Privacy Policy

2. ABOUT THIS POLICY

This is the Privacy Policy for Velocity Frequent Flyer Pty Ltd. It will help you understand how we collect and handle your personal information and online behavioural data in connection with our programs.

We run the Velocity Frequent Flyer program and the Velocity Business Program, and are part of the Virgin Australia Group (“VA Group”). We collect some of your personal information and online behavioural data from, and share it with, other companies in the VA Group to help them operate and improve their products and services. These VA Group companies are:

• Virgin Australia Airlines Pty Ltd
• Virgin Australia International Airlines Pty Ltd
• Virgin Australia Airlines (SE Asia) Pty Ltd
• Virgin Australia Regional Airlines Pty Ltd
• Virgin Australia Cargo Pty Ltd
• Torque Solutions (Australia) Pty Ltd (who analyse Member Data to help us better understand you).

If a business you work for is a Velocity Business Program member, or you travel on a booking that is linked to a Virgin Australia Business Flyer and Velocity Business Program account, you can read our Privacy Statement for Virgin Australia Business Flyer and Loyalty and section 7 of this policy for information about how we collect and handle your personal information and online behavioural data in connection with these programs.

You can also read our Privacy Statement for Membership Join which we give you when you join our Velocity Frequent Flyer program. It covers some of the key points in this Policy.

We’ve organised this Policy to make it as easy as possible to navigate. You can continue reading or use the table of contents above to find information on a specific topic.

3. KEY TERMS USED IN THIS POLICY

To help explain how we collect and use your personal information and online behavioural data, we use some key terms. Taking a moment to understand what these key terms mean will help you understand the Policy.

Velocity/Velocity Frequent Flyer/we/us means Velocity Rewards Pty Ltd and Velocity Frequent Flyer Pty Ltd, the companies that operate the Velocity Frequent Flyer program and Velocity Business Program.

Our Partners are the companies that use our programs to offer benefits to you and our Velocity Business Program members. You can view an up-to-date list of Velocity Frequent Flyer program Partners on our website at https://experience.velocityfrequentflyer.com/partners-offers/all-partners.

You are a member if you have joined the Velocity Frequent Flyer program and been issued a Velocity membership number. Everyone else is a non-member or, if they are associated with a business that is a Velocity Business Program member, a benefit user.

Member Data is the personal information and online behavioural data that we hold about you if you are a member.

Benefit User Data is the personal information and online behavioural data that we hold about you if you are a benefit user, meaning you are associated with a business that is a Velocity Business Program member. See section 7 for an explanation of how and why we collect, handle and share Benefit User Data.

Our programs include the Velocity Frequent Flyer program which is our loyalty program for individuals and the Velocity Business Program which is our loyalty program for small and medium businesses. Virgin Australia Business Flyer is the small and medium business program operated by Virgin Australia Airlines Pty Ltd and linked to the Velocity Business Program.

Personal information is information or an opinion about you, or from which you can reasonably be identified. Most information we collect and hold is personal information because we link it to your Velocity membership number.

Online behavioural data is information we collect when you visit our websites or use the Velocity or Virgin Australia mobile applications (“our mobile apps”).  We collect this data using tracking tools like cookies. We will link this data back to you if you are logged in to your Velocity membership account or a Velocity Business Program account, or if you’ve previously logged in on the same device. If you haven’t logged in, we’ll still collect the data, but we won’t be able to link it back to you. Some of our Partners also collect and share with us online behavioural data about visitors to their websites and mobile apps, including our members.

When we talk about our websites, we mean a website where you have used your Velocity membership account or a business’ Velocity Business Program account to log in to that website. This includes our main Velocity website, the Virgin Australia website, the Velocity Rewards Store, the Velocity e-Store and the Velocity Business Program portal.

When we say we handle your personal information and online behavioural data, we mean the collection, use, disclosure, storage and deletion of that data.

When we use your personal information and online behavioural data which can be linked back to you to select which of our marketing offers to show you online, this is called targeted online advertising. We show you this advertising on social media platforms like Facebook and Instagram, as well as on third party websites.  

