RACV Car Share Privacy Policy

1. About RACV Car Share and our commitment to privacy

The privacy of our customers is of utmost importance to Kingmill Pty Limited (ACN 003 966 649) trading as RACV Car Share.

Kingmill Pty Limited also trades as Thrifty Car Rental (Thrifty). Thrifty is a wholly owned company of National Roads and Motorists’ Association Limited.  In this Privacy Policy, a reference to “we”, “us” or “our” means Thrifty. RACV Car Share is a registered business name of Thrifty.

RACV Car Share is a business operated by Thrifty in conjunction with Royal Automobile Club of Victoria (RACV) Limited ACN 004 060 833. All aspects of the RACV Car Share service are supplied to you by Thrifty , but some additional benefits and services may be made available to you from, or offered to you by, Royal Automobile Club of Victoria (RACV) Limited from time to time .

This Privacy Policy sets out how we manage personal information associated with RACV Car Share.

We may update this Privacy Policy from time to time. The most current version will always be located on our website and is also available by contacting our Privacy Officer on 1300 729 047 or by email to privacy@racvcarshare.com.au or at the address detailed below in section 13.

2. Types of personal information we collect and hold

The types of personal information we collect and hold will vary depending on your dealings with us (or our agents, contractors and third parties) and your use of RACV Car Share, or a request or inquiry you make in relation to RACV Car Share.

In addition to the types of information referred to in our Privacy Policy, information we may collect if you become a member of, and use, RACV Car Share may include any or all of the following:

  • name, address(es), telephone number(s) and other contact details;
  • electronic address(es);
  • date of birth and age;
  • gender;
  • credit card details;
  • details of your membership to any loyalty or affiliate program;
  • vehicle details including registration, model and colour (if you ask to sign you up for Royal Automobile Club of Victoria membership);
  • driving history, including details of any driving related offences or motor vehicle accidents;
  • driver’s license number and/or passport number and, upon our request, a copy of your driver’s license or passport;
  • drivers licence validity and history;
  • locations travelled to, from or through in vehicles used through RACV Car Share;
  • telemetry recorded by vehicles you use through RACV Car Share;
  • transaction details relating to your use of our products, services or other benefits;
  • your social media preferences; and
  • any preferences you tell us about or any other information that you provide

We may collect and hold sensitive information, such as the fact that you are disabled, to allow us to provide our services more effectively to you but only if you provide express consent at the time it is provided.

Please see the Direct Marketing section of this policy for more examples of the kinds of personal information we collect.

3. Website cookies and digital services

We collect and hold such information for statistical and maintenance purposes that enables us to continually evaluate our website performance. Some parts of our websites also use “cookies”. A “cookie” is a small text file that is placed on your computer’s hard drive by a web page server. Cookies store information about the use of our website and are used to identify new or previous visitors to the website and what pages have been accessed. Most web browsers are set to accept cookies, but this function can usually be disabled if you wish. Please note that if you do disable this, not all functionality on our websites will be available to you.

We also use Google Analytics features (including Google Remarketing, Google Display Network Impressions Reporting, the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting) on our website, which uses both first party and third party cookies to record standard internet traffic information.  We, and some third parties (including Google), also use the information to optimise ad selection for groups of individuals based on age, gender, interests and past visits to our site.  The cookies allow us and other third parties (including Google) to evaluate your interactions with ad services on our site and serve targeted advertising on sites across the Internet.  We have enabled Google Analytics for Display Advertising which allows Google and other third parties to advertise to you on our site and across the Internet.

We also use (along with third parties including Google) first party cookies (such as Google Analytic cookies) and third party cookies (such as the DoubleClick cookie) to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website.  In addition, we may use data from Google’s Interest-based advertising or third party audience data (such as age, gender, and interests) with Google Analytics to help us understand how user activity varies based on these factors.

By using Google Ads Settings (www.google.com/settings/ads), you can opt out of these features at any time and customise your Google Display Network Ads.  Alternatively, you can opt out of a third party’s vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page (see http://www.networkadvertising.org/choices/#completed).

