We are committed to protecting your privacy through compliance with the Privacy Act 1988 (Cth) (Privacy Act), the Australian Privacy Principles (APP) and related privacy codes.
This Policy outlines how we collect, use, disclose and store your personal information. It applies to all personal information collected via our website, the Buckle Up mobile application known as Buckle Up (Application), other applications owned, operated or controlled by us, social media accounts and identification verification tools. It also applies to any personal information we collect from third party service providers such as Facebook and PayPal. By providing personal information, you consent to us collecting, using, storing and disclosing your personal information in accordance with this Policy.
Please read this Policy carefully and contact us using the details below if you have any questions.
- The types of information we collect
- Personal information
Personal information is information or an opinion about you or from which you can be reasonably identified.
In particular, we may collect the following types of personal information about you:
- name, gender, email address, age or date of birth;
- photographs and uploaded pictures such as driver’s license or profile pictures;
- payment and transactional information, such as credit card details;
- your device ID, device type and information, geo-location information, , statistics on page views, traffic to and from the sites, ad data, Internet Protocol (IP) address and standard web log information;
- details of products or services which we have provided to you or you have enquired about; and
- any other information relating to you that you provide us directly or indirectly through our Application, including information you provide through emails, social media, surveys and competition entry forms.
- Sensitive information
Sensitive information is a form of personal information, and is information or an opinion of a sensitive nature.
We will only collect, use or disclose your sensitive information if it is reasonably necessary to carry out our functions or activities and we have your consent.
- Why we collect and use your personal information
We collect and use your personal information through lawful and fair means so we can perform our business activities and functions. Your personal information is collected and used for the following purposes:
- to enable you to access and use our Application;
- to provide you with our products and services;
- to provide third parties with our products and services;
- to give you information about our products and services;
- to interact with you;
- to connect you with our business partners;
- to administer surveys;
- to send you promotional and marketing information that may be of interest to you, including information sent by our business partners;
- to administer rewards or other promotional activities sponsored or managed by us or our business partners;
- to conduct product and market research;
- to develop consumer insights so we can better understand your preferences and interests, personalise your experience and enhance the products and services you receive;
- to send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you;
- to perform administrative and operational functions;
- to comply with any legal requirements;
- for any related purpose for which we are entitled to use your personal information; and
- for any other purpose for which you give your consent.
- How we collect your personal information
- We generally collect personal information directly from you when you:
- create an account on our Application;
- use and interact with our Application, including interacting with other users of our Application;
- communicate with us over email, online chat systems, the phone or in person;
- share personal information with us from other applications, social media, websites or services;
- participate in one of our surveys or competitions;
- purchase one of our products or services; and
- We may also collect your personal information from third parties including:
- other users of our Application;
- our service providers, payment system operators and/or processors and debt collectors;
- referrals who may have referred you to us; and
- organisations with whom we have an agreement to share information for business, marketing and related purposes.
- You may choose to deal with us anonymously where it is lawful or practical to do so, such as when you make a general enquiry about our products or services.
- We generally collect personal information directly from you when you:
- Disclosing your personal information and who might have access
- Within Australia
We may disclose your personal information to the following third parties for the purposes described in this Policy, such as:
- our employees, related entities and employees of those entities;
- our business partners, including the owners or operators of any application or platform you have subscribed for through us or in connection with us;
- our professional advisers, dealers and agents;
- third parties and contractors who provide services to us, including customer enquiries and support services, information technology service providers, marketing and advertising services;
- payment systems operators and/or processors;
- our sponsors or promoters of any competition that we conduct;
- any third parties authorised by you to receive information held by us; and
- government, regulatory and law enforcement agencies as required, authorised or permitted by law.
- Outside Australia
We may disclose your personal information to third parties located in the United States of America or other countries as required.
By providing us with your personal information, you consent to us disclosing your personal information to overseas third parties and acknowledge we will take reasonable steps to ensure that overseas third parties deal with your personal information in a way that complies with the Privacy Act and the APPs.
