At Transmissito Pty Ltd ACN 632 893 488 and its related entities (“Transmissito”/ ‘3Clicks’ / ‘we’ / ‘us’) it is important to us that we manage your personal information securely and consistently with relevant legislation, including the Privacy Act 1988 (Cth) (‘Privacy Act’) as well as the Credit Reporting Privacy Code (‘Code’) where applicable.
This Policy outlines how we collect, disclose, use, store or otherwise handle personal information. It is not limited to current customers but to all individuals and business users who deal with us.
This Policy explains:
- The kinds of personal information (including credit-related information) we collect, and the purposes for which we do that;
- How we manage the personal information that we collect about you;
- How you can seek access to and correction of that information;
If necessary, how you can make a complaint relating to our handling of that information
Transmissito is a proprietary company based in Australia providing a service to connect Independent Transport Contractors and Consumers or a platform for “Transport on Demand”.
We are governed by the Australian Privacy Principles (‘APPs’) under the Privacy Act. In our interactions with you, we also comply with Credit Reporting Privacy Code requirements. These set out the way organisations and government agencies can collect and use, disclose and provide access to personal and sensitive information.
(a) Application means the mobile application used to access Transmissito’s Services.
(b) Claims means all demands, claims, proceedings, penalties, fines and liability whatsoever (whether criminal or civil, in contract, tort or otherwise).
(c) Loss means all losses including financial losses, damages, legal costs and other expenses of any nature whatsoever.
(d) Personal information is information that identifies or could identify a person, whether it is true or not. It may include, for example, your name, age, gender, profile picture, contact details, bank account details and financial information.
(e) Sensitive information as defined by the Privacy Act (as amended) is also personal information but relates to your opinions, views, racial or ethnic origin,political options or affiliations, religious beliefs, philosophical beliefs, membership of a professional or trade association, membership of a trade union, sexual preferences or practices or criminal record or health, genetic, biometric information or biometric templates.
(f) Credit Information as defined in the Privacy Act is personal information about an individual (other than sensitive information) relating primarily to your credit-related dealings which can be disclosed to Credit Reporting Bodies (‘CRBs’) that report on consumer credit worthiness and includes:
i. identification information about the individual; or
ii. consumer credit liability information about the individual;
iii. repayment history information about the individual; or
iv. a statement that an information request has been made in relation to the individual by a credit provider, mortgage insurer or trade insurer; or
v. the type of consumer credit or commercial credit, and the amount of credit, sought in an application:
a. that has been made by the individual to a credit provider; and
b. in connection with which the provider has made an information request in relation to the individual; or
vi. default information about the individual; or
vii. payment information about the individual; or
viii. new arrangement information about the individual; or
ix. court proceedings information about the individual; or
x. personal insolvency information about the individual; or
xi. publicly available information about the individual:
a. that relates to the individual’s activities in Australia or the external Territories and the individual’s credit worthiness; and
b. that is not court proceedings information about the individual or information about the individual that is entered or recorded on the National Personal Insolvency Index; or
xii. he opinion of a credit provider that the individual has committed, in circumstances specified by the provider, a serious credit infringement in relation to consumer credit provided by the provider to the individual.
(g) Credit Eligibility Information provided to us by CRBs, so it may also include information about your credit related dealings with other credit providers. CEI also includes any credit worthiness information that we derive from the data from a credit reporting body, for example credit ratings, scores and evaluations about you and your credit worthiness.
(h) Website means the website used to access Transmissito’s Services. Any reference to our Website is also a reference to our Application.
WHAT WE DO
1.1Examples of where we might collect personal or sensitive information include:
(a) when you visit our Website or Application, create a user account, and / or use our online services;
(b) when entering into an agreement with us for the supply of services;
(c) when you correspond or communicate with Transmissito or our agents over the telephone or in any other manner, including by letter, facsimile or email;
(d) providing your credit card information to facilitate payment;
(e) using your internet service provider or mobile network to connect to our services;
(f) when we assess your eligibility for our services;
(g) if you connect with us via a social network;
(h) when you complete a customer survey or send us feedback;
(i) in administering your account, including requests and the provision of our services.
WHY WE COLLECT AND USE PERSONAL INFORMATION
At Transmissito we take your personal privacy seriously. We may collect personal information about you for various reasons, for example:
(a) because you have provided it directly to us, for instance contact details, date of birth, and credit card numbers or bank account details;
(b) to process your application to Transmissito and/or request for services;
(c) to provide you with the most appropriate services for your needs;
(e) because you work for us;
(f) for purposes directly related to any of the above and any of our services;
(g) to provide follow-up on information regarding Transmissito, including responding to comments or questions or providing our services to you;
(h) to meet any requirements of government funding for programs including receiving, collecting and collating de-identified statistical information;
(i) to monitor and evaluate existing services and plan for future services; and
(j) if we are required to share your information with government or regulatory bodies, as required or authorised by law.
