Privacy

INTRODUCTION

Welcome to Splend’s Privacy Policy. At Splend, we want you to know that we have your best interests at heart and in this Privacy Policy we give you information on how we collect and process your personal information when you use our website or mobile applications, take part in any of our competitions, sign-up as a customer with us, apply for a job with us or are a service provider to us.

As protecting your personal information is really important to Splend, we may provide you with additional data privacy notices or information that is specific to your situation – and if we do, you need to read that additional information alongside this Privacy Policy (which is our key document and will always apply).

Splend, as an organisation, is made up of different legal entities and together all of these entities form a group.

This Privacy Policy is kept under regular review and was last updated in August 2024.

WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU AND HOW?

Personal information, is 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. Examples include an individual’s name, address, contact number and email address.

Different kinds of personal information

In general, we collect different kinds of personal information and we’ve grouped them together below for you:

• ·Contact Information includes billing address, delivery address, email address and telephone numbers.

• identity Information includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

• Financial Information includes bank account and payment card details.

• Technical Information includes internet protocol address, your login data, browser type and version,  time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Where you are a customer with us, it also includes data on your driving and the locations that you have travelled to with our vehicle (as our vehicles are installed with devices that track this data).

• Profile Information includes your username and password, agreements signed with you (such as our subscriptions, Flexi and Flexi own agreements), your interests, preferences, feedback and survey responses.

• Transaction Information includes details about payments from you and other details of products and services you have registered for with us.

• Usage Data includes information about how you use our website and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal information but is not considered personal information in law as this information will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal information so that it can directly or indirectly identify you, we treat the combined data as personal information which will be used in accordance with this Privacy Policy.

We do not generally collect sensitive information, and we will only collect sensitive information about you with your consent (unless we are otherwise required or authorised by or under law to do so).

Our relationship with you

The personal information that we collect from you depends on our relationship with you. Below we’ve made a chart which explains the personal information that we collect and  how we collect this data).

We may also collect personal information about you from third parties who refer you to us or who you direct to provide your personal information to us. For example, we might collect information about you from other sources, such as:

• third parties introducing you to us and other third parties like ride share platforms, recruiters or referees; or

• third parties through targeted marketing. Such third parties may include google ads and meta ads

We recommend you routinely review the privacy notices and preference settings of such information sharing platforms.

The purposes for which we collect, hold, use and disclose personal information

The primary purpose for which we collect personal information about you is to enable us to perform our business activities and provide our services to you.

We collect, hold, use and disclose personal information for a range of purposes including to:

• provide our services to you in accordance with our terms and conditions;

• respond to your enquiries about our services;

• for our administrative purposes and internal record keeping;

• provide you with customer service or technical support and deal with any complaints or feedback you have;

• perform research and analysis and improve or develop our products or services;

• manage our relationships with our customers, suppliers, and our contracted service providers;

• consider job applications for current and future employment;

• conduct marketing and promotional activities;

• manage our insurance and risks; and

• comply with our legal and regulatory obligations.

We may use and disclose your personal information for other purposes required or authorised by or under law (including purposes for which you have provided your consent).

If we are unable to collect personal information from or about you, we may not be able to respond to your requests or enquiries and facilitate any requests you make to use our services.

Do we disclose your personal information to others and if so, who?

We may share your personal information with the parties set out below for the purposes set out in the table above.

External third-parties such as:

• Potential and existing customer tracking and engagement providers – for us to be able to track our engagement with potential and existing customers as well as be able to communicate with them through different methods (such as online chat, text and telephone).

• On-demand driving apps – for us to help potential customers when they need assistance in submitting their application to for these apps.

• Organisations that liaise with local regulatory driving bodies – for us to check the identity and driving history, including any demerit points received or previous at-fault accidents.

• Telematics device and software providers – for us to be able to monitor engine data, driving behaviour and vehicle location.

• Payment service providers – for us to process any payments made by our customers to us.

• Insurers and claims processors – for us to deal with any accidents or vehicle issues that our customers face.

• Vehicle servicing, maintenance and repair organisations – for us to ensure that the vehicles that our customers are driving are roadworthy.

• Candidate tracking, assessment and background screening organisations – for us to manage and evaluate candidates that are applying for vacancies with us and to confirm their details and credentials.

• Technology companies that provide us with desktop and cloud-based products – for us to conduct our business and back-up data (which may include your personal information) whilst you are reviewing our website, applying to be our customer, applying for a vacancy with us or acting as one of our suppliers.

• Professional advisers such as law firms, banks, and accountancy firms – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal information).

• Regulators and other governmental authorities – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal information).

• Uber – if you’re not already an approved Uber Driver Partner, with your permission, we will enter your details into Uber’s system to help you sign up for ridesharing.

• Third-parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them.

Is your data ever transferred outside of Australia?

We currently do not share your personal information with overseas third parties or recipients.

Data security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, contractors and other third-parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We also have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Notice.

Third-Party Links

Our websites and applications may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites and applications, we encourage you to read the privacy documentation of every website you visit.

Marketing

Where you have consented to us doing so, or where we have a legitimate interest in communicating with you (and you have not previously unsubscribed from marketing communications), we will use your email address to send you updates on any new products or services we are offering. You can always opt out of receiving these emails by following the instructions in each email to unsubscribe.

We will get your express opt-in consent before we share your personal information for marketing purposes.

Please also note that if you contact us via our website and specifically complete our “enquire now” form for our services, we will contact you and arrange to discuss our services with you. We will not send you marketing communications unless we have obtained your express opt-in consent or if you do subsequently purchase our services and do not opt out of receiving our marketing communications.

We recommend that you routinely review the privacy notices, terms and conditions and preference settings that are available to you. You can ask us to stop sending you marketing messages at any time by contacting us at privacy@splend.com and withdrawing your consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g. as we may be required to contact you about a payment due).

Access to and correction of your personal information

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your relationship with us.

You have a right to request access to personal information that we hold about you and request its correction if it is inaccurate, out of date, incomplete, irrelevant or misleading.

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request where we have a valid reason.

We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Complaints

Please contact us using our complaints form if you have any concerns or complaints about the manner in which we have collected or handled your personal information. We will inquire into your complaint and respond within 30 days. If you are not satisfied with our response, you can contact us to discuss your concerns or lodge a complaint with the Office of the Australian Information Commissioner by visiting www.oaic.gov.au, calling 1300 363 992 or by emailing enquiries@oaic.gov.au.

Contact details

If you would like more information about the way we manage personal information, would like to request access to or correction of personal information that we hold about you, or wish to make a complaint, please contact us at: privacy@splend.com.

Changes to this policy

We may update this Privacy Policy from time to time to reflect the changes in our practices or for legal reasons. The updated version will be posted on our website with the effective date. Please check this page periodically for any changes.