Privacy Policy - Tradie Spec

Purpose of Policy

Introduction
- TradieSpec Pty Ltd ACN 629 902 576 (TradieSpec Pty Ltd) is committed to protecting the privacy of personal information we collect from our customers and other individuals utilising our services. This Privacy Policy applies to the use of all services and websites provided by or under the control of TradieSpec Pty Ltd or one of our related entities (collectively, TradieSpec or we/us) on which a link to this Policy appears.
- This Privacy Policy explains how we collect, hold, use, manage and disclose your personal data and information pursuant to the Privacy Act 1988 (Cth) and the Australian Privacy Principles (together, Privacy Legislation). In this Privacy Policy, references to ‘personal information’ and ‘sensitive information’ have the meanings defined in the Privacy Legislation.
- We take your privacy seriously and are committed to keeping your information confidential and secure. By providing us with any personal information (including via our websites), you consent to us processing your data in accordance with this Privacy Policy and the laws and regulations that may apply to this Policy.
Information covered
- This Privacy Policy will cover:
  - The type of personal data and information we may collect and store about you;
  - How and when we may collect personal information about you;
  - The purposes for which we may collect, hold, use or disclose your personal information;
  - How and why we may share personal information with our related entities;
  - How and why we may share personal information with third parties;
  - Disclosure of personal information outside of Australia;
  - Your rights to access, remove or update your personal information (including how you may unsubscribe from receiving marketing communications from us);
  - How you may lodge a complaint about alleged mishandling of your personal information;
  - How we will handle complaints;
  - Our processes and procedures regarding data security and data breaches;
  - Relevant information pertaining to periodical changes made to our Privacy Policy; and
  - Our contact information.

Collection and retention of personal information

TradieSpec is a vehicle rental company offering short-term and long-term hiring options for customised utility trade vehicles to trades people across Australia. For the purposes of providing these services, TradieSpec is required to collect and process certain personal information (including sensitive information) about persons utilising our services. In doing so, TradieSpec will take all necessary steps and precautions to ensure compliance with this Privacy Policy and the Privacy Legislation in the handling of personal information.

Information provided to us directly
- We collect your data whenever you contact us and provide us with information that we are able to identify you by, including when you contact us by phone, email or when you sign up to use our services. In particular, we collect information about you when you request a quote for our services, in initial customer interviews for the purposes of assessing vehicle rental eligibility, and every time you email, call, text or otherwise contact us directly or visit our office.
- The types of personal information we may collect include:

For Sole Traders:

Full name;
Contact details (including residential address, email address and telephone number);
Identity information (including drivers licence and other identity documents, biometric information);
Residential status (including rental agreement and/or rates notices);
Australian Business Number (ABN);
Employment history;
Driving / traffic history record;
Financial details (including credit card details, cashflow history, bank account details, bank statements, credit history and Statements of Financial Position); and
Emergency contact

For Companies:

Company name and ACN;
Director name(s);
Contact details (including business address, email address and telephone number);
Director(s) identity details (including drivers licence and/or passport); and
Financial details (including bank account details and bank statements).

Information collected automatically
- We automatically gather certain information technology and internet services related information from visitors to our websites, including IP addresses (including device identification identifying the type of device used to access our websites), time and date stamps of visits, browser information, browsing patterns, internet connection details demographic data and general operating system information.
- This information is used to build and grow our professional and marketing profile, aid strategic development, identify potentially fraudulent or criminal activities and assist in the audit of the use of our websites.
Use of cookies
- Our websites use Cookies are small data files stored on a user’s device by a website. Cookies are used to remember information about the user, such as their preference or login status, for future visits to the website or other related websites. Cookies can assist us in providing a more personalised experience for our users by improving the functionality of the website and may assist in monitoring and tracking of user patterns for business growth and advertising purposes.
- By consenting to the use of cookies on our websites, certain information about your use of our sites may be shared with some of our social media, advertising and analytics partners, who may combine this information with other information provided directly to them by you. Our websites use various different types of cookies, some of which may be placed on our sites by third party collaborators and partners of TradieSpec.
- Pursuant to Australian laws and regulations, we are permitted to automatically store cookies on your device where the information stored is strictly necessary for the operation of our websites. For the collection of all other types of cookies falling outside of this classification, we will require and request your consent before collecting this information.
- You can at any time change or withdraw your consent to the collection of cookies on our website (and may also prevent your browser from accepting and storing cookies) by changing your browser’s cookie settings. Any such revocation of our rights to collect and store your data will not affect the lawfulness of any prior use of that data.

