SG Fleet Australia Pty Limited (we, us, our) is a wholly owned subsidiary of SG Fleet Group Limited (ACN 167 554 574), a company listed on the Australian Securities Exchange.
We take our obligations to protect personal information seriously. We are bound by the Privacy Act 1988 (Cth) (Privacy Act) and the Australian Privacy Principles (APPs). This policy explains how and why we collect, use, hold and disclose your personal information.
By providing information to us, including by accessing our services, website, or otherwise engaging with us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this policy.
1. What is personal information?
Personal information is any information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether the information or opinion is recorded in a material form or not.
2. The kind of personal information we collect and hold
We collect and hold information that is reasonably necessary for us to carry out our business activities (which include fleet management, vehicle leasing and salary packaging services) and provide you with our products and services. For example, when you purchase or use any of our products or services, contact us or otherwise visit our website. The information we collect from you may include your identity and contact details, your history of purchases and use of our products and services, and details of enquiries or complaints you make.
The types of personal information that we collect and hold will depend on the nature of your dealing with us, which include (but is not limited to):
(a) contact and identification information such as name, address, phone number, email address, date of birth, marital status, gender, driver’s licence details and other contact details;
(b) employment-related information such as your profession, occupation or job title, employer and payroll information;
(c) payment (including bank) details used to purchase our products or services;
(d) financial position and information and supporting documentation;
(e) credit information, such as particulars of consumer and commercial credit enquiries made with a credit reporting bodies (CRB) for the purpose of assessing your application for commercial credit, collecting payment that are overdue in relation to commercial credit provided by us, assessing whether to accept you as a guarantor in relation to commercial credit provided by us or credit for which an application has been made to us by a company or another individual. For more information see our Credit Reporting Policy (www.sgfleet.com/au/credit-policy);
(f) transaction history information;
(g) legal proceedings that relate to credit provided to you or for which you have applied;
(h) vehicle-related information such as driving speeds, patterns and locations, fuel fills and purposes of travel; and
(i) personal references.
3. Why do we collect, hold and use your personal information?
We collect, hold and use your personal information so that we can:
(a) confirm your identity, communicate with you and manage our relationship with you;
(b) assess and process your application for any product or services that you apply for, or if you are a guarantor, assess whether to accept you as a guarantor;
(c) provide you with access to protected areas of our website;
(d) perform all tasks associated with providing credit and our products and services to you, including performing all necessary administrative tasks;
(e) manage overdue payments and enforce our rights (including undertaking debt collection) in connection with any credit provided to you;
(f) perform internal processes including product development, risk management, pricing an audit;
(g) conduct credit scoring, securitisation, research, risk management and portfolio analysis;
(h) search and register interests under the Personal Property Securities Act 2009 (Cth);
(i) market to you products and services provided by us and our related bodies corporate, dealers, insurers or suppliers; and
(j) comply with relevant laws, including Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth), rules and other subordinate instruments, Personal Property Securities Act 2009 (Cth), and, where applicable, National Consumer Credit Protection Act 2009 (Cth).
Sometimes you may voluntarily disclose, or we may be required to collect, use, store and disclose sensitive information for specific purposes (eg. information about your health for the purpose of assessing your hardship relief application).
Where applicable, we may be authorised to collect your tax file number for the purposes of managing your superannuation contributions under a salary packaging arrangement which has been agreed between you and your employer. Access to tax file number information for such purpose is required under taxation and superannuation laws such as the Income Tax Assessment Act 1936 and the Superannuation Industry (Supervision) Act 1993. In order to send contributions using SuperStream*, we are also required to collect the unique superannuation identifier (for APRA-regulated funds), electronic service address (ESA) for Self-Managed Super Funds and the bank account details of your nominated super fund.
* All superannuation contributions made under a salary sacrifice arrangement must be sent using the SuperStream data and payment standard. For more information on SuperStream, please refer to www.ato.gov.au/superstream.
If you do not provide us with your personal information, we may not be able to provide you with our services, communicate with you or respond to your enquiries.
4. How do we collect your personal information?
We will collect your personal information directly from you whenever you interact with us, for example:
(a) through your use of our website; or
(b) when you complete an application.
