OLA Privacy Policy for Australia

Transcription

1 1. Respecting yur privacy OLA Privacy Plicy fr Australia OLA Australia Pty Limited and its related bdies crprate (including its Indian parent cmpany, ANI Technlgies Private Limited) (the OLA Grup) is cmmitted t cmpliance with privacy laws which apply t its businesses and which set ut standards fr the management f persnal infrmatin, including the Privacy Act 1998 (Cth) and the Australian Privacy Principles (APPs). This plicy utlines ur persnal infrmatin management practices fr all aspects f ur business in Australia including frm ur relatinships with custmers, drivers, peratrs, users f ur services and thers wh may cntact us r abut whm we may be prvided with persnal infrmatin. Specifically, this plicy utlines: the kinds f persnal infrmatin we cllect and hld; hw we cllect and hld it; the purpses fr which we cllect, hld, use and disclse it; yur right t access and seek crrectin f it; hw yu may cmplain abut privacy matters; and ur sharing f yur persnal infrmatin utside Australia. There are sme matters t which this plicy des nt apply. These are referred t belw (see clause 11 belw). 2. What kinds f persnal infrmatin d we cllect and hld? The persnal infrmatin we cllect and hld is what is reasnably necessary fr ur business functins and activities. When we cllect and hld persnal infrmatin, it is f the fllwing kinds: yur persnal details such as yur name (including accunt username), addresses (including addresses and website addresses), telephne numbers, accunt lgin details and passwrds, age and gender, and certain persnal details f yur emergency cntacts; the reference number yu prvide r which we allcate t yu when engaged in services which we prvide r services prcured r bked using ur services; what, hw, when and where yu have engaged in services which we prvide r services prcured r bked using ur services; details abut yur stated r likely preferences and yur experiences with services which we prvide r services prcured r bked using ur services; details abut yur membership in any lyalty prgrams; whether yu have a cnnectin with thers whse persnal infrmatin we may cllect r hld, fr example family members; if yu use scial media r a mbile device t interact with us, any infrmatin that yu allw the scial media site r device t share with us; and depending n the nature f yur dealings with us r the services which we prvide t yu r which yu may btain r make available t thers using ur services, ther types f persnal infrmatin. Examples are: where yu are invlved in prviding transprt-related services, identificatin, taxatin, gvernment r regulatry identifier (such as drivers licence details), and vehicle and insurance details; persnal infrmatin relating t any cmplaints yu make r are made abut yu, including recrding f any calls in that regard; persnal infrmatin cllected and held via financial r payment systems abut the payment mechanism r methd that yu might use (including credit card details) and the payments yu may make fr ur services r any services prcured r bked using ur services; and 1

2 persnal infrmatin which is accessible frm yur use f nline sites r applicatins in which we have an interest r prvide (such as messages fr the purpses f issuing and receiving ne time passwrds and ther device verificatin) and device-related r device-generated persnal infrmatin. The latter might include yur device details, device IDs, yur lcatin, netwrk cnnectins, netwrk access and cmmunicatin and sessin data. Sme f ur services require us t cllect sensitive infrmatin, fr example health-related infrmatin r infrmatin which may be cntained in images yu make available t us, which may be apprpriate if yu are invlved in the prvisin r prcurement f transprt services using ur services, r t assist us in relatin t any liability issues invlving yu. This infrmatin is nly used t prvide yu with thse services r t manage such issues and ther directly related activities and purpses. Yu cnsent t ur cllectin f this sensitive infrmatin and ur use and disclsure f such sensitive infrmatin fr the purpses cntemplated by this privacy plicy. Yu generally have the ptin f nt identifying yurself r f using a pseudnym when dealing with us. But nt where this is impractical (fr example when yu transact nline with us r yu apply t prvide transprtrelated services) r where the law r a curt rder prvides therwise. 3. Hw d we cllect and hld persnal infrmatin? When we cllect persnal infrmatin abut yu, we d s by making a recrd f it. We d this when: yu register with us, fr example when yu create an accunt fr any f ur prducts and services; yu cmmunicate with us nline; yu take part in ur prmtins, cmpetitins, testimnials, surveys and fcus grups; and yu deal with us in ther ways invlving a need fr persnal infrmatin t be prvided such as when yu cntact ne f ur call centres, fill in a frm, lg int ur website r applicatin r make a cmplaint. We may recrd all calls and s cllect any persnal infrmatin prvided during such calls. We may als cllect persnal infrmatin abut yu by accessing data frm ther surces and then analysing that data tgether with the infrmatin we already hld abut yu in rder t learn mre abut yur likely preferences and interests. When yu visit ur electrnic sites, such as websites r applicatins, we may als cllect infrmatin abut yu using technlgy which is nt apparent t yu, fr example using ckies and ther similar technlgies. There is a lt f infrmatin available abut hw ckies wrk and hw t change yur brwser s ckie preferences. Fr example, see Mst f the persnal infrmatin we cllect and hld abut yu is frm yur direct dealings with us, fr example infrmatin yu tell us r infrmatin we learn directly frm yur dealing with us r ur partners, e.g. thrugh ckies. We may smetimes cllect yur persnal infrmatin ther than frm yu directly. Fr example, frm ther suppliers wh, in cmmn with us, have a relatinship with yu r have infrmatin abut yu; frm thse t whm we have given access t ur nline sites (such as thrugh applicatin prgramming interfaces); frm thse we regard as ur business partners, ur ther custmers r ur driver partners; frm publicly available infrmatin and frm third party ratings and feedback. Our cntractrs and service prviders wh perfrm services fr us, such as payment prcessing, fraud management, marketing, data analytics and identity verificatin and backgrund checks may als prvide us infrmatin abut yu. Persnal infrmatin we hld is generally stred in servers and ther cmputer systems. These may be perated by us r by ur service prviders. In all cases, we have rigrus infrmatin security requirements aimed at minimising risks f unauthrised access t, and lss, misuse r wrngful alteratin f, persnal infrmatin. 4. Why d we cllect, hld, use and disclse persnal infrmatin? When we cllect, hld, use and disclse yur persnal infrmatin, we d s primarily in cnnectin with the prvisin, sale and prmtin f gds and services which we prvide r are prvided r prcured using ur services and t imprve n and enhance the range f thse services and fferings. Fr example, we cllect, hld, use and disclse yur persnal infrmatin: 2