Any references to the “Australian Privacy Act” mean the Privacy Act 1988 (Cth), including the Australian Privacy Principles. You can find out more about the Australian Privacy Act and the Australian Privacy Principles from the Office of the Australian Information Commissioner.

4. DATA WE COLLECT ABOUT YOU: MEMBER DATA

Here we explain the types of personal information and online behavioural data we collect about you when you join our Velocity Frequent Flyer program and throughout your membership. We refer to this as your Member Data.

We collect Member Data that helps us build a picture of who you are, so we can deliver a personalised Velocity experience and show you offers and benefits that we think you will find interesting and relevant.

Here’s when we’ll collect your Member Data and the type of information we’ll collect at each point:

4.1 When you become a Velocity member, update your membership details, or enter a competition

We typically ask for details such as your name, address, email address, phone number and date of birth.

When joining the program, we’ll also ask you to set a password, create some security questions, and set a PIN (personal identification number). These details help us to create your Velocity membership account and keep it safe and up-to-date.

You can also choose to tell us other things when you join, including:

• your travel preferences
• whether you are a member of another airline loyalty program
• your sporting and lifestyle interests
• your household status (such as whether you live alone, with others, with a partner, or with family)
• your employment details, if you earn Points when you fly for work

4.2 When you contact us online, on social media or through our Membership Contact Centre

Depending on how and why you get in touch, we might collect:

• information you give us when you make a request, such as a change of name request, Points Transfer or Family Pooling request, or a request for Membership Pause for Parental Leave
• feedback, photos and videos you share
• recordings of calls to our Membership Contact Centre

4.3 When you earn or redeem with us, the VA Group or our Partners

We’ll collect data (including payment information) when you buy products or services from us. That includes when you choose to reward yourself with some shopping in the Velocity Rewards Store.

We’ll also collect data about your transactions with the VA Group and our Partners if you use your Velocity membership number to:

• book a flight
• link your membership with one of our Partners
• transfer Points from a Partner
• earn or redeem Points or Status Credits with a Partner
• enter a competition

4.4 When you interact online with us, the VA Group, our Partners, or our providers

We collect online behavioural data using online tracking tools on our websites, mobile apps, marketing communications and our online advertising. These tools include cookies, tags and tracking pixels. Online behavioural data allows us to learn what you like and don’t like.

Some of our Partners and service providers also use these tools on their own websites and apps and may share insights with us to help us understand what marketing offers and content you might find relevant.

The information we collect through tracking tools includes:

• the operating system of the device you are using
• your web browser type
• your internet service provider (ISP)
• the date, time and duration of your visit to our website
• which pages you visited and clicked on our websites and how long you spent on each page
• the internet protocol (IP) address of the device you are using, which we use to identify the city you are accessing the internet from
• the website you arrived from and the website you went to next
• your interactions with Velocity’s advertising on third party websites, such as news.com.au or eBay, if that website gives us permission to do so
• your interactions with our marketing communications, such as when you open one of our emails
• any purchases you make related to us or our Partners, such as if you redeem Points on our Rewards Store or book a flight on the Virgin Australia website
• how you use our mobile apps, including the pages you visit and click on, the features you use and any of our websites you visit while using the mobile app
• how you interact with push notifications we send to your phone, if you allow us to send you push notifications

4.5 When we collect data that’s publicly available to enrich your Member Data

We also collect geodemographic data, which we license through a third party called RDA Research.

It may sound technical, but geodemographics simply takes data from government sources and develops insights about the traits of people who live in particular neighbourhoods. These are then divided into smaller groups based on similarities in income, education and household type. This helps us better understand how attitudes, lifestyles and product tastes vary between people. This data is then applied to you, based on where you live and how old you are.

For example, if you live in an area where there are many large family homes, and you are of family age, we may present you with offers for family trips in the school holidays. Or, if you live in an area where there are lots of apartments, we might present you with offers for singles, couples and groups of friends (of a similar age to you) to go on city breaks over long weekends.