We may also collect information from third parties including:
(c) our related bodies corporate, business partners, assignees or potential assignees;
(d) introducers, referrers and any other person associated with the lodgement of your application or with whom we collaborate with to provide services to you or may jointly provide services to you;
(e) our banks, financial advisors, funders and related service providers that assist in the processing of your application and the management of your credit;
(f) suppliers of any goods or services financed with credit we provide;
(g) trustee, servicer, credit enhancer, funder, rating agency or other third party, in connection with any funding of your transactions including by means of an arrangement involving securitisation;
(h) your referees, past and present employers, past and present landlords, next of kin;
(i) any person acting on your behalf (eg. financial advisors, solicitor, broker, accountant, executor, administrator, trustee or guardian);
(j) any guarantor or proposed guarantor of your application for credit;
(k) third party service providers including fuel suppliers, insurance providers, maintenance providers, accident management or roadside assistance suppliers;
(l) persons with whom we have white label arrangements (eg. to sell our product under another brand and their related bodies corporate);
(m) rating agencies, valuers and debt collection agencies;
(n) CRBs and other credit providers who have provided credit to you;
(o) government, law enforcement agencies and regulatory authorities (eg. tax authorities) in connection with their lawful information request or to meet legal obligations in any relevant jurisdiction;
(p) from persons who know you including persons with whom you are financially linked; and
(q) any person specifically authorised by you in writing.
We may also collect your personal information from publicly available sources of information, such as from public registers or social media.
5. Do we use your personal information for marketing?
We may use your personal information for marketing and promotional purposes and may send you information about other products and services that may be of interest to you, including by direct marketing. These products and services may be offered by us, our related companies, our other business partners or our service providers. Our communications to you may be sent in various forms such as mail, SMS and email. You consent to us sending you marketing communications. If you indicate a preference for a method of communication, we will endeavour to use that method wherever practical to do so. If you do not wish to receive these types of communication, or do not want your information disclosed for marketing purposes, you may opt out by:
(a) following the opt-out instructions provided in the marketing communications; or
(b) contacting us. Our contact details are set out below.
6. Who do we disclose your personal information to, and why?
We may transfer or disclose your personal information to:
(a) our related bodies corporate or contractors who will deal with your personal information in accordance with their own privacy policies (these parties also have responsibility to keep your information confidential);
(b) insurers, financiers and rating agencies, others of those financier group companies, contractors or other third-party service providers (particularly in the provision to you of products and services involving insurance and finance we are required to pass your details to insurers and financiers);
(c) financiers and credit reporting and rating agencies for the purpose of the funding, refinancing, sale or securitization associated due diligence and review of the products and related services provided to you;
(d) service providers, such as web site hosting providers, IT system administrators and digital transaction management providers;
(e) third parties including government agencies or toll road operators where required or allowed by law or court or tribunal order or in order to register or to protect our interests or to deal with infringements;
(f) any party acting on your behalf (e.g. financial advisers, lawyers, or accountants);
(g) your employer or your guarantor;
(h) suppliers of purchased goods or other persons who have or require an interest in the purchased goods;
(i) organisations to whom we outsource functions including professional advisers and collection and mercantile agents;
(j) third party service providers in respect of your products and related services including service providers assisting you with repairs and claims and any person who introduces you to us; and
(k) where applicable, so that we comply with relevant taxation and superannuation laws, we will forward all necessary data (including tax file number) associated with superannuation contributions, to a third-party solution partner who meets the SuperStream standard.
We may also disclose your personal information to others where:
(l) we are required or authorised by law to do so;
(m) you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
(n) we are otherwise permitted to disclose the information under the Privacy Act.
7. Do we disclose your personal information outside of Australia?
We may disclose personal information outside Australia in order to provide our products and services, and for administrative, IT, data storage or other business management purposes. We take steps reasonable in the circumstances to ensure that any overseas recipient handles your personal information in a way that provides comparable safeguards to those under the Privacy Act, unless you specifically consent to the overseas disclosure taking place without such steps being taken, or the disclosure is otherwise required or permitted by law.
