Skip to content
Skip to content

Privacy Policy

Vodkatrain Privacy Policy

This Privacy Policy was last updated on 20 July 2018.


This privacy policy sets out how Sundowners Overland Proprietary Limited (ACN 005 066 348) and Sundowners Travel (Europe) Limited, (collectively referred to as “Vodkatrain” “we”, “Controller”, “our” or “us”) collects, stores, uses, protects and shares your Personal Data.

By visiting or using our website you agree to the collection, storage, usage and disclosure of your Personal Data by us in the manner described in this Privacy Policy.

We will protect your Personal Data in accordance with Australian Privacy Principles (APP), the General Data Protection Regulations 2016 (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003.We reserve the right to amend this Privacy Policy at any time by updating the terms on our website. By continuing to use the website after these changes have been made you are deemed to have consented with the changes. We encourage you to check this Privacy Policy for any changes when ever you visit our website.


“Controller” means Vodkatrain.

“Information Commissioner” means the relevant commissioner in charge of the state or territory where a Personal Data breach occurs.

“Overseas” means a state or country that is not located within Australia.

“Personal Data” means any information relating to an identified or identifiable person who has submitted personal information to Vodkatrain.

“Privacy Policy” means this document, as amended from time to time.

“Processor” means an individual or entity that processes the personal data on behalf of the Controller.

“Third Party” means an individual or entity (located in Australia or Overseas), other than Vodkatrain who under direct authority are authorised to process Personal Data.

  1. What Personal Data does Vodkatrain collect and store about me?

Vodkatrain generally collects the following information that has been voluntarily submitted in order to process bookings. We have a lawful basis to retain Personal Data when bookings are made and will usually include:

  • Name, contact details (such as home address, work address, email address and telephone number)
  • Date of birth
  • Place of birth
  • Nationality
  • Passport details
  • Occupation
  • Special requirements pertaining to disability or any medical condition impacting travel arrangements
  • Previous travel experiences with Vodkatrain

In the event that you do not provide us with Personal Data, we will be unable to provide you with certain information specific to your request. In the event that we do not require any Personal Data from you in order to process a request or inquiry we will make this clear.

  1. How does Vodkatrain collect and hold Personal Data? 

Vodkatrain collects Personal Data when you request a travel brochure or other information, enter competitions, make a travel booking with Vodkatrain or when you register on the Vodkatrain website. We do not collect Personal Data unless it has been submitted to us.

We take full responsibility for ensuring that proper security measures are in place to protect your information. Personal booking information is captured securely and will not be stored for longer than necessary. We may therefore delete your Personal Data after a reasonable and responsible period of time.

Personal and insurance information will be collected from all clients during the booking process. Once you have travelled, you will be asked to complete a client survey where we will collect further details about you and the tour you travelled on. You may also be asked to review your tour on trusted review websites or we may share these reviews with trusted review websites on your behalf.

  1. Why Vodkatrain collects, stores and uses personal information?

Vodkatrain collects and uses Personal Data for several purposes. These purposes are:

  • To enable Vodkatrain to arrange bookings for travel and accommodation services for you. We only use personally identifiable data for the purpose or service that it has been submitted. Your personally identifiable information is not publicly accessible and is only accessed by Vodkatrain for handling your enquiry.
  • With your permission to provide you with direct marketing offers. Vodkatrain may provide you with direct marketing offers to tell you about products, services and travel destinations that Vodkatrain believes may be of interest to you for planning, product development and research purposes and to give you discount offers, and other benefits associated with being a Vodkatrain client. You will not be sent any unlawful marketing or spam.
  • We will always work to fully protect your rights and comply with our obligations under the General Data Protection Regulation (GDPR) and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and you will always have the opportunity to opt-out or manage your preferences and this option is published at the end of each newsletter. You have the right to direct us to cease further contact or to destroy the Personal Data we have collected about you.

  1. Social Media, Photographs, Videos and Testimonials

Vodkatrain intend to keep track of the domains from which people visit its website and will analyse this data for trends and statistics.

If you make use of any Vodkatrain social media features, either on our website, an App or otherwise through a social media provider, we may access information about you via that social media provider in accordance with their policies. When using a social media feature and if you have chosen to include it in your social media account, we may access information such as your name, profile picture, gender, birthday, email address, town or district and any other information you have chosen to make available. Depending on the privacy settings of you and your friends, we may access information that you provide to a social media provider regarding your respective locations (“Location Data”) to provide you with relevant content. Please note that your Location Data may also be shared with your friends on a social media provider in accordance with your privacy settings for that social media provider. We may also access information from social media providers about your use of an App that we run on their website.

When on tour, employees, agents and/or other travellers of Vodkatrain may from time to time take photographs or make recordings of you and tour activities that may identify you. Vodkatrain reserves the right to use any or all photographs and/or recordings made on tour for promotional reasons in printed materials, on the Internet or other media. In using such images, Vodkatrain undertakes not to reveal your name, contact details or other personal information. You consent to the use of such images or recordings by Vodkatrain and you acknowledge that you will not be entitled to payment or other compensation for the giving of consent or for the use of such images or recordings. Vodkatrain may keep such images or recordings of you on record. If you do not wish for images or recordings of you to be collected, stored or used you must advise Vodkatrain to that effect at the time of booking. Additionally, any photographs, video and text sent to Vodkatrain must be the client’s own and by sending it, the client agrees that Vodkatrain can use it for advertising and marketing purposes.

Feedback supplied to Vodkatrain may also be used in print and online for marketing and advertising purposes. This includes but is not limited to, third party review sites and questionnaires supplied to us pre or post-tour.

