Transurban Privacy Policy

Last updated 2 September 2024 | Print as PDF

1. Our privacy commitment

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.
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.
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. What does the Privacy Policy do?

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.
By using our products or services or by providing personal information to us, you agree to the terms of the Privacy Policy.
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.
If the changes are significant, we will aim to provide a more prominent notice of the change and, where practical, send our customers a notification of the changes.
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.
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. What information do we collect?

We collect information to provide products, services and information to our customers and to the community.
We also collect information where we are required to do so to comply with the law.
The types of personal information we collect depends on the circumstances in which the information is collected and the purpose it was collected for.
The main types of personal information we may collect include:
1. your name and contact details
2. identification details (such as date of birth)
3. your organisation and position, where your organisation has a business account or business dealing with us
4. information on your use of our products and services, including use of our roads, our websites, our apps and our tags, and
5. records of our communications and dealings with you, such as telephone, email, SMS, webchat and other online and in-person communications.
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:
1. your licence plate number
2. your vehicle make, model, year, colour, registration, owner, Vehicle Identification Number (VIN) and in some instances, acquisition date
3. your trip details
4. photos and videos of vehicles, which may include occupants in vehicles or people on the roadside
5. tolls and fees charged, paid, not paid and owed
6. your account balance
7. your tag details
8. your billing details
9. your payment methods, such as credit card and bank details
10. a 'deceased date' of a non-arranged traveller (under specific agreements held with government authorities), and
11. information to determine or verify if you are entitled to a discount, rebate or concession, and to implement or assist with the implementation of such discount, rebate or concession.
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.
We may record and monitor telephone calls and other communications between you and us for training, quality control, verification and compliance purposes.
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.
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.
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.
We collect information about people who invest in Transurban stapled securities.
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.
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.
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.
As part of our roadside technology development efforts, we may collect video recordings which inadvertently and incidentally capture images of pedestrians, Licence Plate Numbers, vehicles and vehicle occupants. None of this incidentally collected information is used for the purpose of identifying any individual.

4. Do we collect sensitive personal information?

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.
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. What information do we collect when you use our online services?

This section applies to use of online services that we control, such as websites, apps, social media and other online services.
When using our online services, we and our technology partners may collect information about you and how you use our online services.
We may collect information such as:
1. user name and password
2. which services you use and how you use them
3. device information, such as the model and ID of the device you use, your operating system, telephone number and mobile phone network
4. server log information, such as details of how you used the service, your IP address, hardware settings, browser type, browser language, the date and time of your use and referral URL
5. cookies that may uniquely identify your browser or your account (please see clause 5.4 below), and
6. location information.
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).
Our online services may 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.
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.
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.
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. What information do we collect under our Hardship Policy?

We have a Hardship Policy. If our Hardship Policy applies to you, we may collect additional information from you and from third parties about you.
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.
We collect this additional information in order to determine the extent of your eligibility under our Hardship Policy and to appropriately implement it.

7. How do we collect information?

We collect your personal information in the following ways:
1. You give it to us. We collect information when you or your representatives provide us with information. For example, this might happen when you're setting up an account with us or where we ask you to provide certain personal information including where you participate in a trial or survey.
2. When you use our products or services. For example, when you use our roads, we collect information about your road use. We collect information through technological means, including:
  1. automatic incident detection systems (including traffic management and safety cameras)
  2. vehicle registration detection systems
  3. electronic toll collection systems (such as a tag attached to an individual's vehicle)
  4. tolling cameras and CCTV, and
  5. apps and websites, including where you have agreed to disclose information about your location while using one of our websites or apps.
  Please see section 5 above for information we collect when you use our online services.
3. When you visit our work locations, sites or offices. For example, we may video people on or near our sites, accessing our work areas or in our offices
4. From third parties. We may obtain information from outside sources such as generally available publications, information available online or through social media platforms and providers. This may also include collecting information from:
  1. other people associated with your toll account, such as your employer, family members or people jointly on the account
  2. other people such as referees or others who do business with you, if you have a corporate account with us
  3. government road and traffic authorities
  4. service providers to government authorities (such as companies that provide traffic camera services to police)
  5. other Australian toll-road operators
  6. researchers
  7. other companies where you have consented to them providing your information to us (such as payment channel providers, rewards partners and rental car agencies), and
  8. suppliers of information products and services (such as companies that consolidate data from multiple public sources).
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.
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. How do we use your personal information?

