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Privacy Policy

Updated: 12 June 2025

WhatWhere exists to help parents find quality activities for their families and encourage adventure and exploration. A fundamental part of earning that trust means being clear about how we use your information and protecting your human right to privacy.

This Privacy Policy describes how WhatWhere and its affiliates ("we," "us," or "WhatWhere"), process personal information in relation to your use of the WhatWhere Platform.

1. WHO CONTROLS MY PERSONAL INFORMATION.

1.1 Controller.

Where this Policy mentions "WhatWhere," "we," "us," or "our," it refers to Pacific Europa Pty Ltd trading as WhatWhere of Suite 61.01, Level 61, MLC Center, 25 Martin Place, Sydney, NSW, 2000, that is responsible for your information under this Privacy Policy (the "Controller").

2. PERSONAL INFORMATION WE COLLECT.

2.1 Information Needed to Use the WhatWhere Platform.

We collect personal information about you when you use the WhatWhere Platform. Without it, we may not be able to provide all services requested. This information includes:

2.1.1 Contact, Account, and Profile Information.
Such as your first name, last name, phone number, postal address, email address, date of birth, and profile photo, some of which will depend on the features you use.

2.1.2 Payment Transaction Information.
Such as payment account, credit card information, date and time, payment amount, and billing postcode, your address, and other related transaction details.

2.2 Information You Choose to Give Us.

You can choose to provide us with additional personal information, including:

2.2.1 Additional Profile Information.
Such as gender, personal description, and any additional profile information you provide.

2.2.2 Information About Others.
Such as information belonging to another person on your family profile or about an additional activity participant. By providing us with personal information about others, you certify that you have permission to provide that information to WhatWhere for the purposes described in this Privacy Policy.

2.2.3 Communications Information.
Such as email, call, message, SMS, and text information where delivery is enabled on or through the WhatWhere Platform. Communication information may also include call recordings and transcripts consistent with the requirements under applicable law, and other log information like your phone number, calling-party number, receiving-party number, account name, email address, forwarding numbers, time and date of communications, duration of communication, routing information, and the types and volumes of communications.

2.2.4 User-Generated Content.
Such as any photos, videos, and other content you choose to provide.

2.2.5 Support Information.
Such as call recordings and transcripts consistent with the requirements under applicable law, and messages collected to provide customer support services, including investigating and responding to user concerns and monitoring and improving our support processes.

2.2.7 Other Information.
Such as when you fill in a form, add information to your account, respond to surveys, participate in research, post to community forums, participate in promotions, import or manually enter address book contacts, provide your address and/or geolocation, provide business information, or share your experience with us. This may include health information if you choose to share it with us.

2.3 Information Automatically Collected by Using the WhatWhere Platform.

When you use the WhatWhere Platform, we automatically collect certain information. This information may include:

2.3.1 Geolocation Information.
Such as precise or approximate location determined from your IP address, mobile or other device’s GPS, or other information you share with us, depending on your device settings. We may also collect this information when you’re not using the app if you enable this through your settings or device permissions.

2.3.2 Usage Information.
Such as searches for Listings, bookings you have made, additional services you have added, access dates and times, the pages you’ve viewed or engaged with before or after using the WhatWhere Platform, and other actions on the WhatWhere Platform, including the pages or content you view and links you click to third-party applications. We may collect this information even if you haven’t created an WhatWhere account or logged in.

2.3.3 Device Information.
Such as IP address, hardware and software information, device information, device event information, unique identifiers, crash data, and read receipts. We may collect this information even if you haven’t created an WhatWhere account or logged in.

2.3.4 Cookies and Similar Technologies

2.4 Information We Collect from Third Parties.

We may collect personal information from other sources, such as:

2.4.1 Third-Party Applications.
If you choose to link, connect, or login to the WhatWhere Platform with a third-party service, such as Google, Facebook, and WeChat, you direct the service to send us information such as your registration, friends list, and profile information as controlled by that service or as authorised by you via your privacy settings at that service. If you choose to connect a smart lock to your WhatWhere account, we may collect information about the smart device, such as log or event information and device information.

2.4.2 Referrals and Co-Guests.
If you are invited to the WhatWhere Platform, for example, as a co-Guest on an activity, the person who invited you can submit personal information about you.

2.4.3 Complainants.
If a Provider, Guest, or any third party submits a complaint about you, we may receive information relating to the specific complaint made to understand and, where relevant, address the complaint.

3. HOW WE USE INFORMATION WE COLLECT.

We use personal information as outlined in this Privacy Policy.

