Privacy Policy

1. Our Commitment to Privacy

The Lane House Melbourne Pty Ltd (ACN 695 858 489) (The Lane House, we, us or our) respects the privacy of our guests, prospective guests, visitors, contractors, suppliers and other individuals with whom we interact. We recognise that the operation of an accommodation business requires us to collect and handle personal information, including identification, contact, reservation, payment, security and other information.

We are committed to handling personal information responsibly, transparently and securely and, where applicable, in accordance with:

• the Privacy Act 1988 (Cth);
• the Australian Privacy Principles (APPs);
• the Notifiable Data Breaches Scheme under the Privacy Act;
• the Health Records Act 2001 (Vic) and Health Privacy Principles where health information is collected or held;
• applicable Victorian surveillance and other laws; and
• other applicable Australian laws relating to privacy, data security and the handling of personal information.

This Privacy Policy explains how The Lane House collects, holds, uses, discloses, protects and otherwise manages personal information.

2. Scope of this Policy

This Privacy Policy applies to personal information collected by or on behalf of The Lane House through our operations, including through:

• our website;
• direct reservations;
• telephone and email enquiries;
• online booking systems;
• online travel agents and other booking intermediaries;
• corporate and travel agent bookings;
• our guest portal;
• digital and contactless check-in systems;
• identification verification processes;
• payment systems;
• digital room-access systems;
• reception and concierge interactions;
• Wi-Fi and technology services;
• CCTV and building security systems;
• licence-plate recognition and car park access systems;
• guest surveys, feedback and complaints;
• marketing communications;
• competitions and promotions;
• social media interactions; and
• other services made available to guests.

This Policy should be read together with our applicable booking Terms and Conditions and any privacy notice provided when we collect particular information.

3. What is Personal Information?

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable.

Depending on the circumstances, the personal information we collect may include:

Identity information

• full name;
• date of birth;
• age;
• signature;
• nationality;
• government-issued photographic identification;
• passport information;
• driver’s licence information;
• proof-of-age documentation; and
• photographs contained within identification documents.

Contact information

• residential or postal address;
• email address;
• telephone or mobile number; and
• emergency contact details where provided.

Reservation and stay information

• reservation number;
• arrival and departure dates;
• room or apartment booked;
• room preferences;
• number and identity of accompanying guests where required;
• special requests;
• accessibility requirements;
• housekeeping requests;
• booking history;
• cancellations and amendments;
• complaints;
• incidents occurring during a stay; and
• communications with our team.

Payment and transaction information

We may collect or process information relating to:

• payment cards;
• transaction records;
• deposits and pre-authorisations;
• refunds;
• outstanding accounts;
• invoices;
• billing addresses; and
• payment history.

Payment card transactions may be processed through third-party payment processors. We seek to limit our storage of complete payment card information where this is not necessary.

Vehicle information

Where you use parking facilities, we may collect:

• vehicle registration or licence-plate number;
• vehicle type;
• parking records; and
• entry and exit information generated through car park or licence-plate recognition systems.

Digital information

When you use our website, guest portal, Wi-Fi or digital services, we or our technology providers may collect information such as:

• IP address;
• browser type;
• device information;
• operating system;
• website activity;
• cookies and similar technologies;
• system logs;
• login information; and
• information necessary to deliver digital guest services.

Security information

Our premises use security systems which may collect:

• CCTV images and footage;
• dates and times of entry or movement through monitored areas;
• access-control records;
• digital key or access-card activity;
• building access records;
• incident reports; and
• other information reasonably required to protect guests, staff and property.

Sensitive and health information

In limited circumstances, guests may voluntarily provide sensitive or health information, for example information relating to:

• accessibility requirements;
• disability or mobility requirements;
• allergies or health-related accommodation requests;
• medical incidents;
• assistance animals; or
• emergency situations.

We will only collect sensitive information where permitted by law, including where appropriate consent has been obtained or another legal exception applies.