We use and disclose your personal information:
1. to provide products, services and information to our customers and to the community
2. for the purposes for which it was collected
3. in order to improve our products and services
4. in order to operate and improve our roads, and to undertake administrative or operational activities associated with designing, constructing, managing and operating our roads
5. in order to make special offers or to undertake promotions related to our products or services, including from our retail brands, business partners or government road or traffic authorities, that we think may be of interest to you
6. to our rewards partners and rental car agencies where you have consented to that use and disclosure
7. in order to conduct surveys
8. to maintain our relationship with you
9. to verify your identity and personal information
10. to maintain and update our records
11. to calculate and recover tolls and fees
12. for debt collection and enforcement purposes
13. to consider your eligibility for assistance under our Hardship Policy or a related assistance program, and to administer such policies and programs
14. to investigate or to pursue any legal claim that we may have against you
15. for road safety purposes
16. for security purposes
17. to assist the enforcement of laws
18. to undertake traffic planning and vehicle management services
19. to meet our obligations and perform our functions under applicable laws and agreements
20. to detect, prevent and investigate any fraud or crime (or suspected fraud or crime)
21. to notify you of changes to our tolls, fees, charges, agreements, products or services, and
22. as otherwise required or authorised by law.
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.
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.
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. Direct marketing and research

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 Transurban retail brands, the products and services of other people or companies, 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:

following the 'unsubscribe' link in the communication
changing your account settings, or
contacting us here.

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. Who do we disclose your personal information to?

We may disclose your personal information:
1. subject to any restrictions imposed by any relevant legislation or contract, among the Transurban entities named in this Privacy Policy, their related entities (including related entities located in the United States and Canada) and their retail brands
2. under information sharing arrangements with the operators of other Australian toll roads
3. to government agencies, such as government agencies responsible for the operation of roads, vehicle registration, transport or emergency services
4. to any entity responsible for the collection of tolls or the taking of enforcement action concerning use of our roads
5. to anyone who acquires or considers acquiring our assets or business (or any part of it)
6. where you have consented to that disclosure, for example to a secondary contact nominated on your account or to one of our rewards partners
7. as required or permitted by law, for example, in response to a subpoena, warrant, or request from a government law enforcement agency, or as required under legislation and regulations applying to our roads
8. to the Tolling Customer Ombudsman
9. to insurance companies
10. to our consultants, contractors, subcontractors, suppliers, service providers, professional advisers and agents, such as:
  1. call centre operators
  2. mailhouse, printhouse and warehouse organisations
  3. marketing, advertising and information service providers including social media services and data supply companies
  4. legal and accounting firms
  5. welfare and hardship assistance providers in accordance with our hardship policy
  6. contractors that own or operate distribution outlets (such as convenience stores and electronic kiosks)
  7. banks, financial institutions and payment processing providers
  8. towing, roadside support and maintenance and logistics contractors (such as if you or your vehicle are involved in or near a road incident)
  9. engineers and surveyors
  10. researchers and investigators
  11. insurers
  12. share registry providers
  13. debt collection companies and credit reporting bodies (for more information) refer to our Credit Reporting Policy at transurban.com/crp and Statement of Notifiable Matters here
  14. Australia Post and delivery supply contractors,
  15. rental car agencies
  16. information technology suppliers that provide support, maintenance and upgrade services for our systems, and
11. to contractors, subcontractors, suppliers and service providers engaged by our commercial partners, where such disclosure is for the purpose of providing or improving our products and services.
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.
Under the Corporations Act 2001 (Cth), we are required to make limited shareholder details available to members of the public on request.

