1. About this Privacy Policy 🔗

1.1 TrailerMates recognises the importance of protecting your personal information. This Privacy Policy explains what personal information we collect, how we collect it, why we hold it, who we disclose it to, how long we keep it, and how you can access it, correct it or complain about how we have handled it.

1.2 We handle personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth).

1.3 This Privacy Policy should be read together with the Privacy Collection Statement at Annexure A of our Rental Terms and Conditions, which is a short summary of the same subject matter. Where this Privacy Policy and that summary differ, this Privacy Policy applies.

1.4 This Privacy Policy forms part of the Rental Contract under clause 1.1(c) of our Rental Terms and Conditions.

2. Who we are 🔗

2.1 TrailerMates is operated by TrailerMates Pty Ltd ACN 703 890 288 ABN 13 703 890 288. In this Privacy Policy, "TrailerMates", "we", "us" and "our" refer to TrailerMates Pty Ltd.

2.2 We operate a self-serve trailer hire business from 14 Collins St, Slacks Creek QLD 4127, and through our website at www.trailermates.com.au and our online booking system.

2.3 Terms that are capitalised in this Privacy Policy and defined in our Rental Terms and Conditions, such as Trailer, Booking, Hirer, Authorised Driver, Rental Period and Issue Report, have the same meaning here.

3. What personal information we collect 🔗

3.1 Information you give us when you book or hire 🔗

When you make a Booking, hire a Trailer, contact us, or are nominated as an Authorised Driver, we may collect:

1. your full name, residential and postal address, email address and telephone number;
2. your date of birth;
3. your driver licence number, class, expiry, State or Territory of issue, and any conditions or restrictions recorded on it;
4. details of the vehicle you will use to tow the Trailer, including its registration number;
5. your Booking history, Rental Periods, Trailer selection, extensions, amendments and cancellations;
6. payment and billing information;
7. company name, position and employee details where a Booking is made for or by a business; and
8. any other information you choose to give us in connection with a Booking or an enquiry.

3.2 Identity verification, including biometric information 🔗

Identity verification is a condition of releasing a Trailer to you. Depending on the method used, we or our identity verification provider may collect:

1. images of the front and back of your current Australian driver licence;
2. a live photograph of your face, taken at the time of verification;
3. the outcome of an automated comparison between that facial image and the photograph on your licence, and any liveness, document authenticity or risk indicators returned;
4. the name, date of birth and document details read from your licence; and
5. the date, time, number of attempts and provider reference for each verification.

A facial image used for automated biometric comparison is biometric information, and is sensitive information under the Privacy Act 1988 (Cth). We collect and use it only with your consent, given under clause 2.3B(e) of our Rental Terms and Conditions, and only for the purposes set out in section 5 of this Privacy Policy. We do not use it for any other purpose, and we do not use it to identify you in any other context.

3.3 Condition reports, photographs and Issue Reports 🔗

Our hire process requires photographic records at collection and return. We collect:

1. photographs you take and submit through the Pickup Inspection Form, the Return Condition Form and any Issue Report;
2. photographs and video we take of a Trailer before, between and after hires;
3. the declarations and answers you give in those forms; and
4. the date, time and, where your device provides it, the location at which a photograph was taken.

Photographs taken in and around a Trailer may incidentally capture people, vehicles, registration plates, addresses and property belonging to you or to others. Where that occurs, that material is personal information and is handled under this Privacy Policy.

3.4 Trailer tracking and telematics 🔗

Every Trailer is fitted with a tracking device. Our Rental Terms and Conditions require your consent to this at clause 15, and clause 4.3(c) records that we may rely on tracking data to establish a breach of the area of operation limits. Through those devices we collect:

1. the current and historical location of the Trailer;
2. movement, journey and stop history;
3. speed, distance travelled and duration of use;
4. battery, power and device status; and
5. tamper, disconnection and unauthorised movement alerts.

This information relates to the Trailer, but because it can be linked to you as the Hirer for a Rental Period, it is personal information within the meaning of the Privacy Act 1988 (Cth).

3.5 Smart lock and access records 🔗

Trailers are released using a TrailerMates smart lock and a single-use or time-limited Access Code. We collect records of when an Access Code was issued, to whom it was issued, when it was used, and any failed or out-of-window attempts to use it.

3.6 CCTV at our premises 🔗

Closed circuit television operates at 14 Collins St, Slacks Creek. Cameras are directed at the Trailers and the collection and return area. Signage is displayed at the site. We collect video images of people and vehicles attending the site. We do not record audio.

3.7 Communications with us 🔗

We collect the content and metadata of communications between you and us, including emails, SMS messages, messages submitted through forms on our website, and notes of telephone calls. Some telephone calls may be recorded.