Importantly, we do not combine the anonymous information collected through Google Analytics with personally identifiable information.

In addition to Google Analytics, we use a range of web analytics tools (such as web beacons) to help us understand consumer behaviour and use of our website.  In particular, these tools enable us to deliver cookies, count visits and understand usage and campaign effectiveness.  This data helps us to stay connected and relevant to our customers.

If you do not wish to receive any cookies you may set your browser to refuse cookies.  However, this will mean that we will not be able to personalise your website each time you visit.

4. Why we collect and hold personal information

We collect, hold and use personal information about our customers to safely, effectively and efficiently provide the RACV Car Share service. This includes, collecting and using your personal information to confirm your identity by reference to government records, to complete your membership and bookings; to provide you services in connection with your rental; for example navigation assistance or an E-Toll Tag, to provide you customer service assistance and to process fees and charges connected to your rental account.

Some of the information we collect is required by our business associates and contractors to operate backend systems which support the safe and efficient supply of RACV Car Share.

We also collect personal information to assist in identifying ways in which we can serve you better, such as providing our products and services to you more effectively and to provide you with services in connection with the Thrifty loyalty program and similar services. We also collect and use your personal information to assist our internal administration and operations including accounting, risk management, record keeping, archiving, systems development and testing, and staff training.

Some of the information we collect is for the purpose of improving our interaction with customers, suppliers, business partners and contractors and their involvement with Thrifty. We collect personal information about third parties, including family members, for purposes in relation to your and their dealings (either directly or indirectly) with Thrifty and the NRMA Group.

Customers who provide personal information about a third party individual need to ensure that those persons are aware of this Privacy Policy, understand it and agree to accept it. If that individual does not have the capacity to understand and agree to these terms, Thrifty requires a parent or guardian to give the assurances set out in this paragraph.

You may refuse to let us collect any of this information from you, but if you do so, you may not be able to use some or all of the RACV Car Share service.

5. How we collect information

Generally, we collect personal information directly from you, such as when you become a member of RACV Car Share. In addition, in the course of providing RACV Car Share, we may collect or compile information which is or becomes personal information. For example, we may collect GPS positional data which records locations to which you have travelled.

We may collect and update this information at any time, including when you contact us for any reason, or in the course of you using RACV Car Share. We may also collect personal information through third parties such as:

  • Royal Automobile Club of Victoria (RACV) Limited, its related companies and affiliated interstate motorists’ clubs;
  • our related companies;
  • our service providers;
  • our business partners who provide customer or loyalty  benefits;
  • Thrifty franchisees throughout Australia;
  • data washing organisations and postal service providers, including Australia Post.

6. Storage and protection of personal information

We store personal information in a combination of secure computer storage facilities and paper-based files and other records. In so doing, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure.

Certain information about your use of RACV Car Share may be accessed by, sent to or processed and stored by our service providers.  Our service providers are obliged to protect the security and confidentiality of that information.

Additionally we will take reasonable steps to destroy or permanently de-identify personal information associated with your use of RACV Car Share when we no longer need it.

7. How we use and disclose personal information

We may use and disclose your personal information for a variety of purposes in connection with the safe and efficient supply of RACV Car Share.  These include:

  • disclosure to a third party identity verification service provider, for the purpose of verifying your identity and matching your identification documents against official records which may be stored on third party systems and services;
  • processing and administering your dealings with us as a member of RACV Car Share;
  • making the benefits of RACV Car Share available to you;
  • developing processes, products, services and benefits to better meet your needs; and
  • disclosing your information for use by relevant parties in connection with RACV Car Share, such as to relevant road transport and law enforcement authorities.
  • We may also use your personal information to offer or provide you with loyalty benefits, discounts or other information about such schemes that may be operated by us or third parties. This includes:
  • providing your details, including information about your use of RACV Car Share, to Royal Automobile Club of Victoria (RACV) Limited, for the purpose of offering motoring club membership to you and other purposes arising from the operation of RACV Car Share;
  • providing your personal information to companies in the RACV Group, and to its other business partners, to give you information and offers about products and services offered by RACV Group or these companies;
  • providing your personal information to Thrifty and to our other business partners, to give you information and offers about products and services offered by us or these companies;
  • obtaining details about how you acquire and use our products, services and benefits; and
  • rewarding customers for utilising our products and services through mechanisms such as discounts, special pricing offers and prizes.

