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1. OVERVIEW

1.1. Best Buy Car Rentals Pty Ltd (ACN 605 750 990) and our related entities ('Us', 'We' or 'Our') are committed to protecting the privacy of your personal information in accordance with the requirements of the Privacy Act 1988 (Cth) (the "Act").

1.2. This Privacy Policy sets out details about how we and our related entities collect and manage your personal information and your credit related personal information and credit eligibility information when entering into, or making a vehicle rental booking and/or enquiry.

1.3. This Privacy Policy may be updated from time to time to take into account changes to laws, technology and our operations. A current version of this policy will be published on our website or can be obtained free of charge upon request.

1.4. When you:

  • engage Us to provide you with any products or services;
  • complete a vehicle rental booking;
  • communicate with us through email, by telephone, in writing;
  • or use any of our other services, including our website,

you agree to the use and disclosure of your personal information in the manner described in this policy.

1.5. It is important to note that we cannot guarantee or accept responsibility for the privacy practices or the content of web sites to which we provide links.

1.6. "Personal Information" means information that can be associated with a specific person and can be used to identify that person and includes your information. Information that has been made anonymous or aggregated so that it cannot be used, whether in combination with other information or otherwise, to identify a specific user is not personal information.

2. COLLECTION

2.1. We collect and hold the kinds of personal information depending on our interaction with you. Generally, the personal information we may collect from you include:

  • name, date of birth, address, telephone number, email address, passport information, drivers licence details and other contact details;
  • your bank account details, debit account details and credit card information;
  • information we collect from providing you with our goods and services, such as;
  • vehicle preference;
  • reservations and rental details including dates, times and places of vehicle hire;
  • employer details and personal referees;
  • personal information you provide to us when you participate in a promotion, competition, promotional activity, survey, market research, subscribe to our mailing list;
  • marketing information;
  • personal information shared by you from social media applications, services or other websites;
  • to the extent permitted by law, other personal information provided by or obtained from third parties; or
  • information about the products and services you would like to obtain through us or that we provide or have provided to our clients.

2.2. We may also collect and hold sensitive information about you that is specifically relevant and necessary for the purpose of our business activities and functions, and your consent is first obtained. Such information may include information relating to:

  • our customer's citizenship or country of birth; or
  • membership of professional or trade associations or unions;

2.3. We may collect and hold any types of credit information about you that are permitted under the Act including:

  • financial information, including your assets, liabilities, income and expenses;
  • the fact that you owe us money and the amount and circumstances;
  • in specified circumstances that in our opinion you have committed a serious credit infringement (that is, acted fraudulently or shown an intention not to comply with your payment obligations);
  • information about serious credit infringements (e.g. fraud);
  • information about adverse court judgments and insolvency; and publicly available information about your credit worthiness.
3. PURPOSE FOR COLLECTION

3.1. We collect, hold, use and disclose personal information so that we are able to perform our business functions and provide customers with our products and services. We will collect, hold, use and disclose personal information for the following purposes:

  • our general business activities and functions, including providing you with our products and services, including services in connection with your vehicle rental and sending you marketing about other products and services that we reasonably believe may be of interest to you;
  • assessing and processing an application or enquiry for rental vehicle or to accept an individual as a guarantor under a rental application;
  • for administrative purposes in relation to the ongoing management of your rental arrangement;
  • communicating with you, including responding to your enquiries about our products and services, applications and accounts;
  • participating in the credit reporting system and providing information to Credit Reporting Bodies ("CRBs") as permitted under Part IIIA of the Act;
  • meeting our legal and regulatory requirements, and enforcing our rights;
  • conducting, improving and developing a business relationship with you;
  • operate and generate content and provide customer support and billing services (including updates and improvements);
  • dealing with complaints; and
  • marketing (such as providing individuals with information about our products and promotional notices and offers).
4. MODES OF COLLECTION

4.1. Whenever it is reasonable and practicable to do so, we collect personal information about our clients directly from you, or your appointed broker or agent.