3.1 Provide the WhatWhere Platform.

We may process this information to:

  • enable you to access the WhatWhere Platform and make and receive payments,
  • enable you to communicate and engage with others,
  • process and respond to your request,
  • provide you with support,
  • send you messages, updates, security alerts, and account notifications,
  • determine your state of residence based on automated review of your account information and your interactions with the WhatWhere Platform, and
  • enable your use of our products and accommodation services.

3.2 Improve and Develop the WhatWhere Platform.

We may process this information to:

  • perform analytics, debug, and conduct research,
  • improve and develop our products and services, and
  • provide customer service training.

3.3 Personalise and Customise the WhatWhere Platform.

We may process this information to:

  • personalise and customize your experience based on your interactions on the WhatWhere Platform, your search and booking history, your profile information and preferences, and other information you choose to give us, and
  • tailor your experience with WhatWhere.

3.4 Safeguard the WhatWhere Platform and Community.

We may process this information to:

  • detect, prevent, assess, and address fraud and security risks,
  • protect our community from illegal activities or other behaviours,
  • verify or authenticate information provided by you, including identity information,
  • comply with our legal obligations, protect the health and well-being of our Guests, Providers, Provider’s employees, and members of the public,
  • resolve disputes with our Members,
  • enforce our agreements with third parties,
  • determine eligibility for certain types of bookings,
  • comply with law, respond to legal requests, prevent harm, and protect our rights,
  • enforce our Terms of Service (“Terms”), and
  • assess or evaluate your interactions with the WhatWhere Platform and information obtained from third parties.

3.5 Provide, Personalise, Measure, and Improve our Advertising and Marketing.

We may process this information to:

  • send you promotional, advertising, and marketing messages, and other information,
  • show, personalise, measure, and improve our advertising-on-advertising platforms,
  • administer referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by WhatWhere or its third-party partners,
  • analyse characteristics and preferences to send you promotional messages, marketing, advertising, and other information that we think might be of interest to you, and
  • invite you to events and relevant opportunities.

3.6 Analyse Your Communications.

3.6.1 Purpose.
We may review, scan, or analyse your communications on or enabled through the WhatWhere Platform for purposes disclosed in this Privacy Policy, including safety, support, product enhancement, and as described in Why we review messages on WhatWhere. Subject to applicable law, we scan and analyse all images uploaded by users to the WhatWhere platform in message threads, profiles, listings, and experiences for certain illegal or inappropriate activities.

3.6.2 Methods.
We use automated methods where reasonably possible. Occasionally we may need to manually review communications, such as for investigations or customer support.

3.6.3 Non-Sale.
We will not sell reviews or analyses of these communications.

3.7 Provide Payment Services.

Personal information is used to enable, or authorise third parties to use payment services such as to:

  • process payments,
  • perform the contract with you,
  • verify your identity,
  • detect and prevent money laundering, fraud, abuse, and security incidents,
  • conduct security investigations and risk assessments.

If you are not an WhatWhere user, we may receive payment information relating to you, such as when an WhatWhere user provides your payment card to complete a booking.

4. SHARING AND DISCLOSURE.

4.1 Sharing With Your Consent or at Your Direction.

Where you provide consent or direct us to share your information, we share your information as described at the time of consent or choice, such as when authorising a third-party application or website to access your WhatWhere account or participating in promotional activities by WhatWhere partners or third parties.

4.2 Who We Share With.

We may share your information with:

4.2.1 Other Members.
To help facilitate bookings, connections, or other interactions between Members; we may share information in certain situations, as described in Sharing and disclosing information with other Members.

4.2.2 Members’ Service Providers.
Providers may use third-party services to help manage or deliver their services. Providers may use features on the WhatWhere Platform to share information about the Guest with such third-party service providers. Other Members may use services other than WhatWhere to process your data, including email or reservation management software. Such services are outside of WhatWhere’s control and will be subject to applicable law.

4.2.3 Service Providers.
We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us run our business and for their compliance purposes, including those that help us: (i) verify your identity (ii) perform product development, maintenance, and debugging (iii) conduct background checks, fraud prevention, security investigations, and risk assessments, (iv) provide customer service, advertising, or payments services, (v) allow the provision of the WhatWhere Services through third-party platforms and software tools, (vi) review, scan, and analyse communications on the WhatWhere Platform for certain purposes, (vii) offer additional services you select. These providers are contractually bound to protect your personal information, have access to your personal information to perform these tasks, and may also disclose your information where required by law.

