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.
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:
However, the nature of this information may change depending on the transaction between the customer and RewardLab.
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 RewardLab.
The information collected regarding customers is held in secure and protected database systems on the premises of RewardLab, 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 RewardLab website, using their own unique customer login details.
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 novated leases).
The RewardLab 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).
Primarily, we collect this information from our customers in order to:
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 RewardLab, about our customers, may be used for the purposes of general marketing activity about our products and services. If RewardLab 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 RewardLab.
We may also use or disclose customer information for related purposes such as:
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 RewardLab 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 RewardLab 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.
RewardLab 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 RewardLab 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.
RewardLab 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 RewardLab, 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.
RewardLab 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. RewardLab complies with applicable laws and rules in the relevant jurisdiction.
Customers can access the information RewardLab holds about them simply by requesting to do so. Customers should contact RewardLab directly to make such requests, and RewardLab 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 RewardLab 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 RewardLab by sending their complaint to hello@rewardlab.com.au. 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.
In the first instance, by asking RewardLab 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 RewardLab, 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 novated 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, RewardLab 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 RewardLab to deal with that customer effectively.
RewardLab takes reasonable steps to protect customer information from misuse and loss resulting from unauthorised access, modification or disclosure. This involves:
RewardLab 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 RewardLab and include our contact information and an easy, functional way of un-subscribing.
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