4.6 When you provide health and other sensitive information

Sometimes, the data we collect from you might indicate a health or medical condition, your religious beliefs or your sexual orientation. We will only collect this type of data with your consent and won’t use it for marketing purposes. We’ll only use it to process your specific request. This might happen, for example, if you make a request for:

• Special Assistance for a travel booking with our airline Partners
• a meal for a travel booking (if this indicates a medical condition or religious belief)
• a Membership Pause for Parental Leave
• a change of name (for example, following marriage)

To help us process some of these requests, we may ask for supporting documents. For example, we may ask for a marriage certificate for a change of name request following marriage.

We collect and handle your Member Data to operate and improve the Velocity Frequent Flyer program and provide you with the exclusive and useful membership benefits you expect. We want to reward you when you use products and services offered by the VA Group and our Partners.

In short, we want you to love being a member and get the most out of it that we can offer you.

Here’s more on exactly why we collect and handle your Member Data:

5.1 To create and manage your membership, we may use your Member Data to:

• assess and process your application to join the Velocity Frequent Flyer program
• assist you if you contact us by phone, mail, email or on social media
• communicate with you about your membership

5.2 To help you to earn, redeem and transfer Points and Rewards and to earn Status Credits, we may use your Member Data to:

• process transactions where you earn, redeem or transfer Points and Rewards, or earn Status Credits
• manage your travel bookings if you redeem Points for a flight or other travel arrangements like hotel or car hire bookings

5.3 To promote products and services to you, we may use your Member Data to:

• identify offers, products, and services offered by us, the VA Group, and our Partners, which may be of interest to you
• market to you (details of our marketing practices are outlined in the sections below)

5.4 To operate and improve our program, we may use your Member Data to:

• identify new opportunities, including potential new Partners, new offers with existing Partners or improvements to offers
• to enable our Partners, such as partner airlines, to recognise you and provide you with benefits when you travel with them
• contact you in relation to market research
• help us and the VA Group to operate our businesses, including:
  • to train our staff
  • to test and develop our systems
  • to comply with our legal, audit, assurance and reporting obligations
  • to investigate and protect against fraud and other illegal activities

We prefer to collect your Member Data directly from you. However, we sometimes collect it from, and share it with, third parties who can help us deliver useful membership benefits to you.

When we share your Member Data with third parties, we always do so in accordance with this Policy. Before we share it, we ensure there are protections in place to keep your Member Data secure and confidential.

Here’s a list of the third parties we may work with and the type of information we may share:

6.1 VA Group and Partners

If you use your Velocity membership to earn or redeem Points with the VA Group or our Partners, we’ll collect some Member Data from them and share it with them.

Some Member Data is captured on our Partners’ web channels or point of sales systems and they send it to us. We use this data to calculate the Points you have earned or redeemed with that Partner.

6.2 People who act for you

We may collect data from, and share it with, people you’ve authorised to act for you. This may include:

• people who book and manage flights and other travel arrangements for you, including corporate bookings
• your family members when you use Family Pooling or a Points Transfer to a family member
• your authorised representative or lawyer

6.3 Third parties who help us to understand what might interest you

These are companies who provide us with:

1. Market research services
   These include the platforms used to run our member research panel, our monthly member satisfaction survey and send out surveys that help us develop new products or partnerships.
   
   The companies we work with are Qualtrics and Potentiate.
   
   
2. Geodemographic services
   As described earlier, we use this data to enrich your Member Data and to help us send you relevant offers and benefits, based on where you live and how old you are.
   
   
3. Data matching services
   These services use your Member Data, such as your name and email address, to identify you as a customer of one of our Partners, or of a potential new Partner.
   
   Data matching with potential new Partners helps us identify whether we share a similar customer base. This helps us assess whether a new Partner would be of interest to our members.
   
   When we match with existing Partners, we can improve our offers from that Partner to you and include or exclude you from a marketing offer as appropriate. For example, our financial services Partners may wish to exclude you from a marketing offer if you already have an account with them.
   
   The aim here is to avoid bothering you with things you already know about or that we assume you won’t be interested in.
   
   We conduct many of our data matching activities through Torque Solutions (Australia) Pty Ltd, which is part of the VA Group. We also use services provided by Equifax Australia.