4. Why We Collect Personal Information

We collect personal information where reasonably necessary for our functions and activities.

This may include collecting, using and disclosing information to:

Reservations and accommodation

• process enquiries and reservations;
• confirm bookings;
• administer accommodation;
• manage arrivals and departures;
• communicate with guests before, during and after their stay;
• provide requested services;
• administer cancellations, amendments and refunds;
• manage room allocations and guest preferences; and
• maintain appropriate reservation records.

Identity verification and fraud prevention

We may verify the identity of guests to:

• confirm that a reservation is genuine;
• confirm the identity of the primary guest;
• match identification with reservation and payment information;
• prevent fraudulent reservations and payments;
• protect guests and property; and
• meet security, legal and operational requirements.

Digital check-in and access

We operate digital and contactless guest services. Personal information may therefore be used to:

• complete online pre-arrival registration;
• verify guest identity;
• facilitate digital check-in;
• issue or activate room-access credentials;
• administer mobile or physical access devices; and
• manage building and room security.

Payments

We may use personal information to:

• process accommodation charges;
• process security deposits or pre-authorisations;
• process incidental charges;
• administer refunds;
• prevent payment fraud;
• recover amounts owing; and
• maintain financial and accounting records.

Safety and security

Personal information may be used to:

• maintain security at The Lane House;
• investigate incidents;
• manage emergencies;
• prevent or investigate theft, fraud or unlawful behaviour;
• enforce our Terms and Conditions;
• protect guests, visitors, employees and property;
• investigate breaches of building rules;
• respond to requests from emergency services or law-enforcement agencies; and
• establish, exercise or defend legal claims.

5. Identification Documents

The Lane House may require guests to provide valid government-issued photographic identification before or during check-in.

Identification may include a:

• passport;
• Australian driver’s licence or learner permit;
• recognised foreign driver’s licence;
• government-issued proof-of-age or photo identification card; or
• other identification reasonably accepted by The Lane House.

Where identification is uploaded electronically, it may be processed through a secure guest registration, property-management, identity-verification or technology platform operated by us or a service provider acting on our behalf.

We will only use identification information for purposes reasonably connected with operating our accommodation business, including identity verification, security, fraud prevention and legal compliance, unless another use is permitted or required by law.

We will take reasonable steps to ensure identification records are retained only for as long as reasonably necessary or required by law.

6. How We Collect Personal Information

We generally collect personal information directly from you when you:

• make a reservation;
• use our website;
• contact us by telephone or email;
• complete online registration;
• upload identification;
• check in;
• communicate with reception or concierge;
• make a payment;
• use our guest portal;
• request services;
• complete a survey;
• submit feedback or a complaint; or
• otherwise interact with us.

We may also receive personal information from third parties including:

• online travel agents;
• travel agents;
• booking platforms;
• corporate booking clients;
• employers arranging business travel;
• payment processors;
• property-management and reservation platforms;
• authorised representatives;
• building-management and security providers; and
• other persons where you have authorised the disclosure or where permitted by law.

7. CCTV and Security Monitoring

CCTV operates within The Lane House and/or the wider building in which The Lane House operates.

CCTV may monitor areas including entrances, exits, foyers, corridors, lifts, car parks and other common or security-sensitive areas.

CCTV is used for purposes including:

• guest, visitor and staff safety;
• building security;
• crime prevention and detection;
• investigating incidents;
• investigating damage or theft;
• monitoring unauthorised access;
• responding to emergencies;
• protecting property; and
• assisting law-enforcement or emergency authorities where appropriate.

CCTV is not intended to be installed in areas where individuals would reasonably expect complete personal privacy, such as inside guest apartments.

Access to recorded CCTV footage is restricted to authorised persons and service providers as reasonably required.

CCTV footage may be disclosed to police, emergency services, insurers, legal advisers, building management or other persons where reasonably necessary or where required or authorised by law.