The Privacy Legislation governs the collection of personal information, which means information about you that can reasonably be used to identify you. As a general rule, use of cookies is not used for personal identification purposes.

For more information about managing cookies, see the guidance from the Office of the Australian Information Commissioner (oaic.gov.au).

Information collected from third parties
- Certain third-party collaborators, partners or otherwise associated entities of TradieSpec may provide us with personal information relating to you collected and stored by them. It’s the responsibility of the relevant third party to ensure it has obtained your consent to collect and share this personal information. Where practicable, TradieSpec will request confirmation from our third-party partners that consent to collect and pass on personal information has been obtained before using the information received.

Some of our third-party partners that we may collect personal information from include Creditor Watch, Equifax and other reputable credit reporting bureaus (for the purpose of obtaining credit reports).

Purposes for collecting, storing and using personal information

Privacy Legislation
- The Privacy Legislation mandates that personal information:
  - can only be used and stored where there is a lawful basis to do so; and
  - can only be used for the particular purpose for which it was collected, such as providing you with our rental vehicle related services, and not for any other purpose unless we have obtained your express consent to do so.
- Required purposes
  - At TradieSpec, we may collect, store, disclose or otherwise use your personal information for one or more of the following purposes:
    - to assess customers’ eligibility for vehicle rental agreements in accordance with our eligibility criteria (e.g. financial details, employment history and driving record);
    - to create an account record to enable customers to access, maintain and update their personal information (e.g. full name, email, telephone number and other contact details);
    - to identify customers (e.g. full name, email, telephone number, residential address, biometric information and other identification information);
    - to communicate with customers (e.g. email and telephone number)
    - [to assist customers in determining funding options (e.g. financial information)];
    - to assess and identify avenues for collection of bad debts;
    - to collect necessary information required for the performance of any rental agreement we have with you (i.e. to provide our services to you);
    - for the purposes of delivering and/or collecting rental vehicles;
    - where we have a legitimate interests to do so;
    - where we have a legal obligation to process and/or store the information; and
    - where you have consented to the use of your personal information.
  - We will ordinarily only collect sensitive personal information that is directly related to, or reasonably necessary for, the provision of our services, and to enable the operation of functions and activities required to offer and provide these services. By providing us with sensitive information, you consent to our collection and handling of that information in accordance with this Privacy Policy and our Privacy Collection Statements.
  - We strive at all times to ensure our processing of your personal information is lawful, transparent and in compliance with this Privacy Policy and any applicable requirements and principles imposed by the Privacy Legislation.
- Storing personal information
  - All personal information collected by us will be stored in a secure cloud computing environment located within Australia or the US that is managed by and under the control of TradieSpec Pty Ltd and/or our third party collaborators or partners.
- Direct advertising and marketing consentsss
  - We may use your personal information for advertising and marketing purposes where you have provided your consent for us to do so. This may include sending you marketing or promotional offers promoting:
    - special offers and other customer incentives;
    - upcoming sales and other events;
    - news regarding TradieSpec;
    - charity drives TradieSspec will be involved in; and
    - current and new products and services.
  - We will not use any sensitive information for direct marketing purposes unless we have obtained your express consent to do so.
  - If you have elected to receive information about our services (or any services offered jointly with or on behalf of other organisations) and wish to edit your preferences or unsubscribe from receiving any marketing communications from us, you can do so at any time by contacting us on the contact details set out in section 10 or this Privacy Policy.