6.4 Third parties who help us to interact with you or run our business

These third parties only use your Member Data to deliver the services we’ve asked them to provide, and they can’t use it for their own purposes. We may collect your Member Data from, and share it with:

• digital platforms and marketing technologies such as Facebook, Instagram, Google and Adobe. These companies help us to define our marketing and advertising audiences, and to deliver marketing offers and targeted online advertising
• Placard, who produces and sends membership packs
• mmw3degrees who produce direct postal mail on our behalf
• third parties, including Sitel, who help us with customer support, including call centre functions. Our Membership Contact Centre is also supported by the Virgin Australia Guest Contact Centre
• Anisimoff, who help us to run competitions and promotions
• technology service providers, such as Amazon Web Services and Amadeus, who provide systems to help us manage your membership.

7. HOW AND WHY WE COLLECT, HANDLE AND SHARE BENEFIT USER DATA IN CONNECTION WITH THE VELOCITY BUSINESS PROGRAM

Here we explain the types of personal information and online behavioural data we collect about you if you are associated with a business that is a Velocity Business Program member, how we collect it, why we collect and handle it and how we share it with third parties. We refer to this as your Benefit User Data.

We operate the Velocity Business Program so that business members and individuals associated with those businesses can receive recognition and benefits for bookings linked with their Virgin Australia Business Flyer account and eligible transactions with Partners. The Velocity Business Program is subject to the Velocity Business Program Terms.

If you are associated with a business that is a Velocity Business Program member, we refer to you in this policy as a benefit user. Where the Velocity Business Program allows you to earn Velocity Frequent Flyer program benefits on Velocity Business Program transactions, we may collect and handle your Member Data (in your capacity as a member) and Benefit User Data (in your capacity as a benefit user) for the same transaction.

7.1 How we collect your Benefit User Data

Here we explain the types of Benefit User Data we collect about you in connection with the Velocity Business Program.

We collect your Benefit User Data so that we can provide recognition and benefits to the Velocity Business Program member and you, deliver a personalised Velocity experience and show you offers and benefits that we think are interesting and relevant to you and the business member.

Here’s when we’ll collect your Benefit User Data and the type of information we may collect at each point:

• when you are nominated as a key contact, account administrator, Travel Management Company contact or are given access to the Velocity Business Program portal for a Virgin Australia Business Flyer and Velocity Business Program member’s account, we may collect your contact details, login credentials and your personal Velocity Frequent Flyer membership number (if you have one):
• when you travel on a booking which is made through the Virgin Australia Business Flyer portal or has otherwise been linked with a Velocity Business Program member’s account through an ABN in the booking or a retro-claim made by a Velocity Business Program member or their nominated Travel Management Company, known as a linked booking. The types of information we collect about linked bookings includes your full name, your flight details and your personal Velocity Frequent Flyer membership number (if you have one)
• when a Velocity Business Program member transfers Points from their loyalty account to your personal Velocity Frequent Flyer account, we’ll collect some of your details from the business member, including your full name and Velocity Frequent Flyer membership number
• when a Velocity Business Program member nominates you to receive other benefits, we’ll collect the information required to make those benefits available to you
• when you interact online with us, the VA Group, our Partners, or our providers, we collect online behavioural data using online tracking tools on the Velocity Business Program portal, our websites, our mobile apps, our marketing communications and our online advertising. These tools include cookies, tags and tracking pixels. Online behavioural data allows us to learn what you like and don’t like. Some of our Partners and service providers also use these tools on their own websites and apps and may share insights with us to help us understand what marketing offers and content you or the business member might find relevant. See section 4.4 for details of the types information we collect through tracking tools

Your linked bookings and any Velocity Point transfers made to you may be visible to the Velocity Business Program member and its authorised users in the Velocity Business Program portal.

7.2 Why we collect and handle your Benefit User Data

We collect and handle your Benefit User Data to operate and improve the Velocity Business Program, including to provide or arrange benefits for the Velocity Business Program member and you.

