Thrifty Privacy Policy
At Thrifty we are committed to protecting your privacy. We respect your privacy and your right to know how that information is being used. We are sensitive to the concerns that our customers and users may have regarding confidentiality, security and use of their personal information and would like to reassure you of our position on this matter. By accessing our site you accept our terms and conditions of its use, including consent to the collection and use of your personal information and our right to make amendments to this statement from time to time. We encourage you to review this statement to inform yourself of any amendments. We will, where possible summarise the amendments which are made.
This statement has been prepared in accordance with the National Privacy Principles as outlined in the Privacy Amendment (Private sector) Act 2000. The principles can be viewed at the Office of the Federal Privacy Commissioner at www.privacy.gov.au.
Collection Of Personal Information
| Use and Disclosure | Data Quality
| Data Security | Openness
Access and Correction | Identifiers
| Anonymity |Transborder Data
Flows |Sensitive Information
New Services and Developments | Compliance
Audit | Definitions
Collection Of Personal Information
We generally collect information from you when you register with Thrifty to receive a service or information. Thrifty may be limited in our ability to provide the requested service if the necessary information is not provided.
Thrifty will collect personal information only by lawful and fair means and not in an unreasonably intrusive way.
If it is reasonable and practicable to do so, Thrifty will only collect information about an individual from that individual.
If Thrifty collects personal information about an individual from another party, Thrifty will take reasonable steps to ensure that the individual is or has been made aware except to the extent that making the individual aware of the matters would pose a serious threat to the life or health of any individual.
Use and Disclosure
Thrifty will, at all times intend only to use your personal information for the purpose in which it was collected or for a directly related purpose.
Thrifty will not use or disclose any information about you without your consent, or access your communications unless:
Thrifty will only use or disclose personal information about an individual for a purpose other than the primary purpose of collection (a secondary purpose) if:
- Both of the following apply;
- The secondary purpose is related to the primary purpose of collection and, if the personal information is sensitive information, directly related to the primary purpose of collection.
- The individual would reasonably expect Thrifty to use or disclose the information for the secondary purpose; or
- The individual has consented to the use or disclosure; or
- The information is not sensitive information and the use of the information is for the secondary purpose of direct marketing.
- It is impractical for Thrifty to seek the individuals consent before that particular use; and
- Thrifty will not charge the individual for giving effect to a request by the individual to Thrifty not to receive direct marketing communications; and
- The individual has not made a request to Thrifty not to receive direct marketing communications; and
- In each direct marketing communication with the individual, Thrifty draws to the individuals attention, or prominently displays a notice, that he or she may express a wish not to receive any direct marketing communications; and
- Each written direct marketing communication by Thrifty with the individual sets out Thrifty's business address and telephone number and, if the communication with the individual is made by fax, telex or other electronic means, a number or address at which Thrifty can be directly contacted electronically; or
- The information is health information and the use or disclosure is necessary for research, or the compilation or analysis of statistics, relevant to public health or public safety:
- It is impracticable for Thrifty to seek the individuals consent before the use or disclosure; and
- The use or disclosure is conducted in accordance with guidelines approved by the Privacy Commissioner under section 95A of the Privacy Act for the purposes of this subparagraph; and
- In the case of disclosure-Thrifty reasonably believes that the recipient of the health information will not disclose the health information, or personal information derived from the health information; or
- Thrifty reasonably believes that the use or disclosure is necessary to
lessen or prevent;
- A serious and imminent threat to an individuals life, health or safety
- A serious threat to public health or public safety; or
- Thrifty has reason to suspect that unlawful activity has been, is being or may be engaged in, and uses or discloses the personal information as a necessary part of its investigation of the matter or in reporting its concerns to relevant persons or authorities; or
- The use or disclosure is required or authorized by or under law; or
- Thrifty reasonably believes that the use or disclosure is reasonably necessary for one or more of the following by or on behalf of an enforcement body;
- The prevention, detection, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law;
- The enforcement of laws relating to the confiscation of the proceeds of crime;
- The protection of the public revenue
- The prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct;
- The preparation for, or conduct of, proceedings before any court or tribunal, or implementation of the orders of a court or tribunal.