3.8 Website, analytics and advertising 🔗

When you visit our website we collect technical and usage information including your IP address, device and browser type, pages viewed, time spent, referring website, search terms, and interactions with our booking widget. We use cookies and similar technologies for this. Section 16 explains this in more detail and how to control it.

3.9 Information from other sources 🔗

We may also collect personal information about you from:

1. a person who makes a Booking on your behalf, or whom you nominate as an Authorised Driver;
2. our booking platform, payment provider and identity verification provider;
3. driver licensing and vehicle registration authorities;
4. councils, toll operators and infringement processing bodies;
5. insurers, repairers, tow and recovery operators and other persons involved in an incident;
6. police and other law enforcement or government agencies;
7. credit reporting bodies, where we are permitted to obtain a report; and
8. publicly available sources, where we are investigating a suspected fraud, a non-return, or an unpaid debt.

3.10 Information about other people 🔗

If you give us personal information about another person, including an Authorised Driver or a person collecting a Trailer on your behalf, you must first have their consent or authority to do so for the purposes set out in this Privacy Policy, and you must tell them where they can find it.

4. How we collect personal information 🔗

4.1 We collect personal information directly from you wherever it is reasonable and practicable to do so. That includes when you make a Booking, complete identity verification, complete a Pickup Inspection Form or Return Condition Form, submit an Issue Report, contact us, or attend our premises.

4.2 We also collect personal information automatically through the systems used to operate a contactless hire, including the booking system, the payment system, the identity verification process, the smart lock, the tracking device fitted to the Trailer, our CCTV, and our website.

4.3 If we are unable to collect the personal information we ask for, we may be unable to accept your Booking, unable to release a Trailer to you, or unable to provide some or all of our services.

5. Why we collect, hold, use and disclose personal information 🔗

5.1 We collect, hold, use and disclose personal information for the following purposes:

1. to assess and accept a Booking, and to provide the hire services you have requested;
2. to verify your identity and your eligibility to hire and tow a Trailer, and to confirm that the person collecting the Trailer is the person entitled to collect it;
3. to issue and control Access Codes and to release Trailers;
4. to take and process payments, deposits, pre-authorisations, refunds and chargebacks;
5. to communicate with you about your Booking, your Rental Period, returns, faults and safety matters;
6. to establish the condition of a Trailer before and after a hire, and to assess whether Damage has occurred and who is responsible for it;
7. to locate, secure and recover a Trailer that is overdue, taken outside the permitted area of operation, reported stolen, or otherwise not returned;
8. to detect, investigate and prevent fraud, theft, unlawful activity and breaches of our Rental Terms and Conditions;
9. to process traffic infringements, tolls and similar charges, including identifying the person responsible for them;
10. to recover amounts owed to us, including through debt collection agencies, the Queensland Civil and Administrative Tribunal, or a court;
11. to establish, exercise or defend legal rights and claims, and to comply with the rules and directions of a tribunal or court;
12. to maintain the security of our premises, our Trailers and our systems;
13. to meet our obligations under Australian law, including taxation, road transport and consumer law obligations;
14. to manage, review and improve our services, systems and safety practices; and
15. to send you marketing communications, subject to section 9.

5.2 We will not use or disclose your personal information for a purpose other than one set out above, or a purpose directly related to it that you would reasonably expect, unless you consent or we are required or authorised by law to do so.

5.3 Biometric information collected under clause 2.3B is used only for the purposes in paragraphs 5.1(b), 5.1(h) and 5.1(k). It is not used for marketing, is not used to identify you outside the verification of a Booking, and is not disclosed except as set out in section 6.

6. Who we disclose personal information to 🔗

6.1 We may disclose your personal information to:

1. our booking platform provider, which operates the online booking system, the customer booking dashboard and the checkout process;
2. our payment provider, which processes payments, refunds, pre-authorisations and chargebacks;
3. our identity verification provider, which performs document checks and automated facial comparison;
4. our smart lock provider, which operates the lock hardware and Access Code system;
5. our telematics and tracking provider, which supplies and hosts the tracking devices and the platform we view their data through;
6. our hosting, cloud storage, database, authentication, email delivery, SMS delivery, website, domain and content delivery providers;
7. our analytics and advertising providers;
8. repairers, tow and recovery operators, salvage operators, storage providers and trailer manufacturers, in connection with damage assessment, repair or recovery;
9. insurers, loss assessors and other parties involved in an incident or claim;
10. debt collection agencies, and any person to whom a debt owed to us is assigned or sold;
11. our legal advisers, and the Queensland Civil and Administrative Tribunal or a court, in connection with a claim;
12. credit reporting bodies, to the extent permitted by the Privacy Act 1988 (Cth);
13. councils, toll operators, transport authorities and other bodies responsible for processing infringements or tolls;
14. driver licensing and vehicle registration authorities;
15. police, regulators and other government agencies, where disclosure is required or authorised by law, or where we reasonably believe it is necessary to report or investigate a crime; and
16. a purchaser or prospective purchaser of our business, or a franchisee or partner operating under the TrailerMates brand, in which case the recipient is required to handle your personal information consistently with this Privacy Policy.

