1. Our commitment to privacy
The privacy of our customers is of utmost importance to Kingmill Pty Limited trading as Thrifty Car Rental (ACN 003 966 649) (Thrifty). Thrifty is a wholly owned company of National Roads and Motorists' Association Limited.
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 Thrifty and the products, services and benefits we (or our agents, contractors and third parties) provide to you, or a request or inquiry you make in relation to such products, benefits and services.
This information 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;
- credit card details;
- details of your membership to any loyalty or affiliate program (for example, Blue Chip membership);
- vehicle details including registration, model and colour (if you ask us to sign you up for NRMA membership);
- driver's license number and/or passport number and, upon our request, a copy of your driver's license or passport;
- 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.
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.
4. Why we collect and hold personal information
Generally, we collect, hold and use personal information about our customers to provide them with a range of products, services and benefits. This includes, collecting and using your personal information to complete your rental booking; 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.
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.
5. How we collect information
Generally, we collect personal information directly from you, such as when you make a reservation or request a product or service, in the course of providing you with that product or service, or when you have other dealings with us. For example, we may collect your personal information from our rental locations or through our in-vehicle technology.
We may collect and update that information over the phone, over the Internet, in person (when you visit us at a Thrifty office), when you write to us or if you participate in our marketing campaigns. We may also collect personal information through third parties such as:
- our related companies including NRMA;
- affiliated interstate motorists' clubs;
- our business partners who provide customer or loyalty benefits;
- our service providers;
- Insurance Australia Limited* (trading as NRMA Insurance) and its related entities;
- 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.
Additionally we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We impose strict requirements of security and confidentiality on all third parties as to how they store, handle and deal with your personal information.
7. How we use and disclose personal information
We may use and disclose your personal information for a variety of purposes in connection with servicing you as a customer of Thrifty and in relation to our business operations. These include:
- processing and administering your dealings with us as a customer, supplier or contractor;
- processing and administering your dealings with us and verifying your membership as a part of a loyalty or discount program with one of our business partners including any auto club of which you are a member;
- providing you with the products and services you have requested from us;
- developing processes, products, services and benefits to better meet your needs;
- dealing with any complaint made by you to us or any complaints handling body;
- where applicable for invoicing purposes only, to any third party who is responsible for payment of your account for your car rental; and
- disclosing your information for use by relevant parties in connection with our services, such as to Thrifty franchisees and to Service NSW or to any enforcement body issuing infringement notices and to any toll road operator.
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 personal information to companies in the NRMA Group, to Thrifty franchisees 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, franchisees, contractors, business partners or related companies for the purposes of, or in connection, with the supply of products and services to you and for the same purposes above.
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 investigation or any other impropriety investigation.
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 may also disclose your personal information to companies in the NRMA Group, to our other business partners, our service providers and Insurance Australia Limited* (trading as NRMA Insurance) and its related entities, to give you information and offers about products and services offered by us or these companies.
9. Opting Out of Direct Marketing
If you do not wish to receive direct marketing information from Thrifty, 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.
10. Overseas disclosure of personal information
Thrifty is likely to disclose some of your personal information, for the purposes described above, to organisations outside Australia including New Zealand, the Philippines, the United Kingdom and the United States of America.
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 (02) 8337 2700 or firstname.lastname@example.org 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 http://www.oaic.gov.au/privacy.making-a-privacy-complaint, or phone 1300 363 992.
13. Contacting us
The Privacy Officer
Kingmill Pty Limited t/a Thrifty Car Rental
PO Box 874 Mascot
Mascot NSW 1460
You can also telephone us on (02) 8337 2700 or email our Privacy Officer at email@example.com.
*Insurance Australia Limited (trading as NRMA Insurance) and its related entities are separate and unrelated to Thrifty and National Roads and Motorists' Association Limited.