We may provide your personal information to our agents, service providers, contractors, business partners or related companies for the purposes of, or in connection with, the supply of RACV Car Share.

8. Direct Marketing

We collect personal information so that we can provide our customers with useful and relevant information about our products and services. Generally, we collect this information directly from you.  In some circumstances, however, we may collect personal information from third parties, including from our service providers and social media platforms such as Facebook.  We use the information we, or our service providers, collect to assist us to determine how we can best engage with our customers about our products and services.  To this end, we, or our service providers, may collect information about your social media preferences and activities so that we can engage with our customers on social media sites.  We may also collect certain demographic information and behavioural information from social media platforms to better serve consumers with more targeted advertising.  If we do not collect this information in the ways described above, we may not be able to let you know about our products and services in the most effective way.

We may use and disclose the information we collect for the purpose of providing you with tailored marketing communications about our goods and services, or to conduct market research. Typically, we send these communications to your email address or mailing address.  Occasionally, we may also send marketing communications to your social media accounts, including, for example, your Facebook account.

We will also disclose your personal information to our related companies and to our other business partners, and companies related to Royal Automobile Club of Victoria (RACV) Limited and to their other business partners, to give you information and offers about products and services offered by us or these companies or organisations.

9. Opting Out of Direct Marketing

If you do not wish to receive direct marketing information from Thrifty or RACV, please use the contact details below to opt-out or use the unsubscribe feature on our electronic marketing communications. Please note that if you make such a request:

  • We may still need to use your personal information to provide you with the services and products you have requested as a customer; and
  • it may not be possible for us to immediately action a request to cease receiving any or all direct marketing material. However, we will respond to such requests as soon as practicable and will make all reasonable efforts to promptly action your request to opt out of receiving future direct marketing material.

We will not sell or rent your personal information without your consent. We may disclose your personal information where we are required or authorised by law to disclose your personal information or for any purposes connected to a fraud, crime prevention or impropriety investigation.

10. Overseas disclosure of personal information

Certain technology that is required for us to supply RACV Car Share is hosted on computer systems operated by our technology service providers and their subcontractors in France, and information about your use of RACV Car Share, which may include personal information, will be sent to, processed and stored in France.  Some identity verification systems operated by third parties may be located in New Zealand, and accordingly some of the personal information you provide to us may be transmitted to New Zealand for identity verification purposes.

11. Access to, and correction of, personal information

We will take reasonable steps to make sure that the personal information we collect, hold, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact us on 1300 729 047 or privacy@racvcarshare.com.au to update your details.

Following a request, we will provide you with a copy of any personal information which we hold about you in accordance with our obligations under the Privacy Act. We may charge a fee for retrieving this information, in which case we will inform you of the fee in advance of providing the information.

In the first instance, we will ask you to provide some of identification, such as your driver’s licence, to ensure that you have the right to access the information.

12. Making a complaint

If you wish to complain about our handling of your personal information, please send a written complaint to the Privacy Officer in the first instance by using the contact details below. We undertake to promptly acknowledge and investigate any complaint about the way we manage personal information. If you are dissatisfied with the outcome of our investigation, you may take your privacy complaint to the Office of the Australian Information Commissioner (OAIC). For information in making a complaint to the OAIC, please visit the OAIC’s website https://www.oaic.gov.au/individuals/how-do-i-make-a-privacy-complaint, or phone 1300 363 992.

13.  Contacting us

If you have any questions about this Privacy Policy, if you wish to update information we hold about you or if you wish to make a complaint about the way we manage personal information, please write to:

The Privacy Officer
Kingmill Pty Limited t/a RACV Car Share

PO Box 874
Mascot NSW 1460

You can also telephone us on 1300 729 047 or email our Privacy Officer at privacy@racvcarshare.com.au.

 

Thrifty Privacy Policy 22.8.2016