6.2 We do not sell your personal information.

6.3 Where we disclose personal information to a service provider, we do so only for the purposes described in section 5, and we require them to protect it and to use it only for those purposes.

7. Overseas disclosure 🔗

7.1 Some of the providers we use store or process personal information outside Australia. Based on our current systems, personal information may be disclosed to recipients in the United States of America, Singapore, the Netherlands, Ireland and other countries in which our providers or their sub-processors operate data centres.

7.2 Our evidence storage, which holds condition report photographs, Issue Reports and related records, is hosted in Australia in the Sydney region.

7.3 Before disclosing personal information to an overseas recipient, we take steps that are reasonable in the circumstances to ensure the recipient does not breach the Australian Privacy Principles, including by contracting with providers that publish binding privacy commitments and, where offered, selecting Australian hosting.

7.4 If you would like to know which country a particular category of your information is held in, contact us using the details in section 19 and we will tell you.

8. Sensitive information 🔗

8.1 Sensitive information is a category of personal information that attracts additional protection under the Privacy Act 1988 (Cth). It includes biometric information and biometric templates.

8.2 The only sensitive information we collect in the ordinary course is the facial image used for automated identity verification, described in section 3.2.

8.3 We collect that information only with your consent. You may decline. If you decline, we will be unable to verify your identity by that method, and unless we are able to verify it another way we will be unable to release a Trailer to you and your Booking will be cancelled in accordance with clause 7.4A of our Rental Terms and Conditions.

8.4 We do not collect information about your health, racial or ethnic origin, political opinions or affiliations, religious beliefs, philosophical beliefs, membership of a professional or trade association or trade union, sexual orientation or practices, or criminal record, and you should not provide that information to us.

9. Direct marketing 🔗

9.1 We may use your contact details to tell you about our services, offers, changes to our fleet, and products and services offered by other businesses operated by the same principals as TrailerMates, currently including Dako Gear.

9.2 We will not use sensitive information for direct marketing.

9.3 Every marketing email and SMS we send contains a way to opt out. You can also opt out at any time by contacting us using the details in section 19. We will action your request within a reasonable time and at no cost to you.

9.4 Opting out of marketing does not stop us sending you messages we need to send to operate your hire, such as booking confirmations, Access Codes, return reminders, fault notices, invoices and notices about a claim.

10. Payment default and debt recovery 🔗

10.1 If you default in the payment of any amount owed to us, we may:

1. obtain a credit report about you where we are permitted to do so;
2. engage a debt collection agency to recover the debt;
3. assign or sell the debt to a debt collection agency or other third party, who may then, as owner of the debt, report your default to a credit reporting body where they are entitled to do so; and
4. recover the debt through the Queensland Civil and Administrative Tribunal or a court, where an unpaid judgment debt may become a matter of public record and may be reflected in your credit file.

10.2 Any reporting of a payment default to a credit reporting body will be carried out only by a party entitled to do so under the Privacy Act 1988 (Cth), and only in respect of defaults that meet the requirements of that Act.

11. How long we keep personal information 🔗

11.1 We keep personal information only for as long as we need it for the purposes set out in section 5, or for as long as we are required to keep it by law, and then we destroy it or de-identify it.

11.2 The licence images and facial photograph collected for identity verification are deleted twelve months after collection, except where they are relevant to an actual or anticipated dispute, claim, investigation or proceeding, in which case they are retained until that matter is finally resolved and any applicable appeal or limitation period has expired. This is the retention rule stated in clause 2.3B(e) of our Rental Terms and Conditions.

11.3 After those images are deleted, we retain a record that verification occurred, the outcome, the name and document details compared, the provider reference, the date and time, and a cryptographic hash of each deleted image. That record contains no biometric information.

11.4 Condition report photographs, Issue Reports and the associated evidence records are retained for the period in which a claim arising from the hire could still be brought or defended, which in Queensland is generally six years, and for any longer period during which a matter remains on foot.

11.5 Booking, financial and taxation records are retained for at least five years as required by Australian taxation law, and generally for six years.

11.6 CCTV footage is retained on a rolling basis and is overwritten automatically as storage fills, unless it is exported and preserved because it is relevant to an incident, a claim, an insurance matter or a police investigation.

11.7 Tracking and telematics data is retained for the period our telematics provider retains it, and any part of it that is relevant to a claim, an infringement or a recovery is exported and retained with the records for that matter.

11.8 Records held for the purpose of a legal claim are retained until the claim is finally resolved and any appeal or limitation period has expired.