8. Licence-Plate Recognition and Parking

The Lane House or the building in which it operates may use licence-plate recognition or similar technology to facilitate vehicle access and parking.

Where applicable, a guest may be required to provide their vehicle registration number.

This information may be used to:

• provide authorised car park access;
• identify authorised vehicles;
• manage parking facilities;
• maintain building security;
• investigate parking or security incidents; and
• enforce applicable parking requirements.

9. Cookies and Website Technologies

Our website and online services may use cookies and similar technologies.

These technologies may be used to:

• enable website functionality;
• maintain user sessions;
• understand website usage;
• improve our website and online services;
• remember preferences;
• analyse website performance;
• detect security issues; and
• support marketing activities where permitted.

You may be able to control cookies through your browser settings. Disabling certain cookies may affect website functionality.

10. Direct Marketing

Where permitted by law, we may use personal information to communicate with you about:

• The Lane House;
• accommodation offers;
• promotions;
• packages;
• events;
• services; and
• other information we reasonably believe may be of interest to you.

Where required, we will obtain appropriate consent.

You may opt out of receiving direct marketing communications at any time by using the unsubscribe facility contained in the communication or contacting us.

We will not require you to receive marketing communications as a condition of staying at The Lane House.

Operational communications relating to an existing reservation or stay are not marketing communications and may still be sent where necessary to provide the service you requested.

11. When We Disclose Personal Information

We may disclose personal information where reasonably necessary to operate The Lane House, including to:

• accommodation booking and distribution platforms;
• online travel agents;
• property-management system providers;
• guest-registration and check-in providers;
• identity-verification providers;
• payment processors and financial institutions;
• IT and cybersecurity providers;
• website and hosting providers;
• communications providers;
• building management;
• security providers;
• cleaning and maintenance providers where necessary;
• accountants, auditors and professional advisers;
• insurers and insurance brokers;
• lawyers and other professional advisers;
• debt-recovery providers;
• government agencies;
• regulators;
• courts and tribunals;
• police and law-enforcement agencies;
• emergency services; and
• other parties where you have consented to the disclosure or the disclosure is otherwise authorised or required by law.

We require service providers handling personal information on our behalf to handle that information appropriately and consistently with their contractual and legal obligations.

12. Overseas Disclosure and Cloud Services

Some technology, booking, payment, communication, analytics or cloud-service providers used by The Lane House may operate or store information outside Australia.

Accordingly, personal information may in some circumstances be disclosed to, accessed from or stored in overseas locations.

Where the Australian Privacy Principles apply to an overseas disclosure, we will take reasonable steps required by law in relation to that disclosure.

The countries involved may vary depending upon the technology providers used by The Lane House.

Where practicable, The Lane House will maintain information identifying the principal overseas locations to which guest personal information is likely to be disclosed.

13. Storage and Security

The Lane House takes reasonable steps to protect personal information against:

• misuse;
• interference;
• loss;
• unauthorised access;
• unauthorised modification; and
• unauthorised disclosure.

Our safeguards may include, as appropriate:

• access controls;
• passwords and authentication controls;
• secure cloud services;
• restricted staff permissions;
• cybersecurity controls;
• physical security;
• secure payment processing;
• staff training;
• confidentiality requirements;
• system monitoring;
• backup procedures; and
• contractual requirements imposed on relevant service providers.

No electronic transmission or storage system is completely secure. We therefore cannot guarantee absolute security, but we will take reasonable steps appropriate to the circumstances to protect personal information.

14. Retention and Destruction

We retain personal information only for as long as reasonably necessary for the purpose for which it was collected, for legitimate business requirements or as required by applicable laws.

Different information may be subject to different retention periods.

When personal information is no longer required and we are not legally required to retain it, we will take reasonable steps to securely destroy it or permanently de-identify it.

Particular care will be taken with copies or records of government-issued identification.

15. Data Breaches

The Lane House maintains processes for responding to actual or suspected data breaches.