More specifically, we may collect and handle your Benefit User Data to:

• set up and provide you a login to access the Velocity Business Program member’s account within the Velocity Business Program portal;
• calculate and arrange recognition and benefits for the Velocity Business Program member and you with us, Virgin Australia, and airline and non-airline partners;
• facilitate the transfer of the Velocity Business Program member’s Velocity points to your personal Velocity Frequent Flyer account;
• identify offers, products, and services offered by us, the VA Group, and our Partners, which may be of interest to you or the Velocity Business Program member
• communicate with you about Virgin Australia Business Flyer and the Velocity Business Program, including about linked bookings, tier status, benefits, points earned and transferred;
• contact you with direct marketing promoting brands, products and services (including third party offers) and surveys in relation to or in connection with Virgin Australia Business Flyer and the Velocity Business Program (see section 8 below for more detail about marketing and opting out); and
• perform administrative and back-office functions, such as calculating the Velocity Business Program member’s annual spend, tier status and benefits.

7.3 Third parties: Collecting and sharing your Benefit User Data

To facilitate the link between Virgin Australia Business Flyer and the Velocity Business Program, we collect from, and share with the VA Group, Benefit User Data collected or generated in operating these programs.

We collect personal information and share personal information with the Velocity Business Member you are associated with, as set out in this section 7. We may also collect Benefit User Data from, and share it with:

• our Partners, to allow them to identify whether the Velocity Business Program member or you are eligible for any benefits, and to arrange and communicate those benefits
• our third party service providers who provide products and services to us or help us provide our products and services, including marketing, digital and technology services, technology-related support services and call centre services.

8. HOW WE USE YOUR MEMBER DATA AND BENEFIT USER DATA FOR MARKETING AND ADVERTISING

We may use personal information and online behavioural data to send you marketing and show you advertisements that are personal and relevant.

How we’ll contact you about benefits and offers

Offers, promotions and benefits – from us and our Partners – may be delivered via:

• email
• SMS text message
• mail
• phone call
• push notifications on your mobile device (if you have these enabled on your device)
• targeted online advertising on other websites, including through digital platforms (such as Google and Facebook)
• personalised advertising on our websites and mobile apps

You can always let us know how you would like us to contact you. We explain how to do this in the next section. Despite our best efforts, we may not always get it right. If you think we’ve slipped up, please contact us and let us know your concerns.

First though, let’s take a more in-depth look at some examples of targeted online advertising and personalisation for members

• Targeted online advertising for Member Data
  We may use your Member Data to show you relevant advertising (from us and our Partners) on other websites. To help target this advertising more precisely to you, we may also (securely) share some of your Member Data with our Partners, digital platforms like Google and Facebook or with other third party websites and mobile apps where we pay for our ads to be shown.
  
  Of course, you can choose to not receive targeted online advertising from Velocity. You can do this by opting out through your Velocity membership account. Be aware though that you may still see our general advertising if we are paying to run non-targeted ads on a website that you visit.
  
  
• Personalising your visit to our websites and mobile apps
  If you log in to our websites or mobile apps, we may show you personalised offers and content. After you log out of our websites, you may continue to see these unless you clear our cookies from your web browser.
  
  Unless you log out of our mobile apps, you will remain logged in and may receive personalised offers and content, including push notifications if these are enabled on your device. But we’ll only send these if we think you’ll find them useful.

9. CHANGING YOUR MARKETING PREFERENCES

You’re always in control of your marketing preferences.

We always try to only send offers or show content that is relevant and useful. We do this by basing what we show or send you on your personal information and online behavioural data.

Sometimes, though, you might want to change what you’re receiving or seeing from us. No hard feelings! The table below shows you how to control what marketing and other updates you receive from us.

Please be aware that:

• if you are a benefit user associated with a Velocity Business Program member, you need to separately opt-out of marketing communications for your personal Velocity Frequent Flyer membership and for the Velocity Business Program. You cannot use the preference centre for your personal Velocity Frequent Flyer membership to opt-out of Virgin Australia Business Flyer or Velocity Business Program marketing
• even if you opt out of all Velocity marketing communications, we’ll still contact you about important matters. These include changes to our membership terms, password reset requests, and membership status changes

How members can say “Thanks, but no thanks”

10. INFORMATION WE COLLECT ABOUT YOU: NON-MEMBERS

Even if you’re not a member, we still treat your privacy seriously and we will always handle your personal information as explained in this Policy and as permitted by the Australian Privacy Act.

