1. Our Privacy Commitment
2.4 If the changes are significant, we will aim to provide a more prominent notice of the change and, where possible, send our customers a notification of the changes.
3. What information do we collect?
3.1 We collect information to provide products, services and information to our customers and to the community.
3.2 We also collect information where we are required to do so to comply with the law.
3.3 The types of personal information we collect depends on the circumstances in which the information is collected.
3.4 The main types of personal information we collect include:
(a) your name and contact details.
(b) identification details (such as date of birth).
(c) your organization and position, where your organization has a business account or business dealing with us.
(d) information on your use of our products and services, including use of our roads, our websites and our apps.
(e) records of our communications and dealings with you, such as telephone, email, SMS, online and in-person communications.
3.5 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:
(a) your license plate number.
(b) your vehicle make, model, year, color, registration, owner and acquisition date.
(c) your trip details.
(d) photos and videos of vehicles, which may include occupants in vehicles or people on the roadside.
(e) tolls and fees charged, paid, not paid and owed.
(f) your account balance.
(g) your transponder details.
(h) your billing details.
(i) your payment methods, such as credit card and bank details.
(j) your driver license details.
(k) information to determine or verify if you are entitled to a discount or concession.
3.6 We may also collect information about 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.
3.7 You are always welcome to provide us with comments, queries and feedback in relation to our products and services and our current and proposed roads.
3.8 We may record and monitor telephone calls and other communications between you and us for training, quality control, verification and compliance purposes.
3.9 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.
3.10 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.
3.11 We may collect information about property ownership in relation to properties near our existing or proposed roads or above our existing or proposed tunnels.
3.12 We collect information about people who invest in us.
3.13 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.
3.14 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.
3.15 We collect information about people who visit our sites and our offices. This may include photographs and videos (which we may use for facial recognition where you have consented to this use) of you when you are in or near our sites or offices.
4. Do we collect sensitive personal information?
4.1 Sensitive information includes information about your health, racial or ethnic origin, religious beliefs and criminal record.
4.2 We will only collect sensitive information about you with your consent or if we are otherwise allowed or required by law to collect that information.
5. What information do we collect when you use our online services?
5.1 This section applies to use of online services that we control, such as websites, apps, social media and other online services.
5.2 When using our online services, we and our technology partners may collect information about you and how you use our online services.
5.3 We may collect information such as:(a) user name and password.
5.5 Our online services may also 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.
5.7 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.
6. How do we collect information?
6.1 We collect your personal information in the following ways:
(a) 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.
(b) 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:
(i) automatic incident detection systems (including traffic management and safety cameras).
(ii) vehicle registration detection systems.
(iii) electronic toll collection systems (such as a transponder attached to an individual's vehicle).
(iv) tolling cameras and CCTV.
(v) 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.
(c) When you visit our sites or offices. For example, we may photograph for your identification or video record people on or near our sites or in our offices.
(d) 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:
(i) other people associated with your toll account, such as your employer, family members or people jointly on the account
(ii) other people such as referees you to us or from others who do business with you, if you have a corporate account with us.
(iii) government road and traffic authorities, and service providers to government authorities (such as companies that provide traffic camera services to police.
(iv) other U.S. toll-road operators.
(vi) other companies where you have consented to them providing your information to us, and
(vii) suppliers of information products and services (such as companies that consolidate data from multiple public sources).
6.3 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.
7. How do we use your personal information?
7.1 We use and disclose your personal information:
(a) to provide products, services and information to our customers and to the community.
(b) for the purposes for which it was collected.
(c) in order to improve our products and services.
(d) in order to operate and improve our roads, and to undertake administrative or operational activities associated with designing, constructing, managing and operating our roads.
(e) in order to make special offers or to undertake promotions related to our products or services, including from our retail brands, business or partners or government road or traffic authorities, that we think may be of interest to you.
(f) in order to conduct surveys.
(g) to maintain our relationship with you.
(h) to verify your identity and personal information.
(i) to maintain and update our records.
(j) to calculate and recover tolls and fees.