3 in cnnectin with transprt-related services by: prviding custmer s and driver s persnal infrmatin (including current lcatin, phtgraph, ratings and vehicle infrmatin) t each ther in cnnectin with the arrangement f specific transprt-related services and t facilitate cmmunicatins between drivers and custmers; and using yur lcatin data t recrd and verify trip and payment infrmatin if yu prvide r prcure transprt-related services using ur services r are lgged nt ur website r applicatin; t prcess and facilitate yur payment fr gds and services, including as required by law; fr direct marketing (see clause 5 belw); fr verificatin f yur identity; t develp insights abut yu r t persnalise yur fferings r experience in using ur services r services f ur third party business partners, including drivers; fr research and develpment r t imprve gds and services, fr example in cnnectin with safety and security and preventing fraud; where yu are invlved in prviding transprt-related services, fr criminal histry and backgrund checks (including verificatin f health infrmatin) and ther manual prcessing checks regarding the verificatin f drivers and vehicles; t assist in dispute reslutin, investigating cmplaints and in enquiries and supprt; fr incidental r ther purpses related t the prvisin f gds and services t yu r the purpses referred t abve. Fr example, we may disclse yur persnal infrmatin within the OLA Grup fr OLA Grup s internal peratinal purpses (including t help us prvide ur gds and services, and mnitr and imprve ur gds and services), t service prviders wh assist us in ur day-t-day business peratins and as part f buying r selling businesses; and as required r permitted by law, curt rder and any gvernment, law enfrcement r ther regulatry bdy. We may cllect, hld, use and disclse yur persnal infrmatin fr ther purpses which are within reasnable expectatins (these may relate, fr example t acting n yur requests; ur invlvement in relatinships between custmers, drivers and third party suppliers f gds r services t yu) r legal reasns (fr example where permitted by law). We may annymise, de-identify r aggregate yur persnal infrmatin. Fr example, we may d this fr the purpses f cnducting analytics, fr example the use and disclsure f annymised data t determine preferences and patterns and fr business imprvement. We may share this annymised, de-identified r aggregated data with ur trusted partners t assist them in cnducting analytics and marketing f prducts and services t yu that are likely t be relevant t yur interests and preferences. It is nt practicable t utline the details f all third parties t whm yur persnal infrmatin is disclsed, hwever, in additin t thse cntemplated abve, we may disclse yur persnal infrmatin t: members f the OLA Grup, which may include, fr example, disclsure t and use f infrmatin by ANI Technlgies Private Ltd (registered and lcated in India) fr the purpses f infrmatin and identificatin verificatin; ur service prviders and their cntractrs and parties wh we regard as business partners f us r the OLA Grup, including payment prcessrs, fraud and security prviders, thse prviding technlgy services and supprt, lyalty schemes and services, cntact centre services, analytics r business services, marketing, prmtins and advertising services, financial services, insurance services r prfessinal r legal services; yur family members r emergency cntacts in the event f an incident r emergency; cmply with ur and the OLA Grup s legal, cmpliance, regulatry and peratinal purpses; and third parties t whm yu ffer t prvide gds r services r frm whm yu prcure gds r services (including any preliminary requests r cmmunicatins regarding such gds and services) 3

