Draft — not in force
This page renders the accepted draft text of our Privacy Policy. It has not yet been reviewed or signed off by the Product Owner or a qualified legal adviser, and it is not our published policy. The site is marked noindex for search engines while this notice is in place.
Privacy Policy
This policy is written for a general audience. It explains what personal information The Eagles Nest collects through this website, why, who it is shared with, and what rights a visitor or guest has under the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
- Status:
- Draft, tracked as DOC-01 in the site's policy register. Requires Product Owner / legal sign-off before publication.
- Last updated:
- [PLACEHOLDER — PO/legal to set the effective date on publication]
- Applies to:
- https://theeaglesnest.host and associated enquiry, booking, and marketing touchpoints.
§1
Who we are
The Eagles Nest is operated by [PLACEHOLDER — PO: legal entity name] ("we", "us", "our"), trading as The Eagles Nest, a private accommodation property in the Scenic Rim, Queensland, Australia.
We are bound by the Australian Privacy Principles under the Privacy Act 1988 (Cth).
Contact for privacy matters:
- Email: stay@theeaglesnest.host
- Phone: 0489 960 735
§2
What personal information we collect
We collect only what is needed to respond to enquiries, process bookings, and — where a visitor opts in — communicate about the property. Specifically:
| Category | What it includes | Collected via |
|---|---|---|
| Booking and enquiry details | Name, email, phone, stay dates, guest numbers, and message content submitted through an enquiry or reservation | Guesty (our booking and reservation platform) |
| Newsletter / lead-magnet sign-up | Name and email address for visitors who opt in to receive updates or a downloadable offer | Our email marketing platform — see review note below |
| Analytics data | Pages viewed, approximate location (city/region level), device and browser type, referring site, on-site behaviour | Google Analytics 4 (GA4), only after consent (see §4) |
| Advertising / remarketing data | Browsing behaviour used to measure and target advertising | Meta Pixel and Google Ads, only after consent (see §4) |
| Technical / server logs | IP address, request timestamps, and standard web server log data | Microsoft Azure (our hosting provider) |
Review note (ESP — email service provider): the project plan specifies Mailchimp as the newsletter/lead-magnet platform. An ActiveCampaign connector also exists in the current toolset. The final email service provider is to be confirmed by the PO before this section names a specific vendor. Until confirmed, this policy refers to it generically as "our email marketing platform."
We do not knowingly collect sensitive information (as defined by the Privacy Act) through this website, and we ask that enquiry and booking messages not include sensitive information beyond what is needed to arrange a stay (for example, information relevant to an accessibility request may be provided voluntarily by the guest).
§3
How we collect information
- Directly from you — when you submit a booking or enquiry, contact us by email or phone, or sign up to receive updates.
- Automatically — through cookies and similar technologies when you browse the site, but only for analytics and advertising purposes once you have given consent (see §4). Essential site functionality does not require consent.
- From our service providers — for example, Guesty passes booking and enquiry details submitted through the booking engine back to us.
§4
Cookies, tracking, and your consent (DOC-02)
This site uses a consent banner (bottom-left, dismissible, no scroll lock) so visitors can choose whether analytics and advertising tools run. Analytics and advertising tags (GA4, Meta Pixel) stay inactive until a visitor opts in. This is a deliberate, documented decision — see docs/design/GATE_DECISIONS.md (DOC-02, decided 2026-08-17).
| Cookie category | Purpose | Runs before consent? |
|---|---|---|
| Essential | Core site functionality (e.g. remembering the consent choice itself, security, load balancing) | Yes — required for the site to work |
| Analytics (GA4) | Understanding how visitors use the site, so we can improve it | No — dark until opt-in |
| Advertising (Meta Pixel, Google Ads) | Measuring and improving the relevance of our advertising, including remarketing | No — dark until opt-in |
You can change your mind at any time. [PLACEHOLDER — PO/legal: confirm the mechanism for withdrawing consent after the initial choice, e.g. a persistent "cookie settings" link in the footer, once the consent banner build (Stage 3) is implemented.]
§5
Why we use your information
We use personal information to:
- Respond to booking enquiries and process reservations
- Communicate with guests before, during, and after a stay
- Send updates or offers to people who have opted in to our mailing list
- Understand how the website is used, so we can improve it (analytics, only with consent)
- Measure and refine our advertising (only with consent)
- Maintain the security and reliability of the website (server logs)
We do not use personal information for any purpose unrelated to these without telling you first.
Pricing note: this website does not publish rates. Live pricing and availability are provided only through the booking engine at the point a guest requests a quote, which is a matter of booking process, not of personal information handling — noted here only to avoid confusion with the data practices described in this policy.