Those overseas recipients may include our:
(a) related bodies corporate in the United Kingdom and New Zealand;
(b) funders and their related companies and service providers, including to such entities in Austria, Bermuda, Brazil, Bulgaria, Canada, China, Costa Rica, Denmark, Fiji, Finland, France, Germany, Hong Kong, India, Indonesia, Ireland, Israel, Japan, Luxembourg, Malaysia, Malta, Mexico, Mongolia, Netherlands, New Zealand, Philippines, Russia, Singapore, South Africa, South Korea, Spain, Switzerland, Taiwan, Thailand, United Arab Emirates, United Kingdom and United States of America; and
(c) service providers (other than our funders) in Belgium, Canada, Germany, Hong Kong, India, Malaysia, New Zealand, Philippines, Singapore, United Kingdom and United States of America.
8. How can you access and correct your personal information?
You may request access or correction of the personal information that we hold about you at any time by contacting us (see details below). Where we hold information that you are entitled to access, we will try to provide you with suitable means of accessing it (for example, by mailing or emailing it to you). There is no charge for requesting access to your personal information, but we may require you to meet our reasonable costs in providing you with access (such as administrative and other reasonable costs including photocopying costs or costs for time spent on collating large amounts of material).
There may be instances in which we are not required to give you access to your personal information. For example, we may need to decline access if granting access would interfere with the privacy of others or if it would result in a breach of confidentiality. If that happens, we will give you written reasons for any refusal.
To ensure that the personal information we collect and use is accurate, complete and up-to-date, you need to provide us with accurate, current and complete information as requested. If you believe or become aware that any of the personal information we hold about you is incorrect, incomplete or inaccurate (for example, if you have changed address or contact details), you should request us to amend it.
9. What is the process for complaining about a breach of privacy?
If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us. Our contact details are set out below.
We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.
If you remain unsatisfied with the way in which we have handled a privacy issue, you may approach an independent advisor or contact the Office of the Australian Information Commissioner (www.oaic.gov.au) for guidance on alternative course of action which may be available.
10. How we hold and protect your data
We take steps reasonable in the circumstances to prevent any misuse, interference or loss, unauthorised access, modification or disclosure to your personal data and to keep it secure. We store most information about you in computer systems and databases operated by either us or our external service providers. Some information about you is recorded in paper files that we store securely.
When you log into the secure section of our website we use a secure server. Any data you give us when you are logged into the secure section of our website is encrypted using a Secure Socket Layer (SSL) session. SSL is an industry standard and is one of the best ways to ensure Internet messages are not intercepted. You should be aware, however, that some older browsers cannot use SSL. If your browser does not support 128-bit encryption (or higher) you will not be able to log into or use our secure website services.
Our general email enquiry forms are not sent via an encrypted channel and for this reason we ask that you do not include confidential information or sensitive personal information when using them.
Security of communications over the internet cannot be guaranteed, and therefore we cannot provide absolute assurance that information will be secure at all times.
We will also take steps reasonable in the circumstances to destroy or de-identify personal information once we no longer require it for the purpose for which it was collected or for any secondary purpose permitted under the APPs.
We may work with third parties to research certain usage and activities on our website. No personal information about you is shared except to the extent it is required to be used by the third party for providing such research, and in the course of conducting this research we, and these third parties, may place a unique “cookie” on your browser.
If our website requires you to register or login to gain access to the website, cookies are used to assist in this process. Cookies are used as part of the registration process, and they are also used to store the username while the user is logged into the site and to track the number of times the user has tried to log in during a single visit.
The following types of cookies could be placed on your computer:
Social Media Cookies: These cookies are used to integrate our site with popular social media sites. Social Media cookies allows visitors to share content quickly and easily with their social networks. Log data may include information such as IP address, browser type, the referring web page, pages visited, cookies, and other interactions with the social sharing buttons or widgets.
Google Analytics Cookies: These cookies (__unam, __utma, __utmb, __utmc, __utmz) are used to measure website traffic and activity, and improve the user experience by providing us with anonymous, unique and repeat visitor performance data in aggregate format.
Marketing Automation Cookies: We use a 3rd party marketing automation provider, Marketo.com. Marketo tracking cookies (_mkto_trk) allow us to collect information about how you use our site after you have received an email from us. The cookies track data linked to your email address and include data such as how you arrived at the site, how often you’ve visited, and which pages you looked at.
12. Contact us
Telephone: 1300 138 235
Post: Privacy Officer
SG Fleet Australia Pty Limited,
Locked Bag 1003, Gordon NSW 2072
Last updated: December 2020