  1. Who does Vodkatrain share your Personal Data with?

We do not sell, rent or trade your Personal Data. Vodkatrain will only disclose your Personal Data in the ways set out in this Privacy Policy and in accordance with local data protection laws.

Vodkatrain may provide your Personal Data to the following third parties:

  • Airlines, railways, other transportation companies, accommodation facilities and tour operators for the purposes of making travel bookings.
  • Persons or companies who are contracted to perform part of Vodkatrain's service delivery. This includes organisations such as local agents overseas and third-party contractors such as tour operators and tour guides.
  • Government instrumentalities (both in Australia and overseas) for the purpose of securing appropriate visas and other travel authorisations necessary to enable entry and travel in the destination countries and for the purpose of complying with the local law in destination countries. Vodkatrain may also supply your Personal Data to your government for consular purposes. Third parties to whom we may disclose Personal Data to may be located in Australia, the United Kingdom and other countries including any countries where you are booked to travel to on a Vodkatrain tour.
  • Mail houses for the distribution of marketing material.
  • Payment processing facilities.
  • IT system administrators.

Vodkatrain will take reasonable and responsible steps to protect any Personal Data that it holds about you from misuse and loss and from unauthorised access, modification and disclosure and will not disclose your Personal Data to organisations outside Vodkatrain for any purpose (other than as outlined in this policy) without your express consent.

In accordance with Article 46 of the GDPR, the Controller or Processor has appropriate safeguards with any third party in order to protect your Personal Data. This may be by way of the following:

  1. A legally enforceable contract;
  2. Binding corporate rules;
  3. Standard data protection clauses;
  4. An approved code of conduct; or
  5. An approved certification mechanism to apply appropriate safeguards.

It is possible that your Personal Data will be transferred to an Overseas third party, who is located in a jurisdiction where you will not be able to seek redress under your local data protection laws and the Overseas third party does not have an equivalent level of protection for your Personal Data. To the extent permitted by local data protection laws, we will not be liable for how these Overseas third parties handle, store and process your Personal Data.

We strongly suggest that you review any third parties’ privacy policies.

Copies of relevant safeguard documents can be made available upon request. Please see clause 9 below for our contact details.

  1. Storing your Secure Information

We are committed to protecting Personal Data and implementing the strictest security measures to ensure all Personal Data provided by you is not unlawfully or accidentally disclosed. Vodkatrain regularly reviews our security procedures to ensure your Personal Data is protected at all times.

Once your Personal Data is no longer required by us, it will be destroyed.

  1. Personal Data Breaches

In the event there is a Personal Data breach, Vodkatrain (if required by the APP or GDPR) will notify the relevant Information Commissioner within 72 hours of the breach and shall at least:

  1. Describe the nature of the personal data breach, and approximate number of personal data records concerned;
  2. Communicate about where more information of the breach can be obtained;
  3. Describe the likely consequences of the breach;
  4. Describe the measures taken to address the breach.

After the Information Commissioner has been notified of a breach we will then notify all affected individuals in writing at their last known email address.

  1. Rights and Remedies
  2. The following rights are available to individuals:
    1. the right of access: the individual shall have the right to obtain information from the Controller as to where their Personal Data is being processed;
    2. the right to rectification: the individual shall have the right to provide correct information that is incorrectly recorded by the Controller;
  • the right to erasure: the individual shall have the right to erase all of their Personal Data without undue delay when any of the following apply:
    1. Personal Data no longer necessary;
    2. there is no legal ground for their information to be processed
    3. the individual objects to the processing of their information;
    4. the Personal Data has been unlawfully processed;
    5. Personal Data is to be erased in compliance with a legal obligation; or
    6. the individual is below the age of sixteen (16) years;
  1. the right to restriction of processing: the individual can restrict the processing of data if:
    1. the accuracy of data is contested;
    2. the erasure of Personal Data is opposed;
    3. the Controller no longer requires the Personal Data, but is required to retain information due to the establishment, exercise or defence of legal claims;
    4. the individual has objected to processing; however, the Controller can provide compelling evidence to override the request of the individual;
  2. the right to data portability: the individual shall have the right to receive data concerning their own Personal Data and shall have the right to send that data to another Controller without hindrance from the current Controller;
  3. the right to object: the individual has the right to object to the processing of Personal Data.

Any requests for the above rights will be addressed within thirty (30) days.

  1. The following remedies are available to individuals:
    1. the right to lodge a complaint with a supervisory authority;
    2. the right to an effective judicial remedy against a Controller or Processor;
  • the right to appoint a body to represent them in respect of the exercise of the rights under point 8(b)(i) and 8(b)(ii) above; and
  1. the right to compensation from Controllers and Processors.

  1. Feedback/Complaints/Contact us

If you would like to contact us to make a complaint, exercise a right, seek a remedy, provide feedback, have a query regarding this Privacy Policy or how we deal with your Personal Data please contact us below:

Phone:                  +61 3 9672 5300

Address:              Level 1, 51 Queen Street, Melbourne, Victoria 3000 Australia

Email:         (Attention: Liz Anderson) (Attention: Liz Anderson)

Upon receiving your request in writing, we will endeavour to reply within thirty (30) days. There is no charge for making a request. In the event your request is unable to be responded to within thirty (30) days, we will contact you and advise of an approximate time to respond. In some limited circumstances we may be legally required to share certain Personal Data, which might include yours, if we are involved with any legal proceedings or required to comply with legal obligations.

Your privacy is of the upmost important to us and in order to fulfil your requests, we have the right to use or disclose any information as needed to satisfy any law, regulation or legal request, to protect the integrity of the site, to fulfil your requests, or to cooperate in any legal investigation.