ComfortDelGro Corporation Australia Pty Ltd (ACN 002 072 004) (‘CDC’, ‘we’, ‘our’ and ‘us’) and its related entities are committed to responsible privacy practices and to complying with the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (‘Privacy Act‘).
Personal information we may collect
The types of personal information CDC collects from you depends on the circumstances in which the information is collected, which may include:
- An individual contacting us with an enquiry, feedback or a complaint
- Contact in relation to booking a charter or on demand or a route service, or
- An application for employment with us.
CDC may collect contact details including your name, address, email address and phone/fax numbers. Where relevant, CDC may also collect your credit card and other payment details, billing address, your driver’s licence and vehicle registration details, and any special requirements you notify to us in respect of the use of our services. Information collected may include information such as comments, likes, tweets, status comments, profile information and complaints on social media and photo or video footage (e.g. CCTV).
CDC may collect personal information as otherwise permitted or required by law.
CDC will not generally require you to disclose any sensitive information (for example, details of race, religious beliefs, sexual orientation, health information, etc) to us. We may however require prospective employees or contractors to provide us with certain health information (see the section below titled ‘Information for Job Applicants’). We may also request you inform us of any special accessibility requirements related to your use of our services.
If you do provide sensitive information to us for any reason, you consent to us collecting that information and to us using and disclosing that information for the purpose which you disclosed it to us and as permitted by the Privacy Act and other relevant laws.
Why do we collect your personal information?
Whenever practical, we endeavour to inform you why we are collecting your personal information, how we intend to use the information and to whom we intend to disclose it at the time we collect your personal information.
We may use or disclose your personal information:
- For the purposes for which we collected it (and related purposes which would be reasonably expected by you)
- For other purposes to which you have consented, and
- As otherwise authorised or required by law.
Some of the specific purposes for which we collect, use and disclose personal information are as follows:
- To facilitate the provision of services you acquire from us and to respond to your queries
- To contact you (directly or through our service providers) to obtain your feedback and to find out your level of satisfaction with our services through surveys
- To keep you informed of operational changes
- When reasonably necessary to protect or enforce the legal rights or interests of CDC (and related entities) or to defend any claims made against CDC (and related entities) by any person
- To verify your identity
- To facilitate your entry and participation in a competition or promotion
- To provide goods or services to you or to receive goods or services from you
- For marketing or client relationship purposes
- To address any issues or complaints that we or you have regarding our relationship
- To contact you regarding the above, including via electronic messages such as SMS and email, by mail, by phone or in any other lawful manner.
Some of the personal information we collect will be essential for us to be able to accurately identify who is using our services. Other types of personal information we collect will help us to profile who is using our services and why, to assist us with continuous service improvements.
We may send promotional materials, including direct marketing materials, or notifications to you where we believe this information may be of interest to you. We will comply with our obligations under the Spam Act 2003 (Cth) and the Do Not Call Register Act 2006 (Cth) in relation to such direct marketing communications.
You may opt out of receiving direct marketing communications from us at any time.
What happens if you don’t provide personal information?
Generally, you have no obligation to provide any personal information requested by us. However, if you choose to withhold requested personal information, we may not be able to provide you with the services that depend on the collection of that information. For example, if we did not collect your personal information when you raised a query regarding lost property on one of our services, we would be unable to notify you if that lost property was later located.
Collection of information from our website
In order to monitor our website and applications’ performance, we may track your IP address, pages accessed, the documents downloaded, your session time and journeys. This information is aggregated on an anonymous basis and cannot be used to identify you. We may place a cookie in the browser files of your computer. This cookie does not contain any personally identifying information but will enable us to:
- Relate your use of the site to information that you have specifically and knowingly provided to us, such as any services we may provide via our website; or
- Allow your browser to track searches you have performed on our website.
By using the CDC website and applications, you consent to the collection and use of this information.
Who can we disclose your personal information to?