4 using ur services, fr example this wuld include sharing infrmatin between drivers and custmers f transprt-related services arranged r facilitated using ur services. 5. Direct marketing We may als cllect, use and disclse yur persnal infrmatin t supply, advertise and prmte gds and services which may be f interest t yu, including thrugh , SMS, pst, phne and als targeted and nline marketing and advertising. This includes the prducts and services f ur suppliers and ther third parties wh ffer prducts and services that may be f interest t yu. We may disclse yur persnal infrmatin t these third parties and their and ur marketing, prmtins and advertising service prviders fr this purpse and yu cnsent t receiving these types f direct marketing and cmmercial electrnic messages. Yu may pt ut f ur direct marketing t yu (and ur direct marketing materials will tell yu hw t d this). 6. Hw can yu enquire abut, access and crrect yur persnal infrmatin? We will prvide yu with access t any f yur persnal infrmatin we hld (except in limited circumstances permitted by law). If yu wish t access yur persnal infrmatin r have an enquiry abut yur privacy, please cntact us at care.australia@lacabs.cm. Yu can address yur queries t the City Manager. Befre we prvide yu with access t yur persnal infrmatin we may require sme prf f identity. We may charge a reasnable fee fr giving access t yur persnal infrmatin if yur request requires substantial effrt n ur part. If yu need t crrect yur persnal infrmatin, please cntact us using ne f the abve means f cntact. 7. Hw can yu cmplain abut ur management f persnal infrmatin? If yu wish t cmplain abut a breach f the privacy rules that bind us, yu may cntact us using ne f the means f cntact specified in clause 6 abve. We may ask yu t put yur cmplaint in writing and t prvide details abut it. We may discuss yur cmplaint with ur persnnel and ur service prviders and thers as apprpriate. We will investigate the matter and attempt t reslve it in a timely way. We will infrm yu in writing abut the utcme f the investigatin. If we d nt reslve yur cmplaint t yur satisfactin and n ther cmplaint reslutin prcedures are agreed r required by law, we will infrm yu that yur cmplaint may be referred t the Office f the Australian Infrmatin Cmmissiner fr further investigatin and will prvide yu with the Office f the Australian Infrmatin Cmmissiner s cntact details. 8. Security The security f yur persnal infrmatin is imprtant t us. We take reasnable steps t prevent the persnal infrmatin we hld abut yu frm misuse, interference r lss, and frm unauthrised access, mdificatin r disclsure. This includes the use f technlgies and prcesses such as access cntrl prcedures, netwrk firewalls, encryptin and physical security t prtect the privacy f yur persnal infrmatin. Hwever, t the maximum extent permitted by law, we exclude and limit ur liability t yu in respect f any breach f security r misuse, interference r lss, and frm unauthrised access, mdificatin r disclsure f yur persnal infrmatin. 9. Our disclsure f yur persnal infrmatin verseas It is ur plicy t require all f ur verseas use r disclsure f persnal infrmatin t be dne in a way which requires bservance f privacy and security standards, bth during transit and at rest at any verseas strage lcatin. We may allw yur persnal infrmatin t be used r disclsed t ur persnnel, OLA Grup cmpanies and third party service prviders wh are in cuntries utside f Australia. We d this: where we have made a business decisin t stre r prcess data with a trusted service prvider (and their cntractrs) r business partner. Examples are thse wh stre and prcess ur and mbile applicatin data, prvide payment prcessing services r cntact centre services, r cnduct verificatin activities. These services cmmnly invlve diverse gegraphic lcatins which change frm time t time fr reasns which include data prtectin and prcessing efficiency. Where these 4

5 services are used by us, it is nt practical fr us t ntify yu f which cuntry yur persnal infrmatin may be lcated in (hwever nte that it includes, withut limitatin, Singapre, the Philippines, Indnesia, the United States f America and India); fr disclsures between OLA Grup cmpanies wh prvide varius supprt services t us (including, withut limitatin, legal, tax, finance, HR and IT supprt including dcument verificatin supprt). Our main business lcatin is in Bangalre, India, but sme f the OLA Grup cmpanies may be based in ther cuntries frm time t time; when ur business which cllected yur persnal infrmatin is in a different cuntry t yur lcatin, fr example where yu are registered fr ur service Australia, but use ur service in a different cuntry; and where yu are invlved with liability r ther issues cncerning gds r services which we prvide r are prvided r prcured using ur services. In such cases we may disclse yur persnal infrmatin t any verseas supplier f such gds r services in the curse f managing thse issues. Where we disclse any f yur persnal infrmatin utside f Australia t any third party (including an OLA Grup cmpany), we take reasnable steps t ensure that such third party prtects yur persnal infrmatin and cmplies with ur privacy bligatins under the APPs. 10. Updates This privacy plicy is current at the date belw. We may change it peridically. If we prpse t change this plicy, we will infrm yu f the change via ur main nline site r such ther means as appears t us apprpriate in the circumstances 11. Other privacy terms and limits f this plicy This is a plicy. There may be additinal privacy ntices and terms relevant t yu depending n the nature f yur dealings with us and n ur particular businesses. In particular, there are additinal privacy terms in ur terms cncerning ur nline sites and applicatins and accunt registratin prcesses. We have separate charters cncerning ur emplyees this plicy des nt apply t the persnal infrmatin f ur emplyees in their capacity as such. This plicy als des nt apply t infrmatin which may be cllected frm an individual by a driver f a cab which is nt prvided by us. This plicy des nt include that f any third parties whse prmtins we may facilitate r whse nline lcatins may be accessible via links frm ur nline lcatins. 12. Mre infrmatin Mre infrmatin abut privacy law and privacy principles is available frm the Privacy Cmmissiner. The Privacy Cmmissiner may be cntacted at (r by at enquiries@aic.gv.au). 5