4.2. Where the Act permits, we may also collect personal information from other people or organisations. Sometimes this may happen without your direct involvement. Some examples of the people or organisations from which we may collect personal information about you are:

  • other car rental providers and our business affiliates;
  • publicly available sources of information (such as telephone directories);
  • your authorised representative (such as a legal adviser);
  • third-party agents (such as business referrers, finance brokers and insurance brokers);
  • CRBs, such as Veda or Dunn and Bradstreet; or
  • government agencies (such as the Land and Property Information office).

4.3. We take reasonable steps to ensure that you are aware of:

  • the likely use of your personal information;
  • the right of access to your personal information;
  • any law requiring collection of the credit related information; and
  • the main consequences of failure to provide any credit related personal information.
5. DISCLOSURE

5.1. We may disclose your personal information:

  • for the primary purposes for which it was collected such as those described above (that is, for our business functions and activities);
  • where you have consented to the use or disclosure;
  • where required or authorised by Australian Law, or to a court/tribunal; or
  • where we reasonably believe that the use or disclosure is necessary to prevent serious impact to an individual's life, health or safety or a serious threat to public health or safety.

5.2. We will not disclose your personal information for any other secondary purposes, unless your consent has been given or as required by law and we will not sell or license any personal information that we collect from you.

5.3. We may also share your personal information with our related entities.

5.4. Where the Act permits us, we may from time to time disclose your personal information to organisations outside of our group of related entities. Generally, these are organisations that help us with our business functions and operations. These organisations may include:

  • authorised representatives of the Best Buy Car Rentals group who sell products or provide services on our behalf;
  • insurers;
  • financial institutions;
  • our accountants, auditors or lawyers; or
  • your representative (for example lawyer, accountant, financial broker and adviser).

5.5. If it is required by the Act we will seek your consent before disclosing to these organisations, otherwise we will only disclose your personal information to these organisations where is it reasonable in the circumstances.

5.6. Where the Act permits us to do so, we may also disclose your credit related information to CRBs such as Veda or Dunn & Bradstreet, if default in the payment of any rental fees or charges to us. That information may then be shared by the CRB with other credit providers for credit assessment and other purposes.

6. HOLDING OF INFORMATION

6.1. We use security procedures and modern technology to protect the personal information that we hold.

6.2. Much of the information we hold is stored electronically on servers owned by us that are located in our company premises or in secure data centres owned by third parties located in Australia. Access to and use of this information within Best Buy Car Rentals is appropriately limited to protect from misuse or unlawful disclosure of the information.

7. ACCURACY OF INFORMATION

7.1. We rely on you to provide us with accurate and up to date information about you. If there are any changes to your personal information during the course of dealing with us, you are responsible for advising us.

7.2. We will take reasonable steps to ensure your personal information is kept up-to-date, accurate, complete and not misleading. If you believe the personal information we hold about you is incorrect or inaccurate, you can request that we update this information by contacting our Privacy Officer (details below).

7.3. We will correct information we hold about you if we discover, or you are able to show to a reasonable standard, that the information is incorrect or inaccurate. If you seek a correction and we disagree that the information is incorrect, we will provide you with our reasons for taking that view.

8. ACCESS AND CORRECTION OF INFORMATION

8.1. You can contact us to request access to the personal information that we hold about you. Generally, we will give you access to your personal information. However, there may be exclusions as permitted under the Act that apply that permit us to not provide you with access in some circumstances.

8.2. If access is denied, we will provide you with the reason why unless, having regard to the grounds for refusal, it would be unreasonable for us to do so. You may make a complaint about a refusal to the Office of the Australian Information Commissioner.

8.3. You can also contact us to request that we correct personal information that we hold about you. Any request to access or correct information should be made to our Privacy Officer using the contact details set out below and will be dealt with in accordance with the Act.

9. MARKETING

9.1. We may use and disclose your personal information to inform you about other products and services we think may be of interest to you in the future, and we may also disclose your personal information to our related entities, third party affiliates or other partners (together referred to as "the Related Companies") so that they may use and disclose the information to inform you about their products and services, including for direct marketing by Best Buy Car Rentals or the Related Companies.