11. When do we de-identify information?

We may de-identify information about an individual so that the information can no longer be related to that individual.
We may then use and disclose that de-identified information in the course of our business.
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.
We may then use and publicly disclose such aggregated information in the course of our business.

12. When do we disclose information overseas?

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.
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 include customer information or individual road user information.
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 that personal information.

13. How do we secure your information?

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.
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.
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. How can you access and correct your information?

You have a right to access the personal information that we hold about you. You may do so by contacting the Transurban Privacy Officer by email on privacy@transurban.com or in writing to the address specified in section 17.2 of this policy.
We will not charge you a fee for your access request, but we may recover from you our reasonable costs of supplying you with this information.
When you request access to personal information, we may need to take measures to verify your identity before providing you with such information.
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.
We will take reasonable steps to only hold personal information about you that is accurate, complete, up-to-date, relevant and not misleading.
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.
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. What information do we collect when you apply to work with us?

When you apply to work with us, we may collect certain information from:
1. you
2. recruitment consultants
3. your previous employers
4. your referees, and
5. other sources of relevant information, such as educational institutions, professional and trade associations, referees and publicly available sources.
The information we collect will assist us to decide whether to make an offer to you to work with us.
In addition to the information set out above (see paragraph 3.4), the information we collect may include information about your:
1. work history
2. education and other qualifications or licences
3. character, and
4. eligibility to work.
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).
Some of the personal information we collect may be considered sensitive information under certain privacy regulations. For example, we may collect:
1. health information (such as medical checks on job applicants, if the information is reasonably necessary for Transurban's functions or activities)
2. criminal information (such as police checks on job applicants)
3. union memberships and affiliations (such as membership information about your industry union).
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 or in writing to the address specified in section 17.2 of this policy.

16. What information do we collect about you when you work for us?

In addition to the information we may collect when you apply to work with us, we may collect information about your:
1. training
2. employee benefits
3. banking details
4. emergency contacts
5. employment performance
6. conduct
7. use of Transurban's facilities, IT (including software applications) and communications resources
8. leave
9. Superannuation, and
10. tax.
We collect this information to train and manage our employees and meet our legal obligations.
Some of the personal information we collect may be considered sensitive information under certain privacy laws. For example, we may collect:
1. health information (such as in connection with road incidents, impact of construction work, sick leave or medical checks on job applicants and employees, if the information is reasonably necessary for Transurban's functions or activities)
2. criminal information (such as police checks on job applicants and employees)
3. union memberships and affiliations (such as membership information about your industry union)
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. Complaints and further information

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.
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:
1. include a method for us to contact you
2. clearly describe your concerns.
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 via their complaint form on their website. As at the date of this Privacy Policy, the contact details are as follows:

Tolling Customer Ombudsman
VIC and NSW
PO Box 7095
Hawthorn North VIC 3122

QLD
PO Box 2615
Mansfield QLD 4122

Phone: 1800 145 009
Email: admin@tollingombudsman.com.au
Website: tollingombudsman.com.au

Office of the Australian Information Commissioner
GPO Box 5218
Sydney NSW 2001

Enquiries Line: 1300 363 992

Lodging a Complaint: https://www.oaic.gov.au/privacy/privacy-complaints

Do you need further information?

For further information about our Privacy Policy or practices, please visit our website at transurban.com or linkt.com.au.
Alternatively, you can contact the Transurban Privacy Officer by email on privacy@transurban.com.
You can also contact the Linkt team.

18. Definitions

In this Policy any reference to 'Transurban', 'we', ‘us’ or 'our' is a reference to the Transurban Group.
We are proud to operate the Linkt retail brand.
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.