Data Protection Regulation (GDPR), which protects the personal data of individuals in the European Union and European Economic Area.

While snug-basin operates in Australia, we recognize and respect the data protection rights of all our clients, including those from the EU/EEA.

Data Controller Information

Data Controller: snug-basin
Address: Level 7, 142 Collins Street, Melbourne VIC 3000, Australia
Email: [email protected]

Legal Basis for Processing

We process your personal data under the following legal bases:

Consent

When you provide explicit consent for us to process your personal data for specific purposes, such as sending marketing communications.

Contractual Necessity

When processing is necessary to fulfill our contractual obligations to you, such as providing the travel services you have requested.

Legitimate Interests

When processing is necessary for our legitimate business interests, such as improving our services, preventing fraud, or ensuring network security, provided these interests do not override your fundamental rights.

Legal Obligation

When processing is necessary to comply with legal obligations we are subject to.

Your GDPR Rights

Under the GDPR, you have the following rights regarding your personal data:

Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of that data along with supplementary information about the processing.

Right to Rectification

You have the right to request correction of inaccurate personal data and completion of incomplete personal data.

Right to Erasure (Right to be Forgotten)

You have the right to request deletion of your personal data in certain circumstances, including:

  • The data is no longer necessary for the purposes for which it was collected
  • You withdraw consent and there is no other legal basis for processing
  • You object to processing and there are no overriding legitimate grounds
  • The data has been unlawfully processed
  • The data must be erased to comply with a legal obligation

Right to Restriction of Processing

You have the right to request restriction of processing in certain circumstances, such as when you contest the accuracy of the data or object to processing.

Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.

Right to Object

You have the right to object to processing based on legitimate interests or for direct marketing purposes. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests.

Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing before withdrawal.

Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority, particularly in the EU member state of your habitual residence, place of work, or place of an alleged infringement.

How to Exercise Your Rights

To exercise any of these rights, please contact us at [email protected] with the subject line "GDPR Request." Please include:

  • Your full name and contact information
  • A clear description of which right you wish to exercise
  • Any relevant details to help us locate your data
  • Proof of identity if requested

We will respond to your request within one month. In complex cases, we may extend this period by two additional months and will inform you of the extension.

Data Processing Activities

Categories of Personal Data

We process the following categories of personal data:

  • Identity data (name, title)
  • Contact data (email address, postal address)
  • Travel preferences and requirements
  • Dietary and accessibility requirements
  • Financial data (payment information processed by third-party processors)
  • Technical data (IP address, browser type, device information)
  • Usage data (website interaction, page visits)
  • Marketing and communications preferences

Recipients of Personal Data

We may share your personal data with:

  • Travel service providers (accommodation, tours, transportation)
  • Payment processors
  • IT service providers (hosting, email, analytics)
  • Professional advisors (lawyers, accountants)
  • Regulatory authorities when required by law

International Data Transfers

As we operate in Australia, your data may be transferred outside the EU/EEA. We ensure appropriate safeguards are in place for such transfers, including:

  • Standard contractual clauses approved by the European Commission
  • Transfers to countries with adequacy decisions
  • Other legally approved transfer mechanisms

Data Retention

We retain personal data only as long as necessary to fulfill the purposes for which it was collected, including:

  • Service delivery and customer relationship management
  • Legal, accounting, and reporting requirements
  • Resolution of disputes and enforcement of agreements

Specific retention periods vary based on the type of data and purpose of processing. You may contact us for information about retention periods for specific data types.

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you.

Data Security

We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, including:

  • Encryption of data in transit and at rest
  • Regular security assessments and updates
  • Access controls and authentication mechanisms
  • Employee training on data protection
  • Incident response procedures

Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify you without undue delay and provide information about the breach and measures taken to address it.

Updates to This Policy

We may update this GDPR compliance information to reflect changes in our practices or legal requirements. Significant changes will be communicated to you via email or prominent notice on our website.

Contact and Questions

If you have questions about our GDPR compliance or data protection practices, please contact us:

Email: [email protected]
Subject: GDPR Inquiry

For general privacy information, please see our Privacy Policy.