1. What is personal information?
Personal information is information about an identifiable individual.
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 and vehicle leasing 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, details of your employees if you are a business, 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 may 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;
(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 electric charging data and purposes of travel;
(i)health information where you consent to the collection of such information and if relevant to the provision of services (e.g. to assist your employer to comply with its occupational health and safety obligations in connection with your use of a vehicle);
(k)personal references; and
(l)information we need where you are applying for employment with us, including references, driving history and criminal record checks.
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 (including leasing and fleet management) to you, including performing all necessary administrative tasks;
(e)improve our products and services;
(f)manage overdue payments and enforce our rights (including undertaking debt collection) in connection with any credit provided to you;
(g)perform internal processes including product development, risk management, pricing an audit;
(h)conduct credit scoring, securitisation, research, risk management and portfolio analysis;
(i)search and register interests under the Personal Property Securities Act 1999;
(j)market to you products and services provided by us and our related bodies corporate, dealers, insurers or suppliers;
(k)where applicable, facilitate appropriate insurance cover and assessing, processing and investigating insurance risks and/or claims relating to you;
(l)perform and maintain accounting, billing, record keeping, systems development testing, staff training processes and for other internal administrative purposes;
(m)assess your application for employment with us or otherwise for the purposes of engaging you as a contractor or consultant; and
(n)comply with relevant laws, including Anti-Money Laundering and Countering Financing of Terrorism Act 2009, rules and other subordinate instruments, Tax Administration Act 1994, and, where applicable, Credit Contracts and Consumer Finance Act 2003.
Sometimes you may voluntarily disclose, or we may be required to collect, use, store and disclose sensitive information for specific purposes.
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.
If, at any time, you provide us with the personal details of someone else (for example, but not limited to, your spouse or your employee), you must ensure that the person has read and understood this policy and separately consented to their personal information being disclosed to us by you, and held and used by us, for the purposes detailed in this policy.
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; or
(c)when we speak on the phone.
We may also collect information from third parties including:
(d)our related bodies corporate, business partners, assignees or potential assignees;
(e)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;
(f)our banks, financial advisors, funders and related service providers that assist in the processing of your application and the management of your credit;
(g)suppliers of any goods or services financed with credit we provide;
(h)trustee (including security trustees), managers, 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;
(i)your referees, past and present employers, past and present landlords, next of kin;
(j)any person acting on your behalf (eg. financial advisors, solicitor, broker, accountant, executor, administrator, trustee or guardian);
(k)any guarantor or proposed guarantor of your application for credit;
(l)third party service providers including fuel suppliers, insurance providers, maintenance providers, accident management or roadside assistance suppliers;
(m)persons with whom we have white label arrangements (eg. to sell our product under another brand and their related bodies corporate);
(n)rating agencies, valuers and debt collection agencies;
(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, and their advisers for the purpose of the funding, refinancing, sale or securitisation, associated due diligence and review of the products and related services provided to you;
(d)service providers, such as website hosting providers, IT system administrators and digital transaction management providers;
(e)trustees (including security trustees), managers, servicers, receivers, credit enhancers, or other third parties, and their advisers, in connection with any funding, refinancing, sale or securitisation;
(f)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;
(g)any party acting on your behalf (e.g. financial advisers, lawyers, or accountants);
(h)your employer or your guarantor;
(i)suppliers of purchased goods or other persons who have or require an interest in the purchased goods;
(j)organisations to whom we outsource functions, including professional advisers and collection and mercantile agents;
(k)potential purchasers as part of the sale or transfer of any of our assets or business; and
(l)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.
We may also disclose your personal information to others where:
(m)we are required or authorised by law to do so;
(n)you may have expressly consented to the disclosure or the consent may be reasonably inferred from the circumstances; or
(o)we are otherwise permitted to disclose the information under the Privacy Act.
Where we disclose or transfer your personal information to third parties in connection with one of the purposes set out in this policy, including if we have assigned or transferred, or are considering assigning or transferring, any of our rights or obligations under any facility, product, or service we provide to you or to which you are a party as a customer, guarantor or otherwise, a reference to “we” or “us” in this policy includes any such organisation.
7. Do we disclose your personal information outside of New Zealand?
We may disclose personal information outside New Zealand in order to provide our products and services, and for administrative, IT, data storage or other business management or funding (including securitisation) 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.
Those overseas recipients may include our:
(a)related bodies corporate in Australia and the United Kingdom;
(b)funders and their related companies and service providers; and
(c)service providers (other than our funders).
You may have rights to enforce the overseas recipient’s compliance with applicable data protection laws.
8. How can you access and correct your personal information?
You may request access to, 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 New Zealand Office of the Privacy Commissioner (privacy.org.nz) for guidance on any 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 websites we use a secure server. Any data you transferred when you are logged into the secure section of our websites 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.
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 law.
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 websites require 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
If you have any questions about this policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please contact us by:
Last updated: September 2021