(k) for debt collection and enforcement purposes.
(l) to consider your eligibility for assistance under our Hardship Policy or within a related assistance program, and to administer such policies and programs.
(m) to investigate or to pursue any legal claim that we may have against you.
(n) for road safety purposes.
(o) for security purposes.
(p) to assist the enforcement of laws.
(q) to undertake traffic planning and vehicle management services.
(r) to meet our obligations and perform our functions under applicable laws and agreements.
(s) to detect, prevent and investigate any fraud or crime (or suspected fraud or crime).
(t) to notify you of changes to our tolls, fees, charges, agreements, products or services.
(u) as otherwise required or authorized by law.
7.3 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.
7.4 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 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.
8. Direct marketing and research. 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.
8.1 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 other Transurban retail brands, the products and services of other people, or related special offers from our 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:
(a) following the “unsubscribe” link in the communication.
(b) changing your account settings.
(c) contacting us here.
8.2 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.
9. Who do we disclose your personal information to?
9.2 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.
10. When do we de-identify information?
10.1 We may de-identify information about an individual so that the information can no longer be related to that individual.
10.2 We may then use and disclose that de-identified information in the course of our business.
10.3 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.
10.4 We may then use and publicly disclose such aggregated information in the course of our business.
11. When do we disclose information overseas?
11.1 We may disclose information to recipients that are located in a different jurisdiction to you and to recipients located outside of the United States. We may disclose personal information to contractors outside of the United States and may use off-shore servers for the purposes of data storage. We have engaged contractors in We have engaged contractors in Australia, the Philippines, Portugal, France, India, Canada, New Zealand, South Africa, Sweden and certain other countries and may disclose certain personal information to those contractors.
11.2 We may also disclose certain personal information to our related entities in Australia and Canada, although such information will typically only relate to employees and internal corporate matters and not customer information or the operation of our roads in the United States.
12. How do we secure your information?
12.1 We use reasonable safeguards and security measures that are designed to protect personal information we hold about you is protected from risks such as misuse, interference, unauthorized access, modification or disclosure. We use a number of physical and electronic measures to protect your personal information.
12.2 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.
12.3 Personal information is only retained for as long as is necessary for the identified purposes or as required by law.
13. How can you access and correct your information?
13.1 You have a right to access most personal information that we have about you. You may do so by contacting us.
13.2 We will not charge you a fee for your access request, but we may recover from you our reasonable costs of supplying you with access to this information.
13.3 When you request access to personal information, we may need to take measures to verify your identity before providing you with such information.
13.4 In some circumstances it may not be possible for us to provide you with all of your personal information. 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.
13.5 We take reasonable steps to ensure the personal information we hold about you is accurate, complete, up-to-date, relevant and not misleading.
13.6 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.
13.7 We reserve the right to refuse to correct your 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 requested be attached to the file that contains your personal information.
13.8 If you are a California resident, please read the “Your California Privacy Rights” section for additional disclosures and information regarding your rights under California law.
14. What information do we collect when you apply to work with us?
14.1 When you apply to work with us, we may collect certain information from:
(b) recruitment consultants.
(c) your previous employers.
(d) your referees.
(e) other sources of relevant information, such as educational institutions, professional and trade associations, referees and publicly available sources.
14.2 The information we collect will assist us to decide whether to make an offer to you to work with us.
14.3 In addition to the information set out above (see paragraph 3.4), the information we collect may include information about your:
(a) work history.
(b) education and other qualifications.
(e) eligibility to work.
14.4 As necessary and where appropriate, we may require you to undergo certain medical checks. We may carry out screening checks (such as background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
15. Data Retention
15.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.
15.2 When we have no ongoing legitimate business need to process your personal information, we are committed to either deleting or de-identifying it.
15.3 When you close your account or request that we delete your personal information, we may retain your personal information for up to 180 days (a) in order to facilitate the final reconciliation of your account, and (b) for archival, audit, disaster recovery, legal, or regulatory purposes, subject to our data retention policies.