4.3 Why We May Share Your Information.

We may share your information in order to:

4.3.1 Build Your Public Profile.
Information you share publicly on the WhatWhere Platform may be indexed through third-party search engines. In some cases, you may opt-out of this sharing in your account settings. We may make certain information publicly visible to others, such as:

  • your profile and account information and information derived from them, as described here,
  • listing pages that include information such as the activities and experiences approximate or precise location description, calendar availability, profile photo, aggregated demand information, and additional information you choose to share, and
  • content in a community or discussion forum, blog, or social media post, and content you make available to the public, including Listing details on third-party sites, platforms, and apps.

4.3.2 Comply with Law, Respond to Legal Requests, Prevent Harm, and Protect Our Rights.

(i) Disclosure.
As we reasonably deem appropriate, we may disclose your information or communications to courts, law enforcement, governmental or public authorities, tax authorities, authorised third parties, or other Members, if and to the extent we are required or permitted to do so by law or where disclosure is reasonably necessary to: (i) comply with our legal obligations, (ii) comply with a valid legal request, such as a subpoena or court order, or to respond to claims asserted against WhatWhere, (iii) respond to a valid legal request relating to a criminal investigation to address alleged or suspected illegal activity, or to respond to or address any other activity that may expose us, you, or any other of our users to legal or regulatory liability, (iv) enforce and administer our agreements with Members, including our Terms and Policies, (v) investigate potential violations of applicable law, (vi) respond to requests for or in connection with current or prospective legal claims or legal proceedings concerning WhatWhere and/or third parties, in accordance with applicable law, or (vii) protect the safety, security, rights, or property of WhatWhere, its employees, its Members, or members of the public.

(ii) Notification.
Where appropriate and/or legally required, we may notify Members about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to WhatWhere, our Members, or expose WhatWhere to a claim of obstruction of justice.

4.3.3 Effectuate Business Transfers.
If WhatWhere undertakes or is involved in any merger, acquisition, reorganization, sale of assets, bankruptcy, or insolvency event, then we may sell, transfer, or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction, such as due diligence. In this event, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

5. Third-Party Partners and Integrations.

5.1 Linking Third-Party Services.

You can link your WhatWhere account with certain third-party services, such as social networks. When you direct the data sharing by creating this link:

  • some of the information provided to us from linking accounts may be published on your public profile,
  • information you provide to us from the linking of your accounts may be stored, processed, and transmitted for fraud prevention, security investigations, and risk assessment purposes,
  • we share information about your reservation with third-party travel partners and reward programs, and
  • publication and display of information that you provide to the WhatWhere Platform through this linkage is subject to your settings and authorisations on the WhatWhere Platform and the third-party service.

5.2 Third-Party Service Terms.

Parts of WhatWhere may link to third-party services. WhatWhere does not own or control these third parties. When you interact with these third parties and choose to use their service, you are providing your information to them.

6. Your Rights.

6.1 Managing Your Information.

You can access and update some of your personal information through your Account settings. You are responsible for keeping your personal information up to date.

7. RETENTION.

7.1 Retention Periods.

We retain personal information for as long as needed or as permitted in light of the purpose(s) for which it was obtained and further processed and consistent with applicable law. The criteria used to determine our retention periods include:

  • the length of time we have an ongoing relationship with you and provide the WhatWhere platform services to you, whether you are a Guest or a Provider (for example, for as long as you have an account with us or keep using WhatWhere) and the length of time thereafter during which we may have a legitimate need to retain your personal information, such as to manage and protect our business, to address issues or defend claims that may arise,
  • whether there is a legal, tax, reporting, or auditing obligation to which we are subject that requires us to keep records of your transactions for a certain period before we can delete them, and
  • whether retention is advisable considering our legal position or to protect the safety of individuals, which includes retention that is required or prudent in accordance with applicable statutes of limitations, litigation, or regulatory investigations.

7.2 Shared Information.

Information you have shared with other Members, such as content, reviews and forum postings, may continue to be publicly visible on WhatWhere, even after your WhatWhere Account is cancelled.

7.3 Residual Copies.

Because we take measures to protect data from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

8. Security.

While no organisation can guarantee perfect security, we are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unlawful or unauthorised access, loss, destruction, or alteration.

9. Changes to Privacy Policy.

We reserve the right to modify this Privacy Policy at any time in accordance with applicable law. If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the WhatWhere Platform will be subject to the revised Privacy Policy.

10. Contact Information.

For questions or complaints about this Privacy Policy or WhatWhere’s handling of personal information you may contact us by emailing admin@WhatWhere.io.