Sharing information with related entities

All personal information collected by us will be held primarily by TradieSpec Pty Ltd. Depending upon the nature of specific services provided, a related entity of TradieSpec Pty Ltd may be engaged to deliver or manage the provision of the service, in which circumstance, any relevant personal information required for the purposes of providing that service may be shared to the related entity.

Sharing information with third parties

In order to provide the services offered, we sometimes need to share your data with third parties. However, we will continue to be responsible for the usage and security of your data when this happens.
TradieSpec may share your personal information with the following third-party recipients:
- logistics suppliers that deliver products on behalf of TradieSpec;
- financial services companies that process TradieSpec financial transactions;
- debt collection agencies; and
- government bodies, law enforcement agencies and data protection or privacy regulators, if and when required by law.
Other than as specified in this Privacy Policy, we will not share your personal information with undisclosed third parties without your prior consent, unless required to do so by law.

Right to access, remove or update personal information

It is your responsibility to ensure that any personal information provided to us by you is current and accurate at all times.
You have the right to access personal information we hold about you and may at any time contact our office to request that we:
- make any relevant changes to the information we hold to ensure your personal information is accurate and up to date;
- erase, remove and/or stop using or processing any personal information about you held by us where there is no longer a primary purpose or reasonable legal grounds for us to use or store the information; or
- transfer any personal information we hold about you to a specified third party.
Upon receipt of such a request from you, we are legally obligated to provide you with access to your data and will take all reasonable steps to comply with your request, unless we are restricted by law to do so.
Any request to access, remove or update your personal information held by us can be made by contacting us on the contact details set out in section 10 of this Privacy Policy. We will respond to a request made within 30 days of receipt of the request.
We will not impose a fee upon you for making a request for access to your personal information. However, we may impose a charge upon you to recover any reasonable cost we incur in preparing, releasing and giving access to any requested personal information.

Complaints

If you believe that we have failed to comply with any of our obligations under the Privacy Legislation or this Privacy Policy, you have the right to make a complaint to us directly by emailing us at section 10 of this Privacy Policy. We will review your complaint and commence an investigation (where applicable) within 30 days of receipt of the complaint.

The investigation period may take up to 30 days or such other period as confirmed in writing. Once the investigation has been completed, we will provide you with a decision of your complaint.
If you are unhappy with the result of the investigation and wish to take your complaints further, you have the right to contact the Office of the Australian Information Commissioner (OAIC). Further information about how to make a complaint to the OAIC can be found at oaic.gov.au or by contacting the OAIC via email at enquiries@oaic.gov.au or telephoning 1300 363 992.

Data breaches

If we suspect that a data breach has occurred, we will undertake an assessment of the circumstances of the suspected breach as soon as reasonably practicable, but in either event within 30 days of being alerted to the suspected breach. Where it is ascertained that a breach has occurred, where required by law, we will notify the Australian Privacy Commissioner and any affected persons as soon as practicable after receiving becoming aware that a data breach has occurred.

Changes to our Privacy Policy

TradieSpec may amend or update this Privacy Policy at any time. Where we make a material change to this Policy, we will provide a notice addressing the relevant change on our website(s).
By continuing to access and use our services and/or websites following a material amendment to our Privacy Policy, you consent to the updated Policy. If you do not agree to any material changes made, you should refrain from using or accessing our services and/or websites.

Contact information

The registered office of TradieSpec is located at:

TradieSpec Pty Ltd ACN 629 902 576
Unit 2, 16/18 Norman Street
PEAKHURST NSW 2210
AUSTRALIA

All queries relevant to this Privacy Policy and any personal information collected, held, used, disclosed or otherwise handled by TradieSpec should be addressed to:

Chief Executive Officer
TradieSpec Pty Ltd ACN 629 902 576
Unit 2, 16/18 Norman Street
PEAKHURST NSW 2210
AUSTRALIA

All comments, queries and requests relating to our use of your personal information are welcomed.