PRIVACY POLICY

1. About this Privacy Policy

1.1 Legion Cabs has formulated this Privacy Policy to outline the types of Personal Information we may collect or retain, how we collect, store, utilize, and disclose that Personal Information, your options regarding our use of that Personal Information, and your rights to access or rectify that Personal Information. For any queries regarding this Privacy Policy, please contact our Privacy Officer through the means specified in section 15.

1.2 We are affiliated with other companies and entities within the A2B Australia Limited Group (related entities). This Privacy Policy pertains to the gathering and utilization of your Personal Information by us and by those related entities. This Privacy Policy may also be applicable under the brands of those related entities. Any mention of "us" in this Privacy Policy also refers to those related entities.

2. Personal Information

2.1 "Personal Information" denotes information or an opinion, regardless of accuracy, recorded in any format or not, about an identified individual or an individual who is reasonably identifiable.

3. What Personal Information do we collect and retain?

3.1 The categories of Personal Information we may collect about an individual will vary based on our interactions with them. Personal Information that we may collect includes (but is not limited to) the following:

(a) name

(b) age and/or date of birth

(d) current and previous addresses (including postal addresses)

(e) email addresses

(f) gender

(g) identification information such as driving license details, including driving license number

(h) certification information such as taxi registration number, taxi plate number, and taxi operator certification details

(i) trip details (including start and end locations, and fare) collected by our products such as payment terminals

(j) payment details, such as your credit card, debit card, or bank account details

(k) Medicare details including individual reference number

(l) occupation and employment details including employment status and any previous work experience

(m) information from or in connection with your resume or job application if you apply for a position with us

(n) emergency contact details

(o) geographical location

(p) Australian Business Number (ABN)

(q) credit history

(r) trade references, credit references, or reports from a third party

(s) credit information

(t) criminal record as well as other disciplinary actions and history

(u) passport and visa details

(v) photographs and/or images of you from camera footage, and

(w) information from social media accounts and profiles.

3.2 We collect and record Personal Information about individuals such as:

(a) our customers, potential customers, and their representatives

(b) our investors and shareholders

(d) contractors and subcontractors and potential contractors and subcontractors and their representatives in relation to providing goods and services to us

(e) drivers and operators of vehicles, in relation to information about the trips taken when logged into our products such as dispatch equipment and payment terminals

(f) other individuals who may use our products and services (for example, individuals who have digital passes provided to them by their employer or someone they know)

(g) our employees past and present, including applicants, and

(h) any other person who comes into contact with Legion Cabs.

3.3 We are authorized to collect tax file numbers (TFNs) as per the Income Tax Assessment Act 1936 (Cth). Providing your TFN for our products and services is optional, however, if not provided, taxation law may necessitate additional deductions from payable amounts.

4. How and when do we collect Personal Information?

4.1 We collect your Personal Information to facilitate our business and organizational functions, to provide, market, and sell our products and services, and for the specified purposes outlined in section 6. In some instances, the collection of Personal Information may be mandated by law.

4.2 Personal Information may be collected during the provision of goods or services, or:

(a) when making a booking (online, through our mobile application, or by contacting our customer service center)

(b) when utilizing or purchasing our products or services, including for the purpose of receiving products or services under an order (e.g., digital payment products)

(d) when providing us, or offering or applying to supply us, with goods or services

(e) when providing information to us in any manner (including completing a form, disclosing information over the phone, via email, fax, or post, or providing a business card)

(f) when driving a vehicle and logged into one of our payment terminals, we receive information about the trips taken (including fare details)

(g) when requesting information about us, our products, or our services

(h) when providing feedback to us

(i) when visiting or completing a form on our Website (refer to section 5)

(j) when registering for or using an account or subscription package on our Website or through our mobile applications, including for the purposes of enabling us to contact you regarding your account

(k) when visiting premises from which we operate

(l) when you (or your employer) provide information to us in the course of conducting or administering our relationship with you, or when engaging in activities related to our business operations

(m) when applying to set up an account with us (including a commercial credit account, Cabcharge Plus corporate account, Taxi operator account, or Taxi driver account)

(n) when seeking to establish an agreement with us (e.g., plate owner management agreement, vehicle lease, short-term loan, and insurance loan)

(o) where required for the purposes of assessing, approving, or onboarding merchant partners, or

(p) when submitting a job application to us

(q) when making a lost property request, for processing purposes

(r) when contacting us by telephone, fax, email, social media, post, or in person

(s) where otherwise required or authorized by law.

4.3 Generally, when providing our products and services, engaging with our personnel, or obtaining goods and services from our service providers, suppliers, or contractors, we collect Personal Information directly from the relevant individual where reasonable and practicable.

4.4 Personal Information may also be obtained from third parties and other sources such as:

(a) your nominated representatives (e.g., spouse, accountant, power of attorney, brokers, and other professional advisors)

(b) our share registry service provider

(c) third parties purchasing our products and services for you, such as when a customer purchases a Cabcharge eTicket for your use or when your employer has an account with us and purchases a Cabcharge eTicket for your use

(d) if you are a taxi driver, from your taxi operator

(e) publicly available sources of information

(f) related entities, companies, and businesses of Legion Cabs

(g) regulatory bodies, if required

(h) government departments and information providers, such as the Department of Immigration and Citizenship (Vevo check) and Service NSW (Driving records)

(i) other commercial credit providers, or

(j) credit reporting bodies providing information about commercial creditworthiness,

though we will generally only collect your Personal Information in this manner if it is unreasonable or impracticable to collect directly from you or if otherwise permitted by law.