§6
Who we disclose information to, including overseas (APP 8)
We share personal information only with service providers who help us run the property and the website, and only to the extent needed for that purpose. Several of these providers process data outside Australia:
| Provider | Role | Data involved | Location |
|---|---|---|---|
| Guesty | Booking and reservation management | Booking/enquiry details | Processes data overseas (United States) |
| Our email marketing platform (Mailchimp or ActiveCampaign — see review note in §2) | Newsletter and lead-magnet communications | Name, email address | Processes data overseas (United States) |
| Google (Analytics, Ads) | Website analytics and advertising measurement | Analytics and advertising identifiers, only after consent | Processes data overseas (United States and other locations) |
| Meta | Advertising and remarketing (Meta Pixel) | Advertising identifiers, only after consent | Processes data overseas (United States and other locations) |
| Microsoft Azure | Website hosting and server logs | Server log data, technical metadata | Hosting region: [PLACEHOLDER — PO: confirm current Azure Static Web Apps region for disclosure accuracy] |
Because these providers may hold or process information outside Australia, APP 8 requires us to disclose this. We take reasonable steps to ensure overseas recipients handle personal information consistently with the Australian Privacy Principles, including relying on each provider's own privacy and security commitments.
The booking engine (book.theeaglesnest.host): when you move from this website to check availability or make a booking, you are handed over to the Guesty booking engine. It carries our name and sits on our domain, but it is operated by Guesty, and it loads services chosen by Guesty rather than by us. When you use it, your device connects to those services and they receive your IP address and basic technical information about your browser.
Observed on 18 August 2026, the booking engine connects to:
| Service | Role | Data involved |
|---|---|---|
| Guesty (app.guesty.com, static.guesty.com, assets.guesty.com) | Runs the booking engine itself | Booking details, IP address, technical metadata |
| Split.io | Feature management used by Guesty to control which version of the engine you see | IP address, technical metadata |
| GeoJS | Location lookup from IP address, used by Guesty | IP address |
These are Guesty's own sub-processors. We do not engage them, cannot switch them off, and receive no data from them — but because the booking engine appears under our brand and our domain, we disclose them here rather than treat them as somebody else's concern. Their handling of your information is governed by Guesty's privacy terms and by theirs.
The consent choice you make on this website does not carry across to the booking engine. It is operated separately and we cannot apply our settings to it.
We do not sell personal information to third parties, and we do not disclose it to anyone beyond the providers listed above except where required by law.
Note: Sanity (a content management platform previously considered for this project) does not process any personal information for this site — content management moved to an in-repository model (see docs/design/ADR-002-content-astro-collections.md), so Sanity is not, and will not be, a data recipient.
§7
Access, correction, and your rights
You may ask us to:
- Tell you what personal information we hold about you
- Correct any information that is inaccurate, out of date, or incomplete
- Delete information we hold about you, where we are not required to keep it (see §8)
- Unsubscribe from marketing communications at any time (every email we send includes an unsubscribe link)
To make a request, contact us using the details in §11. We will respond within a reasonable time and will not charge for a straightforward request. If we refuse a request, we will explain why.
§8
How long we keep information
[PLACEHOLDER — retention decisions pending Stage 5 compliance register. This section will set out how long booking, enquiry, marketing, and analytics data are retained, and the basis for those periods, once the register is complete.]
In general, we do not keep personal information longer than we need it for the purposes described in this policy, or as required by law (for example, tax and financial record-keeping obligations).
§9
Security
We take reasonable steps to protect the personal information we hold from misuse, interference, loss, and unauthorised access, modification, or disclosure. This includes relying on the security measures of our service providers (Guesty, our email marketing platform, Google, Meta, and Microsoft Azure), each of whom is responsible for securing the systems they operate on our behalf.
No method of transmission over the internet or electronic storage is completely secure. If we become aware of a data breach that is likely to result in serious harm, we will handle it in line with the Notifiable Data Breaches scheme under the Privacy Act.
§10
Complaints
If you believe we have mishandled your personal information, please contact us first using the details in §11 so we can try to resolve it directly.
If you are not satisfied with our response, you can lodge a complaint with the Office of the Australian Information Commissioner (OAIC):
- Website: https://www.oaic.gov.au/privacy/privacy-complaints
- Phone: 1300 363 992
§11
Contact us
For any question about this policy, or to make a privacy-related request:
- Email: stay@theeaglesnest.host
- Phone: 0489 960 735
§12
Changes to this policy
We may update this policy from time to time, for example if our data practices, service providers, or legal obligations change. The "Last updated" date at the top of this page will reflect the most recent version. Where a change is significant, we will take reasonable steps to make it clear on the website (for example, a notice on the site or in the consent banner) rather than relying solely on the date change.
This is a working draft prepared to support the Eagles Nest website build. It is not legal advice, and it must not be published until reviewed and signed off by the Product Owner and, where appropriate, a qualified legal adviser (Gate H8, the site's policy register, DOC-01).