Privacy Policy

National Luxury Transport is committed to maintaining the privacy of our customers and staff. Being one of Australia’s leading transport operators and offering unique transport management programs, National Luxury Transport is required through its daily operations to collect and maintain employee and customer information.

National Luxury Transport follow the Privacy Act 1988 as well as other laws and codes governing our industry.

We ensure that our staff are trained in our policies and procedures around privacy and are only able to access confidential information relating to the specific tasks or roles required within the business.

Privacy

The National Privacy Principles (NPPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act) govern

the way in which your Personal Information is collected, used, disclosed, stored, secured and disposed.

Open and Transparent Management of Personal Information

We manage your personal information in an open and transparent manner. This Privacy Policy is publicly available on our website and outlines our practices regarding data handling.

Anonymity and Pseudonymity

Where lawful and practicable, you have the option of interacting with us anonymously or using a pseudonym. For example, general enquiries about our services can be made anonymously. However, we will require your real identity to provide specific products, complete financial transactions, or fulfill contractual obligations.

Collection of Solicited Personal Information

NLT will only collect and retain the information of our customers that is necessary to maintain a high-quality service and meet our customer contract requirements.

Examples of Personal Information collected include: names, addresses, email addresses, phone numbers and date of birth. This Personal Information is obtained in many ways including interviews, correspondence, by telephone, by email, via our Transport Management System, our subcontractors, from publicly available sources and from third parties.

Personal Information is collected for the primary purpose of providing our services and for

recruitment requirements. NLT may use Personal Information for secondary purposes closely

related to the primary purpose, in circumstances where such use or disclosure would be reasonably

expected.

Sensitive information is defined in the Privacy Act to include information or opinion about such things as an individual's racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a trade union or other professional body, criminal record or health information.

Sensitive information will be used by NLT only:

For the primary purpose for which it was obtained
For a secondary purpose that is directly related to the primary purpose
With your consent; or where required or authorised by law

NLT may collect ‘sensitive information’ in limited circumstances relating to employment such as health information, employment records, educational qualifications and criminal records for the purposes of medical or background screening for employment application purposes. By providing this information to us, unless you indicate otherwise, NLT will assume that you have given your consent to the collection of such sensitive information.

Dealing with Unsolicited Personal Information

If we receive personal information that we did not solicit, we will determine within a reasonable period whether we could have lawfully collected it under APP 3. If we determine we could not have collected it, and the information is not contained in a Commonwealth record, we will safely destroy or de-identify the information as soon as practicable, provided it is lawful to do so.

Where reasonable and practicable to do so, NLT will collect your Personal Information only from

you. However, in some circumstances NLT may be provided with information by third parties. In

such a case NLT will take reasonable steps to ensure that you are made aware of the

information provided to us by the third party.

Notification of the Collection of Personal Information

At or before the time we collect your personal information (or as soon as practicable after), we will take reasonable steps to notify you of:

· Our identity and contact details.

· The purposes for which we are collecting the data.

· Any third parties to whom we typically disclose this information.

· How you can access this policy to seek corrections or lodge a complaint.

Use or Disclosure of Personal Information

Your Personal Information may be disclosed in a number of circumstances including the following:

Third parties where you consent to the use or disclosure
For accreditation purposes, including background checks; and
Where required or authorised by law

We will only use or disclose your personal information for the primary purpose for which it was collected, or for a secondary purpose that you would reasonably expect (and which is related to the primary purpose). For any other uses, we will obtain your explicit consent, unless disclosure is required or authorised by an Australian law or a court/tribunal order.

Direct Marketing

We will not use or disclose your personal information for direct marketing purposes unless you have consented to receive such communications, or you have a reasonable expectation that your data would be used this way. You can easily opt out of direct marketing at any time by clicking the "unsubscribe" link in our emails or by contacting us directly.

Cross-Border Disclosure of Personal Information

Before we disclose your personal information to an overseas recipient, we will take reasonable steps to ensure that the recipient complies with the APPs or a similar binding privacy scheme, unless you consent otherwise or an exception applies under the Privacy Act.

Adoption, Use or Disclosure of Government Related Identifiers

We will not adopt, use, or disclose a government-related identifier (such as a Tax File Number or Medicare number) as our own identifier for you unless required or authorised by Australian law.

Maintaining the Quality of your Personal Information

It is important that Personal Information is up to date. NLT will take reasonable steps to make

sure that Personal Information is accurate, complete and up-to-date. If it is found that the information NLT has is not up to date or is inaccurate, staff are to advise NLT to update a staff member’s records to ensure it continues to provide quality services.

If any queries or complaints are raised about the Privacy Policy, these will be addressed by the Managing Director.

Security of Personal Information

We take the security of your data seriously. Personal Information is stored in a manner that reasonably protects it from misuse and loss and from unauthorised access, modification or disclosure.

We employ appropriate technical and organisational measures (such as encryption, secure servers, and access controls) to protect your personal information from misuse, interference, loss, and unauthorised access, modification, or disclosure. When your data is no longer needed, we will take reasonable steps to securely destroy or permanently de-identify it. Records of personal information are kept as per the records management policy for the retention period required by law or standards and regulations.

Access to your Personal Information

If staff would like to access, review, correct or update personal information, they may contact the Managing Director. Requests are to include the staff member’s email address, name and telephone number and specify clearly what information is to be accessed, reviewed, corrected or updated.

On request, NLT will provide the staff member with access to the information its holds

within a reasonable time frame, unless providing access is exempt under the Australian Privacy

Principles. NLT will provide written reasons, including the relevant exemption under the

Australian Privacy Principles, if any request is refused.

Confidentiality

Employees are at all times required to keep confidential all commercially sensitive or personal information that they are privy to. Personal information and discussion about personal information is only communicated in strict accordance with the role of the person in possession of the information (i.e. Managing Director) or with the consent of the person(s) involved.

The requirement to maintain confidentiality must be maintained after employment with National Luxury Transport ends.

Intellectual Property

All work, creativity, innovations, concepts, symbols, procedures instructions, information, data and records remain the property of the respective Operating Company. No reproduction or sharing of this knowledge outside of the Group is permitted without written consent of the relevant General Manager or the Chief Executive.

Complaints and Contact Information

If you have any questions about this Privacy Policy, wish to access or correct your data, or want to lodge a complaint about a potential breach of the APPs, please contact our Privacy Officer:

· Email - feedback@nationalluxurytransport

· Postal Address: 27 Osboldstone Rd, Wangaratta VIC 3677

We will investigate any complaints and respond to you in writing within a reasonable timeframe (usually 30 days). If you are not satisfied with our response, you can escalate your complaint to the Office of the Australian Information Commissioner (OAIC).