12. How we keep personal information secure 🔗

12.1 We take steps that are reasonable in the circumstances to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. Those steps include:

1. holding evidence records in encrypted cloud storage located in Australia, with integrity protection that prevents records being altered after they are written;
2. restricting access to our operational systems to authenticated accounts, and limiting access within those systems to what each account needs;
3. using reputable third party providers for payments and identity verification, so that full card numbers and identity documents are handled by specialist providers rather than stored on our own general systems;
4. securing our physical premises and restricting access to devices holding personal information; and
5. destroying or de-identifying personal information when it is no longer needed, in accordance with section 11.

12.2 No method of transmission or storage is completely secure. While we take the steps described above, we cannot guarantee the security of information transmitted to us over the internet.

13. Data breaches 🔗

13.1 If we become aware of unauthorised access to, unauthorised disclosure of, or loss of personal information we hold, we will assess it promptly.

13.2 Where the breach is likely to result in serious harm to any individual whose information is involved, we will notify the affected individuals and the Office of the Australian Information Commissioner in accordance with the Notifiable Data Breaches scheme.

13.3 We treat any breach involving identity documents or biometric information as presumptively serious, and will notify unless we are satisfied on reasonable grounds that serious harm is not likely.

14. Accessing and correcting your personal information 🔗

14.1 You may ask us for access to the personal information we hold about you, and you may ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading.

14.2 To make a request, contact us using the details in section 19. We may ask you to verify your identity before we act on the request, so that we do not disclose your information to someone else.

14.3 We will respond within a reasonable time and, in most cases, within thirty days. We do not charge for making a request. We may charge a reasonable cost of providing access where a request requires substantial work, and we will tell you before we do.

14.4 We may refuse access or correction where the Privacy Act 1988 (Cth) permits us to do so. That includes where giving access would have an unreasonable impact on the privacy of others, where the information relates to existing or anticipated legal proceedings between us and would not be accessible in the discovery process, or where giving access would be likely to prejudice the investigation of unlawful activity or a suspected fraud. If we refuse, we will tell you why in writing and how to complain.

14.5 If we correct information we have already disclosed to someone else, you may ask us to tell them about the correction, and we will do so unless it is impracticable or unlawful.

14.6 If we refuse to correct information, you may ask us to attach a statement to it noting that you consider it inaccurate, and we will take reasonable steps to do so.

15. Complaints 🔗

15.1 If you believe we have mishandled your personal information or breached the Australian Privacy Principles, contact us using the details in section 19. Describe what happened and what outcome you are seeking.

15.2 We will acknowledge your complaint promptly, investigate it, and give you a written response, ordinarily within thirty days.

15.3 If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

Website: www.oaic.gov.au
Telephone: 1300 363 992
Post: GPO Box 5218, Sydney NSW 2001

16. Cookies, analytics and advertising 🔗

16.1 Our website uses cookies and similar technologies to make the site work, to understand how it is used, to measure the performance of our advertising, and to show you our advertising on other platforms.

16.2 These technologies are provided by third parties including analytics, advertising and session recording providers, and our content delivery and security provider. Those providers may set their own cookies and may combine what they collect on our site with information they already hold about you.

16.3 You can control cookies through your browser settings, and you can opt out of personalised advertising through the settings offered by the relevant advertising platform. Blocking cookies may stop parts of our website or booking system working properly.

16.4 Our booking system is operated by a third party provider and is subject to that provider's own privacy practices in addition to this Privacy Policy.

16.5 Our website may link to other websites. We are not responsible for the privacy practices of those websites, and you should read their privacy policies before providing information to them.

17. Children 🔗

17.1 Our services are not offered to children. Our Rental Terms and Conditions set a minimum age for Hirers and Authorised Drivers.

17.2 We do not knowingly collect personal information from a person under eighteen. If you believe we hold personal information about a person under eighteen, contact us and we will take reasonable steps to delete it, unless we are required to retain it by law or for a legal claim.

18. Changes to this Privacy Policy 🔗

18.1 We may update this Privacy Policy from time to time. The current version is published at www.trailermates.com.au/privacy-policy and is identified by the version number at the top of this document.

18.2 An updated Privacy Policy takes effect when it is published, except that a change which materially reduces the protection given to personal information we already hold about you will not be applied to that information without your consent or unless we are required or authorised by law.

18.3 We keep superseded versions so that the version in force at the time of a particular Booking can be identified.

19. How to contact us 🔗

Privacy Officer
TrailerMates Pty Ltd
14 Collins St
Slacks Creek QLD 4127

Email: support@trailermates.com.au
Telephone: 0420 399 277
Website: www.trailermates.com.au

TrailerMates Pty Ltd ACN 703 890 288 ABN 13 703 890 288