Mobile App Privacy Policy
Version: 1.01
Your privacy is important to Directed Telematics Pty Ltd. This privacy policy (“Policy”) governs the use of any Personal Information that Directed Telematics Pty Ltd and/or its related bodies corporate (“Directed”) collects from you during your use of the software application(s) listed below (“Applications) for mobile devices that were created by Directed and that are made available to you pursuant to agreement(s) entered into by you (or your employer) and Directed or any Directed authorised reseller(s). Directed reserves the right to amend or withdraw all or any of the Applications, at any time and for any reason. Directed will collect, use and hold such Personal Information in accordance with the Australian Privacy Principles, as set out in the Privacy Act 1988 (Cth) and otherwise in accordance with the terms of this Policy.
2. Definitions
“Application(s)”: any software provided by Directed to offer its services, to be used on mobile devices, including all and any upgrades that Directed may make available from time to time and any other software or documentation that enables the use of the Application.
“Business Purposes”: all purposes reasonably related to the business functions and activities of Directed, as well as the products and services that it offers including providing the Applications, providing other products and services of Directed, conducing publicity campaigns, handling complaints, providing and managing the Directed website(s).
“Personal Information”: any user provided and automatically collected information about you that identifies you, or by which your identity can reasonably be ascertained and includes any credit related information provided to Directed.
"Processing”: using or interacting with Personal Information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing Personal Information.
3. Your Consent
By using the Application, you are consenting to the Processing of Personal Information by Directed, as reasonably required for the Business Purposes of Directed and in accordance with this Policy. Subject to the other terms of this Policy, You also consent to such Processing of data and transfer of data to or outside your home country. You warrant that the information that you provide to Directed, whether via the Application or otherwise, is true, complete and accurate in all respects.
4. Collection of Information
What information does the Application obtain?
User Provided Information – The Application obtains information that you provide when you download and register an Application. Where applicable, registration with Directed is mandatory in order for you to be able to use the Application. When you register and use the Application, you generally provide:
(a) Your mobile device number, your name, organization ID, driver ID, password and other registration information and;
(b) Information you enter into our system when using the Application.
Automatically Collected Information - The Application may collect certain information automatically, such as the type of mobile device you use, your mobile device’s unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browsers you use, and information about the way you use the Application. The Application will also collect location data which may be linked to you.
Third Party Provided Information - Directed may also collect Personal Information about you from a third party, for example, from a credit body if you apply for commercial credit, or from its authorised resellers or from regulatory authorities.
Sensitive Information
You are not required to provide any sensitive information about You through the Application. It is unlikely that Directed will collect sensitive information about You. However, if your sensitive information is required, Directed will first seek your express consent and such information will be collected and used in accordance with applicable law.
Government Identifiers
Directed does not use government identifiers (e.g. Medicare numbers) to identify individuals.
How is your Personal Information used?
All Personal Information that you provide to Directed will be used solely for its legitimate Business Purposes, including to provide the Directed services to you or to your employer pursuant to the agreement described above. Where Directed collects Personal Information for any purpose other than stated in this Policy, Directed will provide you with notice of the purpose(s) for which the Personal Information is collected and other reasonably related information pertaining to such collection (at the time of collection or, if that is not practicable, as soon as practicable afterwards).
5. Does the Application collect precise real time location information of the device?
The Application, depending on its functionality and type, may collect precise information about the location of your device. Directed will not share your current location for any purpose other than the authorised purposes described in this Policy.
6. Do third parties see and/or have access to information obtained by the Application?
Yes. Directed will share your Personal Information with third parties only in the ways that are described below.
Directed may disclose Personal Information:
7. What are your opt-out rights?
Opt-out of all information collection by uninstalling the Application
You can stop all collection of information by the Application easily by uninstalling the Application (with the prior consent from your employer, if applicable). You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace.
Direct Marketing
If Directed Electronics collects Personal Information about you for direct marketing purposes, Directed will give you the opportunity to opt-out of receiving direct marketing communications. You can let Directed Electronics know at any time that you no longer wish to receive any marketing materials and your details will be removed from Directed Electronics’ direct marketing database.
8. International Transfers
If your Personal Information is disclosed to an overseas recipient, Directed will take reasonable steps to ensure that the recipient does not breach applicable privacy laws in relation to your Personal Information, unless Directed reasonably believes that:
(a) the recipient is subject to laws that protect information in a similar way to the Australian Privacy Principles; and
(b) there are mechanisms that an individual can access to enforce the privacy of their Personal Information.
9. Information Retention, Accuracy and Management
Directed will retain user provided and automatically collected data for as long as you use the Application and for a reasonable time thereafter or as contractually required. Directed will delete such information from our files within a reasonable time. With respect to unsolicited Personal Information that Directed Electronics determines it could not have collected, Directed Electronics will destroy or de-identify the relevant information as soon as practicable. This will be done only if it is lawful and reasonable to do so and in accordance with applicable laws.
Directed will use reasonable endeavours to ensure the accuracy of your Personal Information, as provided to Directed. When Personal Information is retained, you have the right to view, update, correct or request the deletion of your Personal Information and Directed will respond to your requests subject to applicable law.
10. Security
Directed is concerned about safeguarding the confidentiality of your information. Directed provides physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Application. Please be aware that, although Directed endeavours to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
11. Changes
This Privacy Policy may be updated from time to time for any reason. Directed will notify you of any changes to our Privacy Policy by posting the new Privacy Policy here and making reasonable efforts to notify you thereof. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.
12. APP Privacy Policy availability.
Directed has the terms of their APP Privacy Policy available for free on its website, www.directed.com.au.
12. Notification
All notifications and complaints in relation to this Policy should be issued to apps@directed.com.au .