General
Customer privacy is important to us. We are committed to providing our customers
with quality services and products, and in doing so, we respect that personal information
gathered in this process must be kept confidential. We maintain strict guidelines
regarding access to and use of such information in compliance with the Australian
Privacy Principles 2014.
We will use customer information in the manner described in this policy.
In 2001, a new Federal privacy regime came into effect, regulating the way private
sector organizations deal with personal information. This framework is outlined
in the Privacy Act 1988, associated amendments and the thirteen Australian Privacy
Principles (as outlined in Schedule 1 of the Privacy Amendment (Enhancing Privacy
Protection) Act 2012).
We recognize the importance of personal information privacy and the requirements
of this legislation with respect to the collection, storage and handling of such
information.
This Policy outlines the information that we may collect, how we will collect it,
how it will be used and your consent. If you have any questions regarding this Policy,
please contact us directly.
The Information We Collect and Why
Wherever reasonable and practicable, we will only collect information about our
customers directly from our customers
However, we reserve the right to collect and submit information to third parties
where necessary for us to comply with State and Commonwealth legislation as provided
for by the Privacy Amendment (Enhancing Privacy Protection) Act 2012.
Typically, the information that we hold is in relation to:
- Customer contact details;
- Customer financial interests and where applicable,
financial position.
- The products and services we provide, or
have provided, to you.
However the nature of this information may change depending on the transaction between
the customer and The Lease Company Pty Ltd.
Generally speaking, we do not collect sensitive information about our clients (such
as race, criminal convictions, health or political beliefs) unless required to do
so by law.
We collect health information where we offer products with an insurance component
to our customers. We do not use or share that information for any purpose other
than the underwriting or administration of a customer's policy, claim or account,
or as otherwise disclosed to the customer when the information is collected.
We also collect personal information from people who submit applications or register
interest for employment with The Lease Company Pty Ltd.
The information collected regarding customers is held in secure and protected database
systems on the premises of The Lease Company Pty Ltd, available only to staff with the required
login details and passwords to access the system. Customers can also access this
information (insofar as it pertains to them personally) via the The Lease Company Pty Ltd
website, using their own unique customer login details.
How We Collect the Information?
Generally we collect customer information directly from the customer, however in
some cases information may be collected from third parties regarding the customer
Examples of third party data collection include (but are not limited to) credit
reports where applicable, transaction data from fuel companies (in relation to fuel
card use), client reports from toll-road providers and employment information as
necessary (for example, in relation to company car leases).
The The Lease Company Pty Ltd website requires that your web browser accepts cookies, which
are used to make logging-in possible, but these cookies are not used to collect,
store, and track or monitor any personal information. We also collect website statistics
(which includes pages accessed and search terms used) but this information is not
identifiable (i.e. we cannot tell who you are).
How We Use the Information?
Primarily, we collect this information from our customers in order to:
- Provide quality products or services
- Consider/assess applications made to us by
customers and answer enquiries
- Maintain customer contact details
- Fulfill our legal obligations under applicable
laws and rules such as Anti-Money Laundering and Counter-Terrorism Financing legislation
We may share your personal information, such as company name, address and vehicle
registration numbers, with other companies we deal with, such as vehicle suppliers
or fuel companies, to provide you with the services required. We keep this information
to a minimum and do not provide this information to them to use for marketing purposes
without consent.
The information collected by The Lease Company Pty Ltd, about our customers, may be used
for the purposes of general marketing activity about our products and services.
If The Lease Company Pty Ltd provides customers with marketing material, the customer will
be given the opportunity to communicate their desire to opt out of receiving future
marketing material. When signing a quote, schedule or application, customers consent
to the use of their information for the purpose of direct marketing by The Lease Company
Pty Ltd.
We may also use or disclose customer information for related purposes such as:
- Helping us to develop and identify related
products and services that may interest our customers
- Inform customers about products or services
- Maintaining customer relationships;
- Conducting internal market research or customer
satisfaction reports
- Performing internal administration and operations
including accounting, risk management, record keeping, archiving, systems development
and testing, credit scoring and staff training
- Complying with legislative and regulatory
requirements, including statutory and civil compliance (typically this relates to
infringement and toll notices but can involve other compliance issues)
- Preventing and investigating crime or fraud
to protect customer interests as well as the interests of The Lease Company Pty Ltd
- Developing, establishing and administering
alliances and other arrangements with other organizations in relation to the promotion,
administration and use of our respective products and services
- Managing our rights and obligations in relation
to external payment systems.
In the event that customer contact details are provided to a corporate partner for
the purposes of providing the customer with a loyalty gift, there may be a need
for the partner to contact the customer. If the customer does not wish this to happen,
they can contact The Lease Company Pty Ltd at any time and have their details removed from
any such partnership programs.
