Last updated 18 May 2023
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1. Our privacy commitment
2. What does the Privacy Policy do?
3. What information do we collect?
4. Do we collect sensitive personal information?
5. What information do we collect when you use our online services?
6. What information do we collect under our Hardship Policy?
7. How do we collect information?
8. How do we use your personal information?
9. Direct marketing and research
10. Who do we disclose your personal information to?
11. When do we de-identify information?
12. When do we disclose information overseas?
13. How do we secure your information?
14. How can you access and correct your information?
15. What information do we collect when you apply to work with us?
16. What information do we collect about you when you work for us?
17. Complaints and further information
18. Definitions
1.1 At Transurban we take privacy seriously and incorporate it into the ways that we work. We consider this Privacy Policy to be an important document that provides clear guidelines for you to understand how we manage personal information and the steps we take to protect your privacy.
1.2. This Transurban Privacy Policy (“Privacy Policy”) outlines the commitment of Transurban and its Subsidiaries (“Transurban” or “we”, “us” or “our”), including those operating under the brand, “Linkt” to protect the privacy of our customers’ personal information and other personal information we receive in the conduct of our business. Please note however, that this Privacy Policy is issued by Transurban in Australia for Transurban’s corporate website and complies with Australian law. For privacy policies applicable to operations in other countries where we operate, please refer to those country-specific privacy policies which are available here: US and Canada.
1.3. We comply with all relevant privacy laws where we operate, including the requirements applicable to us under the Privacy Act 1988 (Cth) ("Privacy Act") and relevant State laws.
2.1. The Privacy Policy describes the kinds of personal information we collect, how we look after the personal information we collect, why we collect it, and how we hold, use and disclose personal information.
2.2. By using our products or services or by providing personal information to us, you agree to the terms of the Privacy Policy.
2.3. We may need to change the Privacy Policy. If we do, we’ll post the updated version on our website at transurban.com/privacy and on each relevant retail brand website. The updated version will take effect from the date stated at the top of the Privacy Policy.
2.4. If the changes are significant, we will aim to provide a more prominent notice of the change and, where possible, send our customers a notification of the changes.
2.5. We encourage you to check our website from time to time to be aware of the current Privacy Policy and how it applies to you.
2.6. We also maintain a Credit Reporting Policy, which explains how we manage credit-related personal information. A copy of our Credit Reporting Policy is available on our website at transurban.com/crp and on each relevant retail brand website.
3.1 We collect information to provide products, services and information to our customers and to the community.
3.2 We also collect information where we are required to do so to comply with the law.
3.3 The types of personal information we collect depends on the circumstances in which the information is collected and the purpose it was collected for.
3.4 The main types of personal information we may collect include:
3.5 When you travel on our roads or on roads where we provide tolling or billing services, or if you have a customer account with us, we will collect information such as:
3.6 We may also collect information about the use of your vehicle or your travel arrangements, such as other roads that you use, driving and travel patterns, parking locations, fuel purchase information and use of public transport.
3.7 We may record and monitor telephone calls and other communications between you and us for training, quality control, verification and compliance purposes.
3.8 When you communicate with us, we may collect additional information including the languages you speak, your family and living circumstances, your property, how best to manage communications with you and information about your dealings with us.
3.9 If you participate in a survey or competition, or respond to a feedback request, we will collect the information that you provide in doing so and associated information such as when and how you submitted your response.
3.10 We may collect information about property ownership in relation to properties near our existing or proposed roads or above our existing or proposed tunnels and associated underground services.
3.11 We collect information about people who invest in Transurban stapled securities.
3.12 We collect information about people who are our contractors, suppliers and business partners, or who are employed by our contractors, suppliers and business partners. The information we collect focuses on information needed to conduct business with that individual or party.
3.13 When you do business with us, including if you have a corporate account with us, we may collect information about you from others, such as from referees or from others who do business with you.
3.14 We collect information about people who visit our sites and our offices. This may include videos of you when you are in or near our sites or offices. With your consent, we may also collect information relevant to whether you have been exposed to a known case of COVID-19 or your vaccination status to the extent that this is reasonably necessary in order to prevent or manage COVID-19 in the workplace.
4.1 We will only collect sensitive information about you with your consent and if the information is reasonably necessary for Transurban's functions or activities or if we are otherwise allowed or required by law to collect that information.
4.2 A list of information that could be considered sensitive information includes (but is not limited to) things such as information about your health, racial or ethnic origin, religious beliefs, membership of a professional or trade association, membership of a trade union, biometric information that is to be used for the purpose of automated biometric verification or biometric identification and criminal record.
5.1 This section applies to use of online services that we control, such as websites, apps, social media and other online services.