If a suspected data breach occurs, we may:

1. take steps to contain the incident;
2. investigate what occurred;
3. assess the information affected and potential consequences;
4. take remedial action;
5. determine whether notification is required; and
6. implement measures intended to reduce the likelihood of recurrence.

Where the Notifiable Data Breaches Scheme applies and an eligible data breach is likely to result in serious harm, The Lane House will comply with applicable notification requirements, including notifying affected individuals and the Office of the Australian Information Commissioner where required.

16. Accessing Your Personal Information

You may request access to personal information that we hold about you.

Requests should be directed to our Privacy Officer using the contact details below.

Before providing access, we may need to verify your identity.

We will respond to access requests within a reasonable period.

In certain circumstances permitted by law, we may refuse access to some or all of the requested information. Where required, we will provide reasons for that decision and information about available complaint mechanisms.

17. Correcting Your Personal Information

We take reasonable steps to ensure personal information we hold is accurate, complete, relevant and up to date having regard to the purposes for which it is held.

If you believe personal information we hold about you is:

• inaccurate;
• out of date;
• incomplete;
• irrelevant; or
• misleading,

you may ask us to correct it.

We may need to verify your identity before processing the request.

18. Anonymity and Pseudonyms

Where lawful and practicable, individuals may interact with us anonymously or using a pseudonym.

However, due to the nature of accommodation services, it will generally be impracticable to provide accommodation without identifying the primary guest.

Identification may be required for purposes including:

• confirming a reservation;
• processing payment;
• verifying identity;
• preventing fraud;
• providing building or room access;
• complying with security requirements; and
• protecting guests, staff and property.

19. Children and Minors

Reservations at The Lane House must be made by an adult.

Personal information relating to minors may be collected where reasonably necessary in connection with an accommodation reservation, safety requirement, emergency or other legitimate purpose.

Where appropriate, information concerning a minor should be provided by their parent, guardian or responsible adult.

We seek to limit collection of information about minors to what is reasonably necessary.

20. Third-Party Websites and Services

Our website or guest communications may contain links to third-party websites, applications or services.

Those third parties may have their own privacy policies and information-handling practices.

The Lane House is not responsible for the privacy practices of third parties operating independently of us, and individuals should review the applicable privacy policies before providing personal information to those organisations.

21. Complaints About Privacy

If you believe we have not handled your personal information appropriately, please contact our Privacy Officer.

Please provide sufficient information for us to understand and investigate your concern.

We will:

1. acknowledge your complaint;
2. investigate the circumstances;
3. seek any additional information reasonably required;
4. provide a response within a reasonable period; and
5. take appropriate corrective action where warranted.

If you are not satisfied with our response and the Privacy Act applies to the matter, you may be entitled to make a complaint to the Office of the Australian Information Commissioner (OAIC).

Where a complaint relates specifically to health information regulated under the Health Records Act 2001 (Vic), you may also have rights to complain to the Health Complaints Commissioner Victoria.

22. Changes to this Privacy Policy

We may amend this Privacy Policy from time to time to reflect:

• changes to our operations;
• changes to technology;
• changes to our service providers;
• changes to legal or regulatory requirements; or
• changes to our privacy practices.

The current version will be published on our website.

The effective date shown at the beginning of this Policy indicates when the current version commenced.

23. Contact Us

Questions, requests for access or correction, and privacy complaints should be directed to:

Privacy Officer
The Lane House Melbourne Pty Ltd
ACN 695 858 489
The Lane House Melbourne
Email: frontdesk@thelanehouse.com.au
Telephone: +61 3 9959 3987

Please include “Privacy” in the subject line of written correspondence where possible.

Our Privacy Commitment

The Lane House recognises that privacy and security are important parts of the trust our guests place in us. We aim to collect only the personal information reasonably required to provide safe, secure and efficient accommodation services and to handle that information responsibly throughout its lifecycle.