9.2. We respect your right to ask us not to use your information for direct marketing and Best Buy Car Rentals and the Related Companies will not send you information about products and services if you so request by contacting us using the details set out below. You will generally be given the opportunity to “opt out” from receiving marketing communications from us. You may “opt out” from receiving electronic communications by following any prompts to do so that we may engage from time to time, or by writing to our Privacy Officer.

10. OVERSEAS DISCLOSURE

10.1. Any personal information provided to us may be transferred to, stored by or disclosed to an overseas recipient. For example, we may use a server hosted overseas to store data, which may include your personal information, or engage an organisation located overseas to assist us in our general business operations.

10.2. Before your information is disclosed to an overseas recipient we will take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach privacy laws in relation to your personal information ("reasonable steps").

10.3. However, the reasonable steps may not apply, if we reasonably believe (when disclosing your personal information to the overseas recipient) that:

  • the recipient of the information is subject to a law, that has the effect of protecting the information in a way that, overall, is at least substantially similar to the way in which the Act protects the information; and
  • there are mechanisms that an individual can access to take action to enforce the protection of their privacy.
11. UNSOLICITED INFORMATION

11.1. We will take reasonable steps to determine whether or not the information we receive may be unsolicited information. If we believe that information is unsolicited information, we will destroy the information as soon as practicable or ensure that it is de-identified.

12. ANONYMITY

12.1. Only where it is practicable to do so, we may allow you the option not to identify yourself when dealing with us. However not identifying yourself to us may make it difficult to effectively provide you with our products or services.

13. GOVERNMENT IDENTIFIERS

13.1. We will not use government identifiers such as your tax file number or Medicare number to identify you.

14. COOKIES AND WEBSITE

14.1. A 'cookie' is a packet of information placed on a user's computer by a website for record keeping purposes. Cookies are generally used on our website to:

  • access online services - if you visit the Best Buy Car Rentals website and/or log into our secure areas we will use cookies to enable us to authorise your access;
  • manage advertising - we use advertising companies to deliver our online advertising. When you see one of our ads on a third party website, cookies are sometimes used to collect information about what pages you visit and the type of software you are using; and
  • traffic monitoring, we use tracking companies to gather information about how people are using the Best Buy Car Rentals site, this information includes time of visit, pages visited, and some system information about the type of computer you are using. We use this information to enhance the content and services offered on our website.

14.2. Cookies may also be used for other purposes on our website but in each case none of the information collected can be used to personally identify you.

14.3. Cookies may collect and store your personal information. This Privacy Policy applies to personal information collected via cookies. You may adjust your internet browser to disable cookies. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Please note, each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

14.4. If you disable the use of cookies on your web browser or remove or reject specific cookies from this website or linked sites then you may not be able to gain access to all of the content and facilities in this website, and/or may hinder our ability to provide you with our full range of products and services.

14.5. If you visit the Best Buy Car Rentals website to browse, read or download information, our system will log these movements. These web site logs are not personally identifiable and Best Buy Car Rentals makes no attempt to link them with the individuals who browse the site.

14.6. You may also encounter cookies used by third parties and placed on certain pages of our website that we do not control and have not authorised (such as webpages created by another user). We are not responsible or liable for the use of such cookies.

14.7. Where applicable, your account information is password protected and we recommend you do not divulge your password to anyone. To further protect your personal information, your log-in time will automatically expire after a certain period of inactivity.

15. COMPLAINTS

15.1. If you have a complaint about the way we have dealt with your personal information or think that we have breached the Australian Privacy Principles or the Act, you may make a complaint by contacting our Privacy Officer at the contact details listed below. We will respond to complaints within a reasonable time (generally 30 days).

15.2. If you disagree with our decision, you may refer your complaint to the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing enquiries@oaic.gov.au.

16. CONTACT US

16.1. We will endeavour to ensure your questions or concerns are handled by our Privacy Officer in an appropriate and reasonable manner.

16.2. If you have any questions regarding our Privacy Policy or handling of information, please contact our Privacy Officer at the details below:

Addressee:

  • In Writing:
  • By Phone:
  • By Fax:
  • By Email:
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