In the event that customer contact details are provided to a corporate partner for
the purposes of providing the customer with a loyalty gift, there may be a need
for the partner to contact the customer. If the customer does not wish this to happen,
they can contact The Lease Company Pty Ltd at any time and have their details removed from
any such partnership programs.
We only use and disclose personal information about customers for the purpose for
which it was disclosed to us or related purposes which would reasonably be expected
without customer permission.
The Lease Company Pty Ltd may contract out some of our functions and activities; for example,
we may provide names and addresses to a mailing house to enable us to distribute
information to you about your vehicle. In these situations, we prohibit third parties
from using your personal information except for the specific purpose for which we
supply it.
We do not use your tax file number (TFN), Medicare number or any other government
agency identifier as our customer identifier.
If at any time you provide The Lease Company Pty Ltd with the personal details of someone
else (eg a spouse), you must ensure that the person has read and understood this
privacy policy and separately consented to his or her personal information being
used and disclosed to us by you for the purposes detailed in this policy.
The Lease Company Pty Ltd will not sell personal information to other organizations to allow
them to market directly to our customers.
In the event that a customer defaults under any agreement with The Lease Company Pty Ltd,
personal information may be provided to third party debt-collecting agencies and/or
credit reporting agencies for the purpose of financial recovery and reimbursement,
and in compliance with reporting regulations.
The Lease Company Pty Ltd will not provide personal information about customers to overseas
recipients unless compelled to do so by law.
Laws and rules regarding the use of personal information may vary by jurisdiction.
The Lease Company Pty Ltd complies with applicable laws and rules in the relevant jurisdiction.
Accessing Your Information and Complaints
Customers can access the information The Lease Company Pty Ltd holds about them simply by
requesting to do so. Customers should contact The Lease Company Pty Ltd directly to make
such requests, and The Lease Company Pty Ltd reserves the right to charge a fee in relation
to the costs associated with recovering and allowing access to this information.
If the customer would like to update their personal information or make any corrections,
they can do this simply by contacting The Lease Company Pty Ltd at their convenience.
If a customer has a complaint regarding the use of their information under this
policy, they can lodge a written complaint with The Lease Company Pty Ltd by sending their
complaint either by post to Level 1, 646 Whitehorse road, Mitcham VIC 3132 or to
info@myfleet.lease. The complaint will be managed by a Director personally, and
a response will be given within 10 business days of receiving the complaint. If
the customer is not satisfied with the response or the outcome, the complaint can
be referred to our external dispute resolution provider, the Financial Ombudsman
Service.
Customer Consent
In the first instance, by asking The Lease Company Pty Ltd to assist with your leasing requirements
and/or other advice, customers consent to the collection and use of personal information
as provided for by this Policy. Additionally, when signing a quote, schedule or
application for any of the products and/or services provided by The Lease Company Pty Ltd,
customers give their consent to these activities.
Personal information is usually used or disclosed only after obtaining customer
consent. Consent can be:
Express consent can be either:
For example: when you sign a quote for a company car lease you are giving your express
consent for us to obtain a credit reference about you from a credit-reporting agency.
You imply consent when we can reasonably conclude that you have given consent by
conduct, or in the alternative, by a lack of conduct. For example, if you use a
telephone service and continue the call after hearing the recorded message telling
you that the call may be monitored or recorded for training purposes, you have given
your implied consent to monitor or record your call.
If customers do not consent to certain uses of personal information, The Lease Company Pty
Ltd may not be able to deal with that customer or provide them with a particular
product or service. Similarly, if a customer chooses to remain anonymous or use
a pseudonym it may be impracticable for The Lease Company Pty Ltd to deal with that customer
effectively.
Information Security
The Lease Company Pty Ltd takes reasonable steps to protect customer information from misuse
and loss resulting from unauthorized access, modification or disclosure. This involves:
- Non-Disclosure: we do not disclose your personal
information to other people or corporations in circumstances other than those described
in this Privacy Policy;
- Physical Security: we do not allow unauthorized
entry to our premises or information sources and storage areas;
- Computer System Security: we secure our computer
systems to prevent unauthorized access and modification to our files, databases
and networks; and
- Destruction: where information is no longer
needed it is safely destroyed or deidentified.
Compliance with Anti-Spam Legislation
The Lease Company Pty Ltd understands the inconvenience Spam (unsolicited commercial electronic
messages) can cause to a business, so we make sure we comply with the requirements
of the Spam Act 2003.
Messages are only sent to an address when an individual has consented to receive
it. Such consent is implied through the provision of the email address in question.
All communications via email are relevant and important. Where the communications
are of a general marketing nature, the customer will be provided with an option
to remove themselves from future communications of this nature.
Our messages are clearly identified as being sent from The Lease Company Pty Ltd (or Myfleet
as the trading name) and include our contact information and an easy, functional
way of un-subscribing.