We may disclose your personal information to third parties, for example to third party contractors, Transport for NSW, other transport carriers and data processing companies. Where we disclose personal information to third parties we will use reasonable commercial efforts to ensure that such third parties only use your personal information as reasonably required for the purpose we disclosed it to them and in a manner consistent with the Australian Privacy Principles.
We take all reasonable steps to protect your personal information from misuse and loss, unauthorised access, modification or disclosure. Our personnel are trained to treat personal information so as to maintain confidentiality. When personal information is no longer required, the information will be destroyed or permanently de-identified.
Third party contractors engaged by us may be required to handle your personal information, for example to:
- Provide electronic funds transfer services, credit card account processing and other payment related services
- Conduct market research
- For the purpose of direct marketing to you, where permitted, and
- Provide data processing services.
We will require that any third-party contractor only uses personal information about you for the specific purpose for which we supply it.
Your personal information will not be ‘sold’ by CDC to any other organisation for that organisation’s unrelated independent use.
Personal information (information or an opinion about passengers), collected from passengers, such as name, date of birth, contact details, or sensitive personal information (including information about mobility/accessibility requirements) (together Personal Information) collected by CDC may be disclosed to Transport for New South Wales (TfNSW).
TfNSW may disclose such Personal Information to other Australian government agencies. These government agencies may use Personal Information for any purpose relating to the exercise of their government functions. Such Personal Information may also be disclosed to other third parties if required by law.
TfNSW may also use passengers contact details to conduct surveys relating to the provision of the service provided by CDC on behalf of TfNSW.
By using these services provided by CDC, passengers consent to the collection, use and disclosure of their Personal Information in the manner outlined above.
Does your personal information leave Australia?
Your information may be shared between related entities where necessary, including those based overseas (specifically Singapore where CDC’s ultimate parent company is based).
Information for job applicants
If you submit a job application to CDC, we will use the information provided by you to assess your application. CDC may disclose the information contained in your application to contracted service providers for purposes such as screening, aptitude testing and medical testing.
If CDC requests you undergo a medical assessment, you will be asked to give specific consent for the relevant medical service provider to disclose the results of the assessment to us. If you do not provide this consent, CDC will be unable to consider your application.
CDC will handle health information in accordance with applicable laws.
How can you access and correct your personal information?
CDC endeavours to maintain your personal information as accurately as reasonably possible.
If you would like to access, review, correct or update your personal information, you may contact us at email@example.com. In your request, please include your email address, name, address and telephone number and we will respond to your request as soon as reasonably practicable.
On request, we will provide you with access to the information we hold about you in accordance with the Privacy Act, subject to certain exemptions which may apply. We will provide you with written reasons, including the relevant exemption under the Australian Privacy Principles, if any request is refused.
How to lodge a complaint
If you would like to access your personal information, or have a question or complaint about the collection or use of your information, please write to:
Privacy Officer – ComfortDelGro Corporation Australia Pty Ltd
29 Foundry Road
SEVEN HILLS NSW 2147
Alternately, please email firstname.lastname@example.org.
We will take any privacy complaint seriously and we request that you co-operate with us and provide any relevant information we might need to assess your complaint. We will provide a response as soon as practicable, but within 30 days. If you are not satisfied with our response to your complaint, or at any time, you may refer your complaint to the Office of the Australian Information Commissioner (www.oaic.gov.au).
The following companies are wholly-owned subsidiaries of ComfortDelGro Corporation Australia Pty Ltd:
Hillsbus Co Pty Ltd – ABN 62 116 171 469
CDC Travel Pty Ltd – ABN 49 118 478 318
Hunter Valley Buses Pty Ltd – ABN 68 116 171 432
Blue Mountains Transit Pty Ltd – ABN 59 600 387 479
CDC Victoria Pty Ltd – ABN 21 006 822 420 – and its subsidiaries
Qcity Transit Pty Ltd – ABN 50 001 260 242
Baypalm Pty Ltd – ABN 59 003 969 462
Westbus Region 1 Pty Ltd – ABN 72 116 171 450
Westbus Region 3 Pty Ltd – ABN 92 054 096 892