We only use your personal and sensitive information for purposes which are directly related to the reason you provided us with your information in the first place and where you would reasonably expect us to use your information. This may include sharing your personal or sensitive information with service providers.
We may share your information with government or regulatory bodies as required or authorised by law. These agencies may also share this information with organisations or agencies in other jurisdictions.
HOW WE COLLECT INFORMATION
Whenever possible, we will collect personal information directly from you unless unreasonable or impractical for us to do so. Transmissito may also collect personal information in a variety of ways, including but not limited to when you:
(a) use our Website or Application;
(b) connect with us via social network;
(c) phone us;
(d) write to us;
(e) email us;
(f) visit us in person;
(g) through the use of our services; and
(h) provide feedback to us.
There are certain instances in which we will collect information about you from third parties where it is unreasonable or impracticable to collect it directly from you. For example, we may collect information about you from a business which provides information about commercial credit worthiness for us to assess your application.
DISCLOSURE OF PERSONAL INFORMATION
Disclosure of personal information to third parties
We will not disclose your personal information to another person unless you have given consent or if one of the exceptions under the Privacy Act applies. Where possible, the information that could reasonably identify you as an individual is first removed.
Except as set out above, Transmissito will not disclose your information to a third party unless one or more of the following applies:
(a) you have given your consent for us to do so;
(b) you would reasonably expect us to use or give that information for another purpose related to the purpose for which it was collected such as the sharing of information– directly related to the purpose for which it was collected);
(c) it is otherwise required or authorised by law;
(d) it will prevent or lessen a serious threat to somebody’s life, health or safety or to public health or safety;
(e) it is reasonably necessary for us to take appropriate action in relation to suspected unlawful activity, or misconduct of a serious nature that relates to our functions or activities;
(f) it is reasonably necessary for the enforcement of a law conducted by an enforcement body.
Examples of disclosure
(a) Customer Records
Transmissito maintains records of all customers including financial information which may need to be shared with financial institutions, government or regulatory bodies from time to time.
(b) Credit Reporting
We may disclose personal information about you to a CRB in relation to any credit-related dealings with us. That information may be included in reports by the CRB to other credit providers or to another CRB to help them assess applications by you for credit.
DISCLOSURE OF INFORMATION TO THIRD PARTIES OVERSEAS
We may disclose personal information to overseas based organisations or agencies in the provision and/or administration of your account. We undertake to protect your personal information by ensuring the country of the overseas based organization or agency has similar protections in relation to privacy, or that we enter into contractual arrangements with the organisation or agency to ensure the protection of your privacy.
CAN I REMAIN ANONYMOUS?
It is your choice to provide information to us. Wherever it is lawful and practicable, you have the option not to identify yourself or to use a fictional name when interacting with us. You can remain anonymous when using some parts of our Website, or sites administered by us.
It may be necessary for us to collect your personal or sensitive information if you would like certain services. If you choose to withhold the information we require, we may not be able to provide you the services you have requested.
SECURITY AND STORAGE OF YOUR INFORMATION
We store your information in a number of ways including physically (such as in paper form) or electronically with third party data storage providers. Your privacy and the security of your information is very important to us so where we store your information with third party providers, we will enter into contractual arrangements with those providers to ensure they take appropriate measures to protect your information.
We take appropriate steps to protect your personal and sensitive information held by us from misuse, interference, unauthorised access, modification, loss or disclosure. This includes during storage, collection, processing and transfer and destruction of the information. These steps include but are not limited to:
(a) ensuring our computer systems and Websites have security systems in place such as up to date firewall and data encryption;
(b) maintaining security systems and monitoring of our premises;
(c) implementing confidentiality agreements with our employees and contractors, sub-contractors, service providers and their agents;
(e) maintaining document storage security policies and procedures; and
(f) implementing verification procedures for all inquiries/transactions to ensure only authorised people can access personal information.
Our Website may contain links to external websites. We recommend that you review the privacy policies of those external websites as we are not responsible for their privacy practices.
HOW TO ACCESS AND CORRECT YOUR INFORMATION
We will take reasonable steps to ensure that all personal information we collect, use or disclose is accurate, up-to-date, complete, relevant, and not misleading.
We will correct any personal information that we believe to be incorrect, out-of-date, incomplete, irrelevant or misleading. This may include taking reasonable steps to notify any organisation or government agency to which information was disclosed about the correction. You may request to access or correct your personal information at any time by contacting the Privacy Officer using the contact details below. We will give you access to your information unless one of the exceptions under the Privacy Act applies. For example, if providing access would be unlawful or denying access is authorised by law.
If you request to access or correct your information, we will respond within a reasonable time (usually within 30 days). If your request is refused, we will give you a written notice that sets out the reasons for refusal and how to complain about the decision.
