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Privacy Policy

1. Who are We?

This Privacy Policy applies to all personal information handled by Tramada Systems Pty Ltd, a company incorporated in NSW Australia with a registered office at Level 13, 255 Elizabeth Street,, Sydney NSW 2000 Australia (“Tramada, we, us”).

2. Preamble

Tramada is bound by the Privacy Act 1988 (Cth) (“Privacy Act”) and the Australian Privacy Principles (“APPs”) set out in the Privacy Act and we are committed to handling personal information in line with the Privacy Act.

This Privacy Policy is intended to provide you with a general explanation of how we may collect, store, use and disclose personal information.

This Privacy Policy was last amended on 13 June 2025 and will be reviewed and updated from time to time to ensure that it reflects our current information handling practices and any relevant legislative changes.

This Privacy Policy sets out Tramada’s policies concerning the management of personal information and describes the types of personal information Tramada holds, the purposes for which it holds that personal information, and the ways in which Tramada collects, uses and discloses personal information.

Note that the policies or practices of any third party and/or your organisation may differ, and, unless otherwise provided for by applicable law, we are not responsible for any use or disclosure of your personal information by anyone at any travel agency with which you engage (“Agency”), your organisation, or for any acts or omissions of any Agency or its personnel, your organisation, or its Travel Arrangers. If you have any questions about how any third party handles your personal information or books or manages travel on your behalf, please contact the appropriate representative or organisation.

3. What kinds of personal information do we collect?

The types of personal information we may collect about an individual will depend upon the nature of our interaction with them. We may collect the following personal information from you:

  • details such as your name, address, phone number(s) or email address;
  • payment details, including your credit card number or bank account number;
  • information that identifies you, like your date of birth, passport number, drivers’ licence or other proof of identity documentation;
  • information about products or services that you order or receive, including travel itineraries or travel history and traveller preferences;
  • employment details and education qualifications, including your employment history or employer ID number if applicable;
  • internet cookies.

If you choose not to provide the personal information, we ask you for, we may not be able to offer our products and services to you or facilitate other service providers providing products or services. If applicable, we may also be unable to properly assess any application for employment.

4. Collection and holding of your personal information

Travel Agency Programs: Generally, to help Agencies manage their customers’ travel bookings and their client servicing needs, Agencies contract Tramada to use its proprietary software to carry out some aspects of their processing. Under this contract, the Agency will designate Registered User/s (“Registered User”) to manage and administer the travel needs of its individual clients and of its corporate clients’ personnel and their associates. Some corporate clients will in turn engage an internal travel arranger (“Travel Arranger”) to manage the travel needs of its personnel and their associates. Registered Users and Travel Arrangers both book and manage the travel needs of travellers (“Travellers”). The Agency uses sensitive billing information (such as cardholder name, credit card number, and expiration date) for the purposes of completing the travel bookings you make with an Agency Registered user or your Travel Arranger. Tramada provides the Agency with the software to process and store this information and to facilitate the services the Agency provides you.

Noting the above, we generally collect your personal information in the following ways:

  • Directly. We may collect information directly from you via call or other forms. For instance, we may collect information as part of call to and from our Tramada software service help desk. You may choose to provide certain contact information by filling out our enquiry form;
  • From other third parties: We also may collect information from third parties, including from an Agency or Travel Arranger who you have authorised to provide us with you information or have your profile data loaded into our system.

Following collection, personal information is held by us as described in section 6.

5. Purpose or which personal information is handled by us

We may use the information we collect for a variety of purposes, including:

  • to provide product and services to you or facilitate the provision of products and services to you by a third party;
  • to manage your travel bookings and servicing needs,
  • to communicate to you in relation to products and services and provide support;
  • for marketing purposes, including direct marketing purposes where permitted under applicable laws;
  • administering our relationship with you or an Agency with which you engage;
  • for the purposes of record keeping, internal staff training, quality assurance and call monitoring purposes;
  • for the purposes of ensuring compliance with applicable laws and regulations, undertaking verification and authentication purposes as well as safety and security purposes; and
  • to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Tramada; and/or
  • in response to valid requests by public authorities, including to meet national security or law enforcement requirements.

6. How is your personal information held?

Booking travel for someone else: When you make a reservation for someone else through the Agency, they may request personal information and travel preferences about that individual. You must obtain the consent of other individuals and ensure such other individuals review this Privacy Policy prior to providing us with their personal information and travel preferences, as any access to view or change their information will be available only through your account. The Agency will collect, use and disclose that individual’s personal information only for the purposes of making a reservation.

How your personal information gets into the Tramada system?
Before any personal information can be entered into the Tramada processing system by an Agency, there will be a requirement for the Agency Registered User to sign in via a password protected login. Tramada also encourages Agencies to use two-factor authentication for their logins. Personal Traveller information being entered by a Travel Arranger will require the Arranger to sign in via a secure online booking engine or via the organisation’s online portal which, in turn, will have secure integrations with the Agency and /or Tramada and which will also have their own individual Privacy Policies. Generally, Tramada stores all information provided to it including, without limitation, all personal information about you that you specifically and voluntarily provide or give to the Agency Registered User or the Travel Arranger in any other way. This includes information that can identify you, including first name, surname, telephone number and email address, passport information and billing information (such as credit card number, cardholder name, and expiration date). Your Agency Registered User or Travel Arranger may enter into the Tramada system additional personal information about you such as your employer ID number.

Tramada provides software in which Agencies store and process personal information. We do not modify or disclose this information and only access it to the extent required to solve processing issues for Agencies and for account administration purposes.