5.2 When using our online services, we and our technology partners may collect information about you and how you use our online services.
5.3 We may collect information such as:
5.4 Our online services may use cookies and other similar technology. Cookies are small pieces of data stored on the web browser of your device. These are used by us for site administration and analysis purposes as well as delivering tailored content to you. If you don't wish to take advantage of cookies, you may configure your browser not to accept them (although this may disable or render unusable some of the features of our online services).
5.5 Our online services may also detect and use your IP address or domain name for internal traffic monitoring and capacity management purposes or to otherwise administer the online services. The patterns of usage of visitors to the online services may be tracked for the purposes of providing improved service and content based on aggregate or statistical review of user traffic patterns.
5.6 Our online services may use third party services, like Google services (such as Google Analytics, Google Ads, Invisible reCAPTCHA and Google Maps). For example, if you allow our online services access to your device location, our Pay in Person Online Service may use Google Maps to collect your location and locate nearby stores. For more about how Google collects and processes data, please see Google's Privacy Policy, Google Terms of Service and their information on how Google uses your data.
5.7 From time to time, we may use third-party online services to collect personal information such as your name and email address or telephone number to administer online competitions, customer feedback and surveys.
5.8 Our online services may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. The privacy practices applicable to other websites may differ substantially from ours. Please read the privacy policy of any other websites you visit before using them.
6.1. We have a Hardship Policy. If our Hardship Policy applies to you, we may collect additional information from you and from third parties.
6.2. The additional information we collect may include information about your financial and personal circumstances or specialist support you may be receiving such as financial counselling, welfare assistance or hardship/relief aid.
6.3. We collect this additional information in order to determine the extent of your eligibility under our Hardship Policy and to appropriately implement it.
7.1 We collect your personal information in the following ways:
7.2 You must only provide us with personal information about someone else if that person consents to you doing so and to us collecting, holding, using and disclosing their personal information in accordance with this Privacy Policy.
7.3 If you choose not to provide certain personal information to us, we may not be able to fulfil your request or provide you with certain services or information relating to us.
8.1 We use and disclose your personal information:
8.2 Other Australian toll-road operators. We may exchange certain personal information with other Australian toll-road operators. For example, if you open an account with us, we may use and disclose your personal information for the purposes of facilitating your travel on our roads and any other Australian toll-roads with whom we have information sharing arrangements in place. Information sharing arrangements allow the operators of those roads to obtain payment for travel when you travel on their roads.
8.3 Road incidents. If your vehicle is involved in or in the vicinity of a road incident, we may disclose your personal information to emergency services, insurance providers and towing, roadside support and maintenance and logistics contractors. This information may include images and video footage of the incident and the vehicles involved, as well as the details of any vehicles and occupants. A road incident also includes property and road damage caused by your vehicle or a vehicle that you are in.
8.4 Required by law. We may disclose your personal information to the police and to other government law enforcement agencies where it is required by law or where we believe it is reasonably appropriate to do so. We may provide police with real time access to our systems, for example, to access and view footage from our cameras.
9.1 We may use and disclose your personal information to carry out consumer, market, community and traffic research, compile demographics and perform other analysis so that we can develop and implement initiatives to improve our services, improve the design, construction and operation of our roads and identify people likely to be affected by or interested in our roads and services.
9.2 We may use and disclose your personal information for marketing purposes. We may contact you about our products and services, the products and services of other Transurban retail brands, the products and services of other people, or related special offers from our rewards partners and/or business partners, that we think may be of interest to you. This information may be sent to you by email, SMS or by other means. You can opt-out or unsubscribe from receiving these types of promotional communications by:
9.3 Unsubscribing from promotional communications will not stop service-related communications from us, such as administrative alerts in relation to your account and notifications in relation to road closures
10.1 We may disclose your personal information:
10.2 In certain circumstances, you may nominate by way of statutory declaration a person who operated your vehicle on our toll road. If this occurs, we may contact that person and inform them of the details of your nomination.
10.3 Under the Corporations Act 2001 (Cth), we are required to make limited shareholder details available to members of the public on request.
11.1 We may de-identify information about an individual so that the information can no longer be related to that individual.
11.2 We may then use and disclose that de-identified information in the course of our business.
11.3 We may also aggregate information on the use of our services and roads (for instance, traffic information) in such a way that the information can no longer be related to the specific individuals.
11.4 We may then use and publicly disclose such aggregated information in the course of our business.
12.1 We may disclose information to recipients that are located in a different Australian State or Territory to you and to recipients located outside Australia. We may disclose personal information to contractors outside of Australia and may use off-shore servers for the purposes of data storage. We have engaged contractors in the Philippines, the United States, Portugal, France, India, Canada, New Zealand, South Africa, Sweden and certain other countries and may disclose certain personal information to those contractors.