DIRECT COMMUNICATIONS AND PROMOTIONAL MATERIALS
From time to time, we may send out promotional materials and information from government departments or other third parties. If you do not wish to receive these communications, please contact us to unsubscribe from that mailing list.
Your information may also be used by us to provide you with details of other organisation’s services where permitted by the Privacy Act or where you have consented to the use or disclosure of your personal information for direct communications and promotional materials.
It is our policy that any direct communications or promotional material will include a statement advising that you can request to not receive further material from us by contacting us using the details provided. Please note that if you choose this option this will also prevent you receiving offers of discounts as well as all promotional and informational materials.
The Transmissito Website and other websites administered by us use small files known as ‘cookies’ to record your visit to the Website and collect some statistical information. We use this information to help administer and improve our Websites and services. We do not use this information to personally identify you. Information we may collect includes:
(a) your computer’s IP address;
(b) your domain name;
(c) the date and time or access to the Website;
(d) pages accessed and documents downloaded;
(e) the previous site visited;
(f) if you have visited the Website before;(g) the type of browser software in use;(h) your mobile carrier; and
(i) device information including device and application ID.
You may set your browser to disable cookies when visiting our Websites. However, some Website functions may be unavailable if you choose to do so.
USE OF OUR WEBSITE AND APPLICATION
While Transmissito endeavours to take reasonable care in preparing and maintaining the information on this Website we do not warrant the accuracy, reliability, adequacy or completeness of any Website content. You acknowledge and accept that the Website content may include technical inaccuracies and typographical errors. The Website content is subject to change at any time without notice and may not necessarily be up to date or accurate at the time you view it.
It is your responsibility to enquire with us directly to ensure the accuracy and currency of the material or information you seek to rely upon. To the extent permitted by law, including the Competition and Consumer Act 2010 (Cth), Transmissito disclaims all liability for loss directly or indirectly arising from your use of or reliance on the Website and the Website content.
You must not attempt to change, add to, remove, deface, hack or otherwise interfere with this Website or any material or content displayed on the Transmissito Website.
THIRD PARTY CONTENT AND LINKS
Transmissito’s Services may be accessed by our Website or by Application. Use of applications that connect our Website or Application with a third-party service (“Third Party Services”) are at your own discretion and risk and such Third Party Services may communicate, connect to or gather information from you.
Transmissito is not responsible for any such external links and material, and do not endorse any advertising or other content appearing in or linked to from our Services.
All correspondence and any communications between you and any third party accessed or found through our Services are strictly between you and the third party.
By using Third Party Services, you agree and acknowledge to the following:
if you use the Third-Party Services to share information, you are consenting to information about your profile on our Service being shared;
your use of a Third-Party Services may cause personally identifying information to be publicly disclosed or associated with you;
your use of a Third-Party Services is at your own risk and you hereby indemnify and hold us harmless from and against all Claims and Loss arising out of on in any way through the use of the Application;
Additionally, Apple Inc., Google Inc., Microsoft Corporation or Blackberry Limited and/or their applicable international subsidiaries and affiliates will be third-parties to these Terms and Conditions if you access the Application using Third Party Applications developed for Apple iOS, Android, Microsoft Windows, or Blackberry-powered mobile devices. These third parties are not parties to these Terms and Conditions and are not responsible for the provision or support of the Services in any manner. Your access to the Services using these devices is subject to terms set forth in the applicable third party’s terms of service.
You may not:
(a) remove any copyright, trademark or other proprietary notices from any portion of the Website;
(b) reproduce, modify, prepare derivative works based upon, distribute, license, lease, sell, resell, transfer, publicly display, publicly perform, transmit, stream, broadcast, or otherwise exploit the Website except as expressly permitted by Transmissito;
(c) decompile, reverse engineer or disassemble the Website except as may be permitted by applicable law;
(d) link to, mirror or frame any portion of the Website;
(e) cause of launch any programs or scripts for the purpose of scraping, indexing, surveying, or otherwise data mining any portion of the Website or unduly burdening or hindering the operation and/or functionality of any aspect of the Services; or
(f) attempt to gain unauthorised access to or impair any aspect of the Services or its related systems or networks.
Unless expressly granted, Transmissito does not grant any license or right in, or assign all of part of, its intellectual property rights in the content or applications incorporated into the Website or Application or in the user interface of the Website or Application.
COMPLAINTS AND ENQUIRIES
If you consider your privacy concerns have not been resolved satisfactorily by us, or you wish to obtain more information on privacy requirements, you can contact The Office of the Australian Information Commissioner on 1300 363 992 or visit their Website at www.asic.gov.au.
|By Post||Attn: Privacy Officer Transmissito Pty Ltd 8 Washington Place Stretton QLD 4116|