4.5 If the Personal Information collected includes sensitive information, including health information, we will seek your consent unless law permits collection without it.

4.6 In instances where we engage with you multiple times within a short period concerning the same matter, we may not provide a separate notice about privacy each time.

4.7 Some cases mandate the collection of Personal Information under relevant state and federal legislation, such as:

(a) when entering into credit arrangements;

(b) to verify the identity of taxi drivers under relevant state personal transport regulations; and

4.8 If you opt not to provide your Personal Information for the purposes outlined in this Privacy Policy, or if we cannot collect the necessary Personal Information, we may be unable to provide you with all or part of the requested information, products, or services, or effectively manage our relationship with you. Taxi drivers or operators failing to provide required Personal Information may not receive their payments.

5. Information collected via our Website and applications

5.1 Personal information may be collected by us and by our third-party service providers assisting us in operating our applications or websites including, but not limited to, those located at: www.legioncabs.com.au

5.2 We may utilize various technological methods periodically to track the visiting patterns of individuals accessing our Website or using our applications, including methods as outlined in this section 5.

Google Analytics

5.3 We employ Google Analytics to analyze how our Website is utilized. Google Analytics generates statistical and other information about website usage via cookies, stored on users’ computers. Information generated is used to create reports about Website use. Google stores this data. We will not use Google Analytics to track or collect any personally identifiable information of Website visitors. We will not associate any data gathered from our Website with any Personal Information from any source as part of our use of Google Analytics.

5.4 To opt-out of having your Website visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For installation and uninstallation details, visit the Google Analytics opt-out page.

Click Stream Data

5.5 When accessing information from our Website, we or our internet service provider may collect data such as the date, time, and duration of a visit, pages accessed, IP address of your computer, and any downloaded information. This data is utilized for statistical, reporting, and website administration, maintenance, and improvement purposes.

5.6 Our Website may use ‘cookies’ to monitor web traffic, enhance content and services, and gather information about pages visited and software utilized. Cookies are small text files transferred to a user’s computer hard drive by a website for storing information about a user’s identity, browser type, or website visiting patterns.

5.7 If you access our Website or click through to it from a link in an email we send you, a cookie may be downloaded onto your computer’s hard drive.

5.8 Cookies may also serve other purposes on our Website.

5.9 You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is sent. Each browser differs, so consult the “Help” menu of your browser to learn how to modify your cookie preferences.

5.10 Disabling the use of cookies on your web browser or removing/rejecting specific cookies from our Website or linked sites may restrict access to some content and facilities on those websites.

5.11 We engage network advertisers to display advertisements on our Website and other platforms, enabling us and these advertisers to tailor ads for products and services based on your potential interests. Ad network providers, advertisers, sponsors, and traffic measurement services may utilize various tracking technologies such as pixels, cookies, JavaScript, wix, Flash LSOs, and others to gauge ad effectiveness and personalize content. These technologies are subject to the specific privacy policies of each entity and not this Privacy Policy. We may provide these advertisers with information, including Personal Information, about you.

5.12 Additionally, unless you opt out of receiving direct marketing from us as outlined in paragraph 10 of this Privacy Policy, we may share certain information (like your email address) with social networks or advertisers such as Facebook Custom Audiences. This enables us to target ads and content more effectively to you and others with similar interests across various platforms. We may collaborate with other ad networks and marketing platforms, like Google, to target ads to Custom Audiences submitted by us and others. You have control over how Facebook and other ad networks display specific ads to you, as detailed further in their respective privacy policies or through provided opt-out mechanisms.

5.13 You may have the option to opt out of many ad networks. For instance, you can visit the Digital Advertising Alliance (DAA) Consumer Choice Page or the Network Advertising Initiative (NAI) Consumer Opt-Out Page for details on opting out of interest-based advertising and managing information used by DAA companies or NAI members.

5.14 Opting out of one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page may stop those companies from delivering interest-based content or ads to you. However, it doesn't guarantee the cessation of all advertising through our Website or other platforms. You may still receive ads based on the specific website you're visiting (contextually based ads). Furthermore, if your browser is configured to reject cookies when opting out on a consumer choice website, your opt-out may not be effective.

5.15 If you prefer we don't use or disclose your Personal Information, like your email address, to third parties for Custom Audiences as described in this section 5, you can opt out following the procedure outlined in paragraph 10 of this Privacy Policy.

Wix

5.16 Wix, originating from third-party sites, are used to track visitor activities on our Website.

Third-Party Content (e.g., Social Media Links)

5.17 Certain content on our Website includes applications provided by third parties, like social media buttons or links enabling content sharing or linking to our Website through relevant third-party platforms. These third-party applications may collect information through your interactions with them, even if direct interaction is absent. We're not responsible for the technical operation of these applications or the data collection practices of the relevant third parties. Refer to the respective third-party websites to understand their privacy practices and the options available regarding your Personal Information collection.

