1. Our commitment to privacy
The privacy of Members and our customers is of utmost importance to the National Roads and Motorists' Association Limited (ACN 000 010 506) (NRMA).
2. Types of personal information we collect and hold
The types of personal information we collect and hold will vary depending on your Membership, your dealings with the NRMA Group and the products, services and benefits we (or our agents, contractors and third parties) provide to you, or a request or inquiry you make in relation to such products, benefits and services. This information may include any or all of the following:
- Name, address(es), telephone number(s) and other contact details;
- Electronic address(es);
- Date of birth;
- Vehicle details including registration, model and colour;
- Transaction details relating to your use of our products, services or Member benefits;
- Payment information (such as credit card, PayPal or bank details);
- Details of your membership to any loyalty or affiliate program;
- Vehicle details including registration, model and colour;
- Driving history, including details of any driving related offences or motor vehicle accidents;
- Driver's license number and/or passport number and, upon our request, a copy of your driver's license or passport;
- Drivers licence validity and history;
- Location data including the geographic location of your vehicle and/or location of devices used in the vehicle, such as GPS units, or a smartphone accessing our app or associated apps;
- Your social media preferences;
- Any benefits you obtain from your Membership; any of the above information in respect of additional cardholders or your family members; and
- Any preferences you tell us about or other information that you provide.
- We may collect and hold sensitive information, such as the fact that you are disabled, to allow us to provide our services more effectively to you (particularly Roadside Assistance) but only if you provide express consent at the time it is provided.
Please see the Direct Marketing section of this policy for more examples of the kinds of personal information we collect.
3. Website cookies and digital services
Information is also generated and collected whenever a page is accessed on our website that records information such as the time, date and specific page. We collect such information for statistical and maintenance purposes that enables us to continually evaluate our website performance. Some parts of our websites also use "cookies". A "cookie" is a small text file that is placed on your computer's hard drive by a web page server. Cookies store information about the use of our website and are used to identify new or previous visitors to the website and what pages have been accessed. Most web browsers are set to accept cookies, but this function can usually be disabled if you wish. Please note that if you do disable this, not all functionality on our websites will be available to you.
We also use Google Analytics features (including Google Remarketing, Google Display Network Impressions Reporting, the Double Click Campaign Manager and Google Analytics Demographics and Interest Reporting) on our website, which uses both first party and third party cookies to record standard internet traffic information. We, and some third parties (including Google), also use the information to optimise ad selection for groups of individuals based on age, gender, interests and past visits to our site. The cookies allow us and other third parties (including Google) to evaluate your interactions with ad services on our site and serve targeted advertising on sites across the Internet. We have enabled Google Analytics for Display Advertising which allows Google and other third parties to advertise to you on our site and across the Internet.
We also use (along with third parties including Google) first party cookies (such as Google Analytic cookies) and third party cookies (such as the DoubleClick cookie) to report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our website. In addition, we use data from Google's Interest-based advertising or third party audience data (such as age, gender, and interests) with Google Analytics to help us understand how user activity varies based on these factors
Importantly, we do not combine the anonymous information collected through Google Analytics with personally identifiable information.
In addition to Google Analytics, we use a range of web analytics tools (such as web beacons) to help us understand consumer behaviour and use of our website. In particular, these tools enable us to deliver cookies, count visits and understand usage and campaign effectiveness. This data helps us to stay connected and relevant to our Members and customers.
4. Why we collect and hold personal information
Generally, we collect, hold and use personal information about Members and customers to establish Memberships and provide a range of products, services and benefits to Members and customers relating to their motoring and related lifestyle needs.
We also collect personal information to assist in identifying ways in which we can serve you better, such as providing our products and services to you more effectively, and to assist our internal administration and operations including accounting, risk management, record keeping, archiving, systems development and testing, and staff training.
Some of the information we collect is for the purpose of improving our interaction with Members and their involvement in the NRMA Group.
5. How we collect information
Generally, we collect personal information directly from you, such as when you apply for Membership or request a product or service, in the course of providing you with that product or service (e.g. Roadside Assistance), or when you have other dealings with us.
We may collect and update that information over the phone, at roadside, over the Internet, in person (when you visit us at an NRMA office), when you write to us or if you participate in our marketing campaigns. We may also collect personal information through third parties such as:
- Our related companies;
- Affiliated interstate motorists' clubs;
- Our business partners who provide Member benefits;
- Insurance Australia Limited* (trading as NRMA Insurance) and its related entities;
- Our service providers;
- The RMS and toll providers
- Car dealers and manufacturers who provide Membership packages in the sale of vehicles; and
- Data washing organisations and postal service providers, including Australia Post.
In certain circumstances, for example, if you have Connected from NRMA service, In addition, in the course of providing that service, we may collect or compile information which is or becomes personal information. For example, we may collect personal geographic information from GPS positional data, telematics devices or location services through our smartphone applications.
6. Storage and protection of personal information
We store personal information in a combination of secure computer storage facilities and paper-based files and other records. In so doing, we have taken numerous steps to protect your personal information from misuse, interference and loss, and unauthorised access, modification or disclosure.
Additionally we take reasonable steps to destroy or permanently de-identify personal information when we no longer need it. We impose strict requirements of security and confidentiality on all third parties as to how they store, handle and deal with your personal information.