16. What information do we collect about you when you work for us?
16.1 In addition to the information we may collect when you (i) apply for employment with us and (ii) commence working with us, we may collect information about your:
(b) employee benefits
(c) banking details
(d) emergency contacts
(e) employment performance
(g) use of Transurban's facilities, IT (including software applications) and communications resources
(h) leave, and
16.2 We collect this information to train and manage our employees and meet our legal obligations.
16.3 Some of the personal information we collect may be considered sensitive information under certain privacy laws. For example, we may collect:
(a) criminal information (such as police checks on job applicants and employees), or
(b) biometric information for the purpose of identity verification (such as your photograph to allow access to a Transurban premises).
16.4 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 U.S. Privacy Officer by email on USprivacy@transurban.com.
17. Our Policy towards children
17.1 Our websites, apps, social media and other online services are not for use by individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under the age of 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.
18. Complaints and further information
18.2 If you are concerned about the way we deal with personal information, please contact us in writing. Please:
(a) include a method for us to contact you.
(b) 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 or the U.S. Tolling Customer Ombudsman.
Alternatively, you can contact the Transurban U.S Privacy Officer by email at USprivacy@transurban.com.
20. Your California Privacy Rights
20.1 California law requires businesses to use specific terms when describing the types of information we collect. Please note that we collect the same personal information from California residents as we do from residents of other states as described above, and we use all personal information as described above. For purposes of our disclosures under California law, we collect the following types of personal information:
(a) Identifiers (such as name, email or physical address, online identifiers, date of birth, IP/MAC address, vehicle registration information, log-in credentials, account information including transponder number)
(b) Financial account information (such as payment card information)
(c) Geolocation data (specifically precise location when you are traveling on toll roads or roads for which we handle toll billing)
(d) Commercial information (such as a record of our services for which you have registered an account or other purchasing history or tendencies)
(e) Demographic and profile information (such as information in your publicly available social media profile)
(f) Internet or network activity information (such as browsing history, your interaction with our websites and apps, and your engagement with advertisements)
(g) Protected characteristics (such as sex, gender, race, ethnicity, citizenship, or nationality)
(h) Education information (in connection with your application to work for us)
(i) Professional or employment-related information (such as your current or past employer and job title, whether in connection with a business account with us or your application to work for us)
(j) Audio, electronic, visual, or similar information (such as photographs of you moving through our toll roads or recordings of your telephone conversations with our customer service representatives)
20.2 We disclose the personal information listed in Section 20.1 with our service providers, affiliates, and subsidiaries for business purposes. Services providers include data storage providers, payment processors, email providers, data security providers, professional advisors, advertising partners and platforms, data analytics providers, and any other entity that provides services to us in connection with operating our business and providing services to you. We also share information with other road operators to enable you to use your transponder on those other roads. Additionally, we disclose identifiers and geolocation information to government entities in connection with their operation of toll roads.
20.3 We do not sell personal information, as defined by California law.
20.4 We described ways you can access and correct your information in the above section, “How can you access and correct your information?” If you reside in California, you may have the right to access specific pieces of your information, the right to know further details about our processing of your information, the right to request deletion of your personal information, and the right to not be denied our services for exercising these rights.
(a) You can exercise these rights by:
(i) Emailing us at firstname.lastname@example.org
(ii) Calling us at 855-495-9777
(iii) Visiting our “Contact us” webpage
(b) We may need to verify your identity before fulfilling your request to exercise your rights.
(i) If you hold an account with us, we will verify your identity by having you log into your account or verify account-specific activity or information including through a channel other than your account.
(ii) If you do not have an account with us, you will need to provide information to establish your identity to the degree of certainty required by law. Such information may include name, email address, or other information relating to your use of your websites, apps, or services.
(c) We accept consumer rights requests through authorized agents, as required by law. While we will fulfil your rights request through an authorized agent, we may notify you as the consumer of the agent’s request on your behalf, and we also may require that you as the consumer verify your identity before we fulfil the request through your agent.
(d) We will retain certain information relating to your rights requests to demonstrate our compliance with applicable law, as well as to improve our consumer request and response processes.