- If Thrifty uses or discloses personal information under paragraph above, it will make a written note of the use or disclosure.
Data Quality
Thrifty at all times take reasonable steps to ensure that the personal information that we collect, use or disclose is accurate, complete and up to date.
Data Security
Thrifty takes all reasonable steps to protect the personal information we hold from misuse and loss and from unauthorized access, modification and disclosure.
The following measures are in place:
- Firewall protection to protect against hackers and other potentially harmful access means
- Server auditing and alerting is in place in case of potential attacks
- All Thrifty staff and external contractors are bound by non-disclosure and confidentiality agreements.
The firewall system protecting the server logs all unauthorized access and monitors for repeated attempts to illegally gain access. Should that occur the firewall system would automatically block the source computer system for a minimum of 60 minutes from having any access to the Thrifty web server.
System tests occur every 2 weeks. System tests include port scans to ensure the firewall is properly protecting the server and tests to ensure the latest security patches are in effect on the server platform and the database server.
Openness
Thrifty will have clearly expressed policies on its management of personal information and these will continue to be readily available. Thrifty will take reasonable steps to let individuals know, generally, what sort of personal information it holds, for what purposes, and how it collects, uses, and discloses that information.
This Privacy Policy and our Privacy Statement are examples of how Thrifty lets you know about our commitment to Privacy and the protection of personal information. This is not only important to us, but it is also the law. To contact our Privacy Officer, email privacy@thrifty.com.au.
Access and Correction
You have a reasonable right to access the personal information we store about you. If you find that the information we hold about you is inaccurate or out of date, then we will correct it. In the case that your personal information changes (such as email address, contact numbers etc) customers can notify our privacy officer to make amendments by emailing privacy@thrifty.com.au or mail to: The Privacy Officer, Po Box 784 Mascot NSW 1460.
At all times Thrifty will give you the right to access your information except to the extent that:
- In the case of personal information other than health information providing access would pose a serious and imminent threat to the life or health of any individual; or
- In the case of health information where providing access would pose a serious threat to the life or health of any individual; or
- Providing access would have an unreasonable impact upon the privacy of other individuals; or
- The request for access is frivolous or vexatious; or
- The information relates to existing or anticipated legal proceedings between Thrifty and the individual, and the information would not be accessible by the process of discovery in those proceedings; or
- Providing access would reveal the intentions of the organization in relation to negotiations with the individual in such a way as to prejudice those negotiations; or
- Providing access would be unlawful; or
- Denying access is required or authorized by or under law; or
- Providing access would be likely to prejudice an investigation of possible unlawful activity; or
- Providing access would be likely to prejudice;
- The prevention, detention, investigation, prosecution or punishment of criminal offences, breaches of a law imposing a penalty or sanction or breaches of a prescribed law; or
- The enforcement of laws relating to the confiscation of the proceeds of crime; or
- The protection of the Public revenue; or
- The prevention, detection, investigation or remedying of seriously improper conduct or prescribed conduct; or
- The preparation for, or conduct of, proceedings before any court or tribunal, or implementation of its orders; by or on behalf of an enforcement body; or
- An enforcement body performing a lawful security function asks the organization not to provide access to the information on the basis that providing access would be likely to cause damage to the security of Australia.
However, where providing access would reveal evaluative information generated within Thrifty in connection with a commercially sensitive decision-making process, Thrifty may give the individual an explanation for the commercially sensitive decision rather than direct access to the information.
If Thrifty has denied access to the individual personal information and has given accurate explanation and the individual is not satisfied, Thrifty will, at the request of the individual, consider whether the use of mutually agreed intermediaries should be engaged. All individuals requiring access to their information will be subject to an enquiry to establish their identity before access is granted to the information.