7. Disclosure of your information

Tramada may share your personal information with third parties, including:

  • our service providers and third-party vendors which provide services or functions to enable us to process information (e.g. internet service providers, payment processing providers, global distribution systems, online booking engines). These service providers and vendors help us provide the Agency with the processing services and applications it requires to efficiently deliver its travel services to you;
  • with your Agency or Travel Arranger;
  • with third party vendors with whom we engage to make your reservation or travel arrangements;
  • regulators to meet Tramada’s legal and regulatory obligations;
  • law enforcement agencies so that they may detect crime or prosecute offenders;
  • our data storage providers, some of which are located overseas – see section 11 of this policy for further information; and
  • Agencies which use Tramada and their customers or others.

8. Your choices with respect to access and correction of your information

You, your Agency Registered User, or your Travel Arranger can access, add, update or delete your information by logging into the Tramada system and/or into the Online Booking Engine used by your organisation.

You may also submit a written request to access or correct the personal information that your Agency and we hold about you. If you make such a request, your Agency and Tramada are entitled to request appropriate identification before servicing such request. You can make a written request for access to your personal information by contacting your Agency or us. We will endeavour to respond to the request (including any passed on by your Agency to us) within an appropriate timeframe and, in any event, within any timeframes required by law.

In relation to Agency Registered Users’ personal information held by Tramada, please note that we reserve the right to send you service announcements, administrative messages, and surveys relating either to the Agency’s account with us or to its transactions with Tramada, without offering the Agency Registered User the opportunity to opt out of receiving them while designated as a Registered User of the Agency and authorised to access the Tramada system.

9. How we protect your information

We are committed to protecting the security of your personal information so we take all reasonable precautions to protect it from unauthorised access, modification or disclosure. Your data is stored in a secure environment and all data transfers are encrypted. We use firewalls, an intrusion detection system, regular vulnerability scanning and access monitoring to monitor access to our production environment. We have secure working environments and work management systems that prevent unauthorised access or copying of personal information (e.g. staff management). We have locked down access to our production environment and data access is only available to staff on a need-to-know basis. All accesses to the production environment are logged. It is not possible to connect a device to our production environment.

We use virus scanning tools and have procedures in place to keep these up to date.

We conduct an annual security awareness programme and this forms part of the Tramada Induction of all new staff members.

We conduct an annual security review in accordance with PCI DSS (Payment Card Industry Data Security Standards), including an external penetration test.

Whilst Tramada has strong processes for managing the security of personal information, security risks do change over time. Tramada will endeavour to stay vigilant in improving and maintaining, from time to time, the security and confidentiality of your personal information.

10. External links

If any part of this website links you to other websites that we do not own or operate, those websites do not operate under this Privacy Policy. We recommend you examine the privacy policies posted on those other websites to understand their procedures for collecting, using, and disclosing personal information.

11. Where your personal information is stored

Tramada stores and processes personal information about Travellers in secure environments in Australia (including an online back-up service) and in other countries. We also use Google Cloud which has strict data protection policies and practices, for data storage. Tramada endeavours to ensure that no matter where it is stored, your information is protected in accordance with this Privacy Policy and the requirements of the applicable data protection law wherever it is processed.

Personal information relating to residents outside Australia will be handled according to this Privacy Policy.

We will only process personal information in ways that are compatible with the purposes outlined above in this Privacy Policy (or those you later authorise).

As explained in this Privacy Policy, we may provide your Personal Data to third parties who perform services on our behalf.

12. Data retention

Your Agency determines for how long your information is to be retained or if it is to be anonymised. We will not retain your information for longer than is necessary for our legitimate business purposes or for legal requirements or archival purposes. However, please be advised that we may retain (on behalf of the Agency) some information after your Agency has closed your account with it, for instance, if this is necessary to meet our legal obligations, including retaining the information for tax, reporting, accounting or other purposes.

13. Cookies and other technology

This section of our Privacy Policy applies solely to information collected on the Tramada website.

Only domain name, not email address, is recognised for visitors to our website.

The information we collect is:

  • used to improve the content of our website; and
  • never shared with other organisations for commercial purposes.

This site collects site performance identifiers. These give us information about how Tramada’s website is used and helps us provide you with a more user-friendly experience. We use analytics cookies (see below) to gather statistics about our site. For example, they help us monitor how many users are on the site and what sections are most popular.

Cookies are small data text files and can be stored on your computer’s hard drive (if your web browser permits). The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. You can choose to not receive a cookie file by enabling your web browser to refuse cookies or to prompt you before accepting a cookie.

Cookies and digital identifiers may be disabled by changing security settings on your web browser, however, doing so may diminish the service that Tramada provides through its website.

14. Changes to this privacy policy

Tramada may update this Privacy Policy in the future. We will notify the Agency about material changes to this Privacy Policy should they be made in the future.

15. How you may complain

You may wish to lodge a complain about our handling of your personal information in breach of the Privacy Act. To lodge a complaint about our handling of your personal information, please contact us as set out in section 16 below.

16. How to contact us

If you have any questions or complaints about our privacy handling process, please contact the Privacy Officer as outlined below. We will do our best to respond within 30 days. If you are making a complaint and it takes longer to resolve, we will keep you up to date on the progress of the investigation. If you are dissatisfied with our handling of your complaint, you have the legal right to complain to the Office of the Australian Information Commissioner.

Email: privacy@tramada.com

Post:
Privacy Officer
Tramada Systems Pty Ltd
Level 13, 255 Elizabeth Street,
Sydney NSW 2000
Australia