We collect and handle personal information about non-members, including:

• job applicants 
• travel and booking agents
• a Velocity member’s authorised representatives
• our suppliers and other people we do business with

We handle this information to operate Velocity and manage our commercial relationships with suppliers and other third parties. However, we won’t use or disclose it for marketing purposes, unless you allow us to.

11. HOW WE KEEP YOUR PERSONAL INFORMATION AND ONLINE BEHAVIOURAL DATA SECURE

We’ve built security measures into our systems and processes to protect your personal information and online behavioural data.

We hold your personal information and online behavioural data in our technology systems, databases, telephone recordings and sometimes, in paper files.

When it comes to security, rest assured that we take active steps to protect your personal information and online behavioural data from being accessed, shared, changed or stolen by unauthorised people or companies. We do this by having physical, electronic, and network security systems controls, and we monitor for security violations. We also limit who can access your personal information and online behavioural data, and we train our people to keep your personal information and online behavioural data safe and secure.

We use third parties to process and store some personal information and online behavioural data, including in the cloud. Public cloud service providers sell computing services that share resources and storage between many users. This allows us to access software, tools and storage over the internet, rather than build and host these on our premises. Our public cloud service providers include Amazon Web Services and Microsoft Azure.

Where we store or process your personal information and online behavioural data in a public cloud service, we ensure that our service providers have controls in place to protect the data and keep it separate from other users of the service.

12. SHARING YOUR PERSONAL INFORMATION AND ONLINE BEHAVIOURAL DATA OUTSIDE AUSTRALIA

Sometimes we need to share your personal information and online behavioural data with overseas companies.

Our Partners are located in Australia and overseas.

We also use overseas third party service providers. As part of our ordinary operations, these third party service providers are located in Canada, Denmark, France, Germany, Hong Kong, India, Ireland, Italy, Japan, Malaysia, New Zealand, Paraguay, Poland, Singapore, The Philippines, Turkey, United Kingdom and United States of America.

13. HOW TO ACCESS AND CORRECT YOUR PERSONAL INFORMATION

Under the Privacy Act, you have the right to ask for access to your personal information and ask us to correct it if it is inaccurate.

You can view and update some of your Member Data by logging in to your Velocity membership account. In your account, you can update your contact details, view your transaction activity and update your communications preferences. If you are a benefit user associated with a Velocity Business Program member, you cannot view or update your Benefit User Data through your personal Velocity membership account but you can ask the Velocity Business Program member’s key contact or an account administrator to update your details in the portal.

Don’t have an account or can’t find what you need? If you are a member, call our Membership Contact Centre between 8am-8pm (AEDT) Monday to Friday on:

Australia - 13 18 75
New Zealand - 0800 230 875
Other International Locations - +61 2 8667 5924

If you are a benefit user associated with a Velocity Business Program member, call the Virgin Australia Business Flyer team between 7:30am – 7pm (AEST) Monday to Friday or 8am – 5pm (AEST) Saturday, on 1300 246 498 (Australia only).

You can also contact our Privacy Officer directly. Find contact details in the ‘Contact Us’ section below.

Some things to keep in mind when making a request

• We’ll need to verify your identity before we can process your request.
• We’ll respond to your request as soon as we can and provide you with access to your personal information in the way you have requested, as long as your request is reasonable. 
• If we need to give you access in a way that’s different to your request, we’ll discuss this with you. 
• Occasionally, we might refuse to correct or give you access to your personal information. For example, if we believe that your request will have an unreasonable impact on the privacy of someone else, or if we are investigating possible illegal activity and giving you access might affect those investigations. If we can’t correct or give you access to your personal information as requested, we’ll let you know why in writing. If you disagree with us, you can let us know using the complaints procedure which we outline below.

If we cannot correct your personal information, you can ask us to make a note, including in your Velocity membership account (if applicable), that you believe your personal information is inaccurate, out-of-date, irrelevant or misleading.

14. HOW TO CONTACT US

Snail mail or email? It’s your choice:

privacy@virginaustralia.com

Privacy Officer
PO Box 1034
Spring Hill QLD 4004