Privacy Policy

Last updated: February 2026

1. About This Policy

1.1 This Privacy Policy explains how Touring Golf Pty Ltd (ABN 79 695 344 211) ("TouringGolf", "we", "us", "our") collects, uses, discloses, stores, and protects your personal information when you use our website at touringgolf.com, make a booking, express interest in our tours, or otherwise interact with us.

1.2 We are committed to handling your personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth) and any other applicable privacy legislation.

1.3 By using our website or providing personal information to us, you acknowledge that you have read and understood this Privacy Policy.

2. Information We Collect

Information You Provide Directly

2.1 We collect information that you provide to us when you:

• Submit a booking form or expression of interest
• Contact us by email, phone, or through the website contact form
• Correspond with us about your booking or tour arrangements

2.2 The types of personal information we collect may include:

• Identity information: Full name, date of birth, passport details (number, expiry date, country of issue)
• Contact information: Email address, phone number, postal address
• Booking information: Room preference (twin share or single occupancy), golf handicap, dietary requirements, special requests, how you heard about us
• Health information: Medical conditions, mobility limitations, or other health matters you disclose that are relevant to your participation in the Tour (this is sensitive information under the Privacy Act)
• Emergency contact information: Name, phone number, and relationship of your nominated emergency contact
• Payment information: Payment method and transaction details (card details are processed by Stripe and are not stored by us — see clause 6)

Information Collected Automatically

2.3 When you visit our website, certain information is collected automatically through cookies and analytics services. See clause 3 for full details of the cookies we use and how to manage them.

3. Cookies & Analytics

What Are Cookies

3.1 Cookies are small text files that are stored on your device (computer, tablet, or mobile phone) when you visit a website. They allow the website to recognise your device and collect information about your browsing behaviour.

Cookies We Use

3.2 Our website uses the following cookies:

3.3 Google Analytics 4 (GA4) is a web analytics service provided by Google LLC. It uses the first-party cookies listed above to collect aggregated data about how visitors use our website, including pages visited, time spent on pages, referral sources, and general geographic location (country/region level). GA4 does not store visitors' full IP addresses.

3.4 The data collected by Google Analytics is transmitted to and processed by Google on servers that may be located outside Australia, including in the United States. Google's processing of this data is governed by Google's Privacy Policy and the EU-U.S. Data Privacy Framework.

3.5 We use Google Analytics data solely to understand how our website is used, improve our content and user experience, and measure the effectiveness of our marketing. We do not use Google Analytics for advertising, remarketing, or user profiling purposes.

Cloudflare Web Analytics

3.6 We also use Cloudflare Web Analytics, a privacy-friendly analytics service provided by Cloudflare, Inc. Cloudflare Web Analytics does not use cookies, does not track individual users across sites, and does not collect personal data. It provides us with aggregated, anonymous data about website traffic and page views.

Managing Cookies

3.7 You can control and manage cookies through your browser settings. Most browsers allow you to:

• View what cookies are stored on your device and delete them individually or in bulk
• Block all cookies or only third-party cookies
• Configure settings to accept or reject cookies on a site-by-site basis

3.8 Please note that blocking or deleting cookies may affect the functionality of some websites, though our website will continue to function normally without cookies.

3.9 You can also opt out of Google Analytics tracking specifically by installing the Google Analytics Opt-out Browser Add-on, available at tools.google.com/dlpage/gaoptout.

Cookie Consent

3.10 Under Australian privacy law, cookie consent banners are not currently a legal requirement. However, we are transparent about our use of cookies through this Privacy Policy. If you do not wish to accept cookies, you may adjust your browser settings as described in clause 3.7.

3.11 If you are visiting our website from within the European Economic Area (EEA), the United Kingdom, or Switzerland, Google Analytics is not loaded and no analytics cookies are set on your device. Visitors from these regions are served only by Cloudflare Web Analytics, which is cookieless and does not collect personal data.

4. How We Use Your Information

4.1 We use your personal information for the following purposes:

• Booking and tour delivery: Processing your booking, arranging accommodation, golf, transport, dining, and other Tour services with third-party suppliers, and managing your participation in the Tour
• Communication: Contacting you about your booking, providing Tour information, itineraries, pre-departure details, and responding to your enquiries
• Payment processing: Processing your deposit, progress payments, and final balance through our payment provider (Stripe)
• Health and safety: Using health information you provide to make reasonable accommodations, assess fitness-to-travel considerations, and respond to any medical situations during the Tour
• Website analytics: Using aggregated, non-personally-identifiable data from Google Analytics and Cloudflare Web Analytics to understand how our website is used and to improve our content and services
• Legal and regulatory compliance: Meeting our obligations under Australian taxation, consumer protection, and other applicable laws

4.2 We will not use your personal information for direct marketing unless you have expressly consented to receiving marketing communications. You may withdraw your consent at any time by contacting us.

5. Disclosure to Third Parties

5.1 To deliver the Tour, we share relevant personal information with third-party service providers, including:

• Hotels and accommodation providers: Name, room preference, dietary requirements, and any relevant medical or accessibility information
• Golf courses: Name and golf handicap details
• Restaurants and dining venues: Name, headcount, and dietary requirements
• Transport providers: Name and headcount for coach bookings
• Memorial sites and museums: Group booking details (name and headcount)
• Payment processor (Stripe): Payment and transaction information necessary to process your payments
• Google LLC (Google Analytics): Anonymised browsing data collected via cookies as described in clause 3
• Email service provider: Name and email address for booking confirmations and Tour communications

5.2 These third-party providers are located in Australia, France, Belgium, Switzerland, and the United States. By booking the Tour or using our website, you consent to the transfer of relevant personal information to these overseas recipients for the purposes described in this policy.