12.2 We may also disclose certain personal information to our related entities in the United States and Canada, although such information will typically only relate to employees and internal corporate matters and not customer information or the operation of our roads in Australia.
12.3 We will take commercially reasonable steps so that any overseas recipient does not breach the Australian Privacy Principles (other than Australian Privacy Principle 1) in relation to the personal information.
13.1. We use reasonable safeguards and security measures to protect personal information we hold about you from risks such as misuse, interference, unauthorised access, modification or disclosure. We use a number of physical and electronic measures to protect your personal information as well as training our staff (and contractors) in best practice internal procedures and systems with respect to the handling of personal information. We also take steps to secure your information by vetting our third party providers.
13.2. However, the Internet is not a secure environment. Although due care is taken, we cannot guarantee the security of information provided to us via electronic means or stored electronically.
13.3. Personal information is only retained for as long as is necessary for any purpose for which it may be used or disclosed under the Privacy Act or as otherwise required by law.
14.1 You have a right to access the personal information that we hold about you. You may do so by contacting us.
14.2 We will not charge you a fee for your access request, but we may recover from you our reasonable costs of supplying you with access to this information.
14.3 When you request access to personal information, we may need to take measures to verify your identity before providing you with such information.
14.4 In some circumstances it may not be possible for us to provide you with all of your personal information, or an exception to access under the Privacy Act may apply. For example, we may not be able to give you access if it would unreasonably affect someone else's privacy. If we do not provide access to the personal information held about you, we will tell you why.
14.5 We will take reasonable steps to only hold personal information about you that is accurate, complete, up-to-date, relevant and not misleading.
14.6 If you think that any personal information we hold about you is inaccurate, you may contact us. We will take reasonable steps to make sure that the information is corrected.
14.7 We reserve the right to refuse to correct your personal information in some circumstances. If we refuse to correct any personal information about you, and we cannot reach a subsequent agreement, you may request that a note or statement regarding the correction request be attached to the file that contains your personal information.
15.1 When you apply to work with us, we may collect certain information from:
15.2 The information we collect will assist us to decide whether to make an offer to you to work with us.
15.3 In addition to the information set out above (see paragraph 3.4), the information we collect may include information about your:
15.4 As necessary and where appropriate, we may require you to carry out screening checks (such as background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
15.5 Some of the personal information we collect may be considered sensitive information under certain privacy regulations. For example, we may collect:
15.6 Subject to privacy regulations, we may sometimes collect sensitive information about you from a third party. If you think we have received your sensitive information in error, you may contact the Transurban Privacy Officer by email on privacy@transurban.com.
16.1 In addition to the information we may collect when you apply to work with us, we may collect information about your:
16.2 We collect this information to train and manage our employees and meet our legal obligations.
16.3 Some of the personal information we collect may be considered sensitive information under certain privacy laws. For example, we may collect:
16.4 Subject to privacy laws, we may sometimes collect sensitive information about you from a third party. If you think we have received your sensitive information in error, you may contact the Transurban Privacy Officer by email on privacy@transurban.com.
17.1 If you want to talk to us about your privacy please contact the Transurban Privacy Officer by email on privacy@transurban.com. We are happy to discuss how we handle your personal information, how your personal information is collected or about any other aspect of our Privacy Policy.
17.2 If you are concerned about the way we deal with personal information, please contact us in writing at:
Transurban - Attention: Privacy Officer
Locked Bag 28
South Melbourne VIC 3206.
Please:
17.3 We will aim to respond as soon as we can. If you are not satisfied with our response, you may also contact the relevant regulator such as the Australian Information Commissioner or the Tolling Customer Ombudsman. As at the date of this Privacy Policy, the contact details are as follows:
Tolling Customer Ombudsman QLD Phone: 1800 145 009 | Office of the Australian Information Commissioner |
Do you need further information?
17.4 For further information about our Privacy Policy or practices, please visit our website at transurban.com or linkt.com.au.
17.5 Alternatively, you can contact the Transurban Privacy Officer by email on privacy@transurban.com.
17.6 You can also contact the Linkt team.
18.1 This Privacy Policy applies to, and a reference to “we”, “our” or “us” means, the following entities to the extent they collect, use and disclose personal information in or from Australia:
18.2 Subsidiary means, in respect of a company, trust or other entity, a subsidiary of that entity within the meaning of the Corporations Act 2001 (Cth) or an entity which is, for the purposes of section 50AA of the Corporations Act 2001 (Cth), under the “control” of that entity.
18.3 We are proud to operate the LINKT retail brand.
18.4 For privacy policies applicable to operations in other countries where we operate, please refer to those country-specific privacy policies which are available here: US and here Canada.