If Thrifty levies charges for providing access to personal information, those charges;
- Will not be excessive; and
- Will not apply to lodging a request for access
If Thrifty holds personal information about an individual and the individual is able to establish that the information is not accurate, complete and up to date, Thrifty will take reasonable steps to correct the information so that is accurate, complete and up to date.
If the individual and Thrifty disagree about whether the information is accurate, complete and up to date, and the individual asks Thrifty to associate with the information a statement claiming that the information is not accurate, complete or up to date, Thrifty will take reasonable steps to do so.
Identifiers
Thrifty will not adopt as its own identifier an identifier that has been assigned by a government agency (or by an agent of, or contractor to, a government agency acting in its capacity as agent or contractor). Thrifty will not use or disclose an identifier assigned to an individual by a government agency except where paragraphs are applicable in access and correction.
Anonymity
Whenever it is lawful and practicable, individuals will have the option of not identifying themselves when dealing with Thrifty.
However, in most cases with Thrifty, it will not be practicable for Thrifty to provide certain services requested by individuals without identifying themselves.
Transborder Data Flows
Thrifty will transfer personal information about an individual to someone (other than Thrifty or the individual) who is in a foreign company only if:
- Thrifty reasonably believes that the recipient of the information is subject to a law, binding scheme or contract which effectively upholds principles for fair handling of the information that are substantially similar to the National Privacy Principles; or
- The individual consents to the transfer; or
- The transfer is necessary for the performance of a contract between the individual and Thrifty, or for the implementation of pre-contractual measures taken in response to the individuals request; or
- The transfer is necessary for the conclusion or performance of a contract concluded in the interest of the individual between Thrifty and a third party; or
- All of the following apply:
- The transfer is for the benefit of the individual
- It is impracticable to obtain consent of the individual to that transfer;
- If it were impracticable to obtain such consent, the individual would be likely to give it; or
- Thrifty has taken reasonable steps to ensure that the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the National Privacy Principles.
Sensitive Information
Thrifty will not collect sensitive information from an individual unless:
- The individual has consented; or
- The collection is required by law; or
- The collection is necessary to prevent or lessen a serious and imminent threat to the life or health of any individual, where the individual whom the information concerns:
- Is physically or legally incapable of giving consent to the collection; or
- Physically cannot communicate consent to the collection; or
- The collection is necessary for the establishment, exercise or defence of a legal or equitable claim.
Despite the above paragraph, Thrifty may collect health information about an individual if:
- The information is necessary to provide a health service to the individual; and
- The information is collected:
- In accordance with guidelines approved by the Privacy Commissioner under section 95A of the Privacy Act.
- In accordance with rules established by competent health or medical bodies that deal with obligations of professional confidentiality which bind Thrifty.
New Services and Developments
Thrifty will consider the privacy impact of new services before they are introduced.
Compliance Audit
Thrifty will maintain an independent compliance audit program to ensure its privacy protection principles and policies remain appropriate, and that Thrifty operates in compliance with those principles and policies.
Definitions
Identifier
Includes a number assigned by an organisation to an individual to identify uniquely that individual for the purposes of the organisations operations. However, an individuals name or ABN is not an identifier.Individual
Refers to the person whose personal information an organisation holds. The words person or people are used when referring to anyone other than the individual.Personal Information
Means information or an opinion (including information or an opinion forming part of a database) whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.Primary Purpose
The primary purpose is the dominant or fundamental reason for information being collected in a particular person.Privacy Act
Means the Privacy Act 1988 (Cth), as amended from time to time.Related Purpose
A related purpose includes all the purposes that are directly related purposes as well as some additional ones.Secondary Purpose
Secondary purposes are purposes other than the primary purpose that an organisation has in mind for the information it collects. Related and directly related purposes are secondary purposes.