- Using your personal information for direct marketing
We, or our business partners, may use your personal information to contact you via phone, SMS, email or mail to promote and market our products and services.
By providing us with your personal information, you consent to us or our business partners contacting you for direct marketing, even if you have registered your home, mobile and/or fax number on the Do Not Call Register.
You can opt-out from being contacted by us or our business partners for direct marketing by emailing ‘unsubscribe’ to firstname.lastname@example.org or sending an SMS with ‘unsubscribe’ to 0491 231 945.
- If you do not provide us with your personal information
You can choose not to provide us with your personal information.
However, this may mean we will be unable to provide you with our products and services, including our Application, or be limited in how we can do so.
When you use or access our Application, we may collect information through cookies on your device.
Cookies are files that store information on the device on which you are using or accessing our Application. They tell us when you visit our Application, which pages you visit and the information you downloaded. They also remember your details and preferences so you can easily continue your browsing session when you return to our Application.
If you do not want to activate Cookies, you can opt-out of receiving them by amending the settings of your internet browser, however you may find that some parts of our Application will have limited functionality and personalisation if you do so.
- How we store and protect your personal information
We hold your personal information in electronic form, in secure databases owned and operated by our third party service providers.
We manage the security of your personal information by using SSL encryption, implementing firewalls and login password protocols, monitoring staff access and through network segregation for sensitive information.
While we take reasonable steps to ensure your personal information is protected from loss, misuse and unauthorised access, modification or disclosure, security measures over the internet can never be guaranteed. This means we cannot guarantee the security of your personal information. In the event of a data breach, we will comply with the required data breach reporting laws.
- Links to third party websites/platforms
Our application may contain links to websites, other apps and social media platforms operated by third parties.
Those links are provided for convenience and may not remain current or be maintained. Unless stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites.
The privacy policies that apply to third parties’ websites may differ substantially from this Policy, so we encourage you to read those privacy policies before using those websites.
- Accessing or correcting your personal information
- Accessing your personal information
If you would like to access your personal information, please contact us using the details below.
While we try to give you access to your personal information free of charge, we may charge you a reasonable fee to cover costs associated with:
- searching for, locating and retrieving your personal information; and
- reproducing and sending you your personal information.
In certain circumstances, we may not be able to give you access to your personal information. In these circumstances, we will write to you to explain why we cannot comply with your request.
We will try to respond to your request for access within 14 days of receiving your request.
- Correcting your personal information
We try to ensure any personal information we hold about you is accurate, up-to-date, complete and relevant.
If you believe the personal information we hold about you is inaccurate, out-of-date, incomplete, irrelevant or incorrect, please contact us using the details below and we will take reasonable steps to ensure it is corrected.
We will try to respond to your request for correction within 14 days of receiving your request.
- Destroying or de-identifying personal information
We destroy personal information when we no longer need it, unless we are otherwise required or authorised by law to retain the information.
- Making a complaint
If you believe your privacy has been breached or you have a complaint about our handling of your personal information, please contact us using the details below.
We take privacy complaints seriously. If you make a complaint, we will respond within 7 days to advise you of the person responsible for managing your complaint. We will try to resolve your complaint within 30 days. When this is not reasonably possible, we will contact you within that time to let you know how long we will take to resolve your complaint.
We will investigate your complaint and, where necessary, consult with third parties about your complaint. We will decide how to address your complaint and write to you to explain our decision.
If you are not satisfied with our decision, you can refer your complaint to the Office of the Australian Privacy Commissioner. Details about how to file a complaint can be found at http://www.oaic.gov.au.
- Depending on the nature of the change, we may announce the change on our website home page or by email (if we have your email address). However, in any event, by continuing to use the Application following any changes, you will be deemed to have agreed to such changes.
- Contact us
All questions or queries about this Policy and complaints should be directed to:
0491 231 945
Dated: 5 October 2017