5.3 We will take reasonable steps to ensure that overseas recipients handle your personal information in a manner consistent with the Australian Privacy Principles. We note that the European Union's General Data Protection Regulation (GDPR) provides a comparable standard of data protection for recipients in France and Belgium, and that Google's data processing is covered by the EU-U.S. Data Privacy Framework.

5.4 We do not sell, rent, or trade your personal information to any third party for marketing or any other purpose.

5.5 We may disclose your personal information where required or authorised by law, including in response to a court order, subpoena, or request by a government agency.

6. Payment Security

6.1 All payments are processed through Stripe, a PCI DSS Level 1 certified payment processor. Your credit or debit card details are transmitted directly to Stripe via encrypted connection and are not received, processed, or stored by Touring Golf at any point.

6.2 We retain only a record of the transaction (amount, date, and last four digits of the card used) for our accounting and reconciliation purposes.

7. Data Storage & Security

7.1 We store your personal information using industry-standard security measures, including:

• Encrypted connections (HTTPS/TLS) for all data transmitted to and from our website
• Restricted access to personal information on a need-to-know basis
• Secure storage of booking records in access-controlled systems
• Regular review of our security practices

7.2 Our website is hosted on Cloudflare Pages with infrastructure located in multiple global regions. Booking form submissions and expressions of interest are transmitted securely and stored in access-controlled systems.

7.3 While we take reasonable steps to protect your personal information, no method of electronic storage or transmission is completely secure. We cannot guarantee absolute security of your data.

8. Data Retention

8.1 We retain different categories of personal information for different periods:

• Booking and financial records: 7 years from the end of the financial year in which the Tour takes place, in accordance with Australian Taxation Office record-keeping requirements
• Expressions of interest (non-booking): 2 years from submission, or until you request deletion, whichever is earlier
• Contact form enquiries: 1 year from the date of enquiry, or until you request deletion, whichever is earlier
• Health information: Securely deleted within 3 months of the Tour completion date, unless retention is required for the resolution of a claim or dispute
• Google Analytics data: Retained by Google for the period configured in our GA4 property settings (currently 14 months), after which it is automatically deleted by Google
• Cookies on your device: The _ga cookie expires after 2 years. You may delete cookies at any time through your browser settings

8.2 At the end of the applicable retention period, personal information is securely deleted or de-identified so that it can no longer be associated with you.

9. Sensitive Information

9.1 Under the Privacy Act, health information is classified as sensitive information and is subject to additional protections. We only collect health information that you voluntarily provide to us and that is reasonably necessary for the safe delivery of the Tour.

9.2 We will only use or disclose your health information for the purpose for which it was collected (assessing fitness to travel, making reasonable accommodations, and responding to health situations during the Tour), unless you consent to another use or disclosure is required by law.

9.3 Your health information will only be shared with third parties (such as hotels or medical providers) where it is necessary for your safety or to accommodate your needs, and only to the minimum extent required.

10. Your Rights

10.1 Under the Australian Privacy Principles, you have the right to:

• Access: Request access to the personal information we hold about you. We will respond to access requests within 30 days.
• Correction: Request correction of personal information that is inaccurate, out of date, incomplete, irrelevant, or misleading. We will respond to correction requests within 30 days.
• Complaint: Lodge a complaint if you believe we have handled your personal information in breach of the Australian Privacy Principles (see clause 12).

10.2 To exercise any of these rights, contact us using the details in clause 13. We may need to verify your identity before processing your request.

10.3 There is no fee for making an access or correction request, though we may charge a reasonable fee for providing access if the request requires significant effort to compile. We will advise you of any fee before proceeding.

11. European Data Protection

11.1 While Touring Golf is an Australian company and primarily subject to the Privacy Act 1988 (Cth), we recognise that some personal information we handle may be subject to the European Union's General Data Protection Regulation (GDPR). This includes information shared with European hotels, golf courses, and other suppliers, as well as browsing data collected from visitors accessing our website from within the EEA.

11.2 Where the GDPR applies, we process personal information on the following legal bases:

• Contract: Processing necessary to perform our contractual obligations to you (delivering the Tour)
• Legitimate interests: Processing necessary for our legitimate business interests (such as website analytics and service improvement), where those interests are not overridden by your rights
• Consent: Where you have given specific consent (such as for marketing communications)
• Legal obligation: Processing necessary to comply with applicable laws

12. Complaints

12.1 If you believe that we have breached the Australian Privacy Principles or otherwise mishandled your personal information, you may lodge a complaint with us by contacting us using the details in clause 13.

12.2 We will acknowledge your complaint within 5 business days and investigate it promptly. We aim to resolve all complaints within 30 business days. If we need more time, we will let you know and keep you informed of progress.

12.3 If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC):

• Online: www.oaic.gov.au/privacy/privacy-complaints
• Phone: 1300 363 992
• Post: GPO Box 5218, Sydney NSW 2001

13. Contact

For questions about this Privacy Policy or to exercise your rights under clause 10, contact:

Privacy Contact: Cameron Carmody, Director
Touring Golf Pty Ltd
ABN: 79 695 344 211
36/36-50 Taylor St, Annandale NSW 2038, Australia
Email: [email protected]
Website: touringgolf.com
Phone: +61 410 154 096

14. Changes to This Policy

14.1 We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Last updated" date at the top of this policy indicates when it was most recently revised.

14.2 If we make material changes that affect how we handle your personal information, we will notify you by email (if we have your email address) or by posting a prominent notice on our website.

14.3 Your continued use of our website or services after any changes to this Privacy Policy constitutes your acceptance of the updated policy.