6. How Do We Use Your Personal Information?

6.1 We utilize the Personal Information we gather for our business operations, organizational functions, and marketing endeavours to enhance customer satisfaction and promote our products and services.

6.2 The collected Personal Information is used for various purposes, including facilitating bookings (online, mobile application, or via our call center), identifying and communicating with you, providing requested information, products, or services, offering support to customers, processing payments, managing and improving our products and services, conducting research to understand customer needs, analyzing our shareholder base, fulfilling statutory and legal obligations, and more.

6.3 We reserve the right to monitor, review, retain, and disclose any information as necessary to comply with applicable laws. However, we are not obligated to monitor the use of the Website or retain user session content.

6.4 Personal Information may be aggregated for reporting, statistical, and marketing purposes to better understand customer preferences and improve our offerings. Any disclosed aggregated, demographic, or de-identified information to third parties will not contain Personal Information.

6.5 By using our services, you consent to the usage of your Personal Information as outlined in this Privacy Policy and any agreements entered into with us.

7. When does Legion Cabs share your Personal Information

7.1 Legion Cabs may share or grant access to your Personal Information with third parties as outlined in section 6. Depending on your interaction with us, we may share your Personal Information with our affiliated entities, third-party providers of products and services, or other parties (such as your referees in the case of a job application).

7.2 Your Personal Information may also be shared with:

(a) our internal divisions, business units, or departments

(b) your chosen representatives

(c) vehicle operators, regarding details like your authorization as a driver, account information, trip logs, and data from payment terminals concerning trips taken by operators' drivers

(d) external parties assisting in providing products and services

(e) professional service providers and advisors acting on our behalf, such as legal counsel

(f) medical providers, including practitioners involved in insurance claim assessments

(g) agents, contractors, or representatives aiding in our business operations (e.g., data storage, analytics, marketing)

(h) credit reporting and mercantile agencies (e.g., Equifax)

(i) debt collection agencies

(j) your credit providers or trade suppliers

(k) financial institutions, insurers, auditors, IT service providers, etc., in relation to products or services provided to us

(l) Government bodies, regulatory authorities, and other entities as mandated by law (e.g., Centrelink, ASIC, police).

7.3 Additionally, your Personal Information may be shared with our website hosts or software application providers in specific situations, such as technical issues or to ensure effective and secure website operations.

7.4 As our business evolves, we may acquire customer information through acquisitions, mergers, or partnerships. In such cases, Personal Information may be transferred as part of the assets. Similarly, if a portion or all of our business or assets are sold or transferred, including in insolvency, customer information, including Personal Information, may be disclosed to a potential purchaser.

8. Sharing Information Overseas

8.1 While we primarily operate within Australia, there may be instances where your Personal Information is disclosed, transferred, stored, or processed overseas, either by us or by third-party service providers. This could occur if:

(a) our offices or affiliates are located overseas

(b) certain activities are outsourced overseas

(d) our computer systems, including servers, are situated abroad.

8.2 By using our services, you consent to the collection, use, storage, and processing of your Personal Information outside Australia as described in this Privacy Policy.

8.3 Specifically, your Personal Information may be shared with third parties outside Australia, where their or our computer systems may be located, for purposes outlined in this Privacy Policy."

9. Other Uses and Disclosures

9.1 We may use and disclose your Personal Information for purposes not explicitly listed in this Privacy Policy, notifying you at the time of collection or use.

10. Marketing

10.1 Your consent is obtained for sending you information, including promotional material, about us, our products, services, and related entities via various channels like direct mail, email, SMS, MMS, app push notifications, and more.

10.2 Marketing activities also encompass sections 5.11 to 5.15 (Advertising networks and Custom Audiences), extending to Personal Information collected through methods other than our Website or applications.

10.3 To opt out of receiving marketing information, unsubscribe through provided links in marketing emails or SMS communications, disable app push notifications, update communication preferences in your account settings, or contact us directly.

11. Storage and Security of Personal Information

11.1 We strive to keep your Personal Information secure through physical, technical, and procedural safeguards. Once your Personal Information is no longer required, we may de-identify or remove it from our systems.

12. Access and Update Your Personal Information

12.1 You are entitled to access the Personal Information we hold about you, with reasonable access provided in ordinary circumstances. You can also correct your Personal Information through the Website, mobile applications, or by contacting us directly.

13. Complaints

13.1 If you believe we haven't respected your privacy or conducted ourselves in line with this Privacy Policy, contact our Privacy Officer. We'll investigate and notify you of the outcome.

Updates to the Privacy Policy

14. Updates to this Privacy Policy

14.1 We periodically review and update this Privacy Policy to align with new laws, regulations, practices, and technology. All Personal Information is governed by the most recent Privacy Policy posted on our Website.

15. Contact Us

15.1 For any queries, complaints, access requests, opt-outs, or updates to your Personal Information, contact our Privacy Officer at admin@legioncabs.com.au

This Privacy Policy was last updated on 4/03/2024