7. How we use and disclose personal information
We may use and disclose your personal information for a variety of purposes in connection with servicing you as a Member or customer and in relation to our business operations. These include:
- Processing and administering your Membership or dealings with us as a customer;
- Providing you with the products and services you have requested from us;
- Developing processes, products, services and benefits to better meet your needs;
- Disclosing your information for use by relevant parties in connection with your Membership and services; such as to affiliated interstate motorists' clubs or the Australian Automobile Association.
We may also use your personal information to offer or provide you with loyalty benefits, discounts or other information about such schemes that may be operated by us or third parties. This includes:
- Obtaining details about how you acquire and use our products, services and Membership benefits;
- Rewarding Members for utilising our products and services through mechanisms such as discounts, special pricing offers and prizes; and
We may provide your personal information to our agents, contractors or related companies for the purposes of, or in connection with, the supply of products and services to you and for the same purposes above.
8. Direct marketing
We collect personal information so that we can provide our Members with useful and relevant information about our products and services. Generally, we collect this information directly from you. In some circumstances, however, we may collect personal information from third parties, including from our service providers and social media platforms such as Facebook. We use the information we, or our service providers, collect to assist us to determine how we can best engage with our Members about our products and services. To this end, we, or our service providers, may collect information about your social media preferences and activities so that we can engage with our Members on social media sites. We may also collect certain demographic information and behavioural information from social media platforms to better serve consumers with more targeted advertising.
At times, we use tools that enable us to identify the online sources of the telephone sales enquiries that we receive. The information we collect through these tools includes the time and date of the call, the geographical location of the call, the telephone number of the caller (unless withheld), and the IP address of the device the caller used to arrive at your website. The collection of this information helps us to determine the effectiveness of our marketing campaigns by identifying whether the calls we receive were generated by Google Adwords click throughs, or by Facebook ad click throughs (for example).
If we do not collect information in the ways described above, we may not be able to let you know about our products and services in the most effective way.
We may use and disclose the information we collect for the purpose of providing you with tailored marketing communications about our goods and services, or to conduct market research. Typically, we send these communications to your email address or mailing address. Occasionally, we may also send marketing communications to your social media accounts, including, for example, your Facebook account.
We may also disclose your personal information to companies in the NRMA Group, to our other business partners, our service providers and Insurance Australia Limited* (trading as NRMA Insurance) and its related entities, to give you information and offers about products and services offered by us or these companies.
9. Opting out of direct marketing
If you do not wish to receive direct marketing information from the NRMA Group, please use the contact details below to update your preferences, or use the unsubscribe feature on our electronic marketing communications. Please note that if you make such a request:
- We may still need to use your personal information to provide you with the services and products you have requested as a Member or customer; and
- It may not be possible for us to immediately action a request to cease receiving any or all direct marketing material. However, we will respond to such requests as soon as practicable and will make all reasonable efforts to promptly activate a change in preference or an opt out of receiving future direct marketing material.
We will not sell or rent your personal information without your consent. We may disclose your personal information where we are required or authorised by law to disclose your personal information or for any purposes connected to a fraud, crime prevention or impropriety investigation.
10. Overseas disclosure of personal information
NRMA is likely to disclose some of your personal information, for the purposes described above, to organisations in the United Kingdom, the Philippines, the Netherlands, Ireland and the United States of America.
11. Location-Based Services
To provide location-based services on the NRMA Roadside Assistance iPhone or Android application, NRMA, its partners and licensees may collect, use, and share location data, including the real-time geographic location of your mobile device. This location data is used by NRMA, its partners and licensees to provide and improve location-based features and services. The location data is collected anonymously in a form that does not personally identify you, however we may request you to provide personal information and link that information to your location data for the purpose of providing some of the location based features of the NRMA Roadside Assistance iPhone or Android application.
12. Access to, and correction of, personal information
We will take reasonable steps to make sure that the personal information we collect, hold, use or disclose is accurate, complete and up to date. If your personal details change, such as your address or phone number, please contact us on 13 11 22 to update your details.
Following a request, we will provide you with a copy of any personal information which we hold about you in accordance with our obligations under the Privacy Act. We may charge a fee for retrieving this information, in which case we will inform you of the fee in advance of providing the information.
In the first instance, we will ask you to provide some of identification, such as your driver's licence, to ensure that you have the right to access the information.
13. Making a complaint
If you wish to complain about our handling of your personal information, please send a written complaint to the Privacy Officer in the first instance by using the contact details below. We undertake to promptly acknowledge and investigate any complaint about the way we manage personal information. If you are dissatisfied with the outcome of our investigation, you may take your privacy complaint to the Office of the Australian Information Commissioner (OAIC). For information in making a complaint to the OAIC, please visit the OAIC's website http://www.oaic.gov.au/privacy/privacy-complaints, or phone 1300 363 992.
14. Contacting us
The Privacy Officer
National Roads and Motorists' Association Limited
9 George Street
North Strathfield NSW 2137
You can also telephone us on 13 11 22, visit an NRMA office or email our Privacy Officer.
*Insurance Australia Limited (trading as NRMA Insurance) and its related entities are separate and unrelated to National Roads and Motorists' Association Limited.
[Last amended on 1 March 2017]