Last updated: January 2021
1 Our Privacy Commitment
1.1 At Transurban (USA) Holdings Inc. and Transurban DRIVe Holdings LLC, we take privacy seriously. We consider our Privacy Policy to be an important document, and we hope that you take the time to read it carefully.
1.2 Our Privacy Policy outlines the commitment of Transurban (USA) Holdings Inc., Transurban DRIVe Holdings LLC, and each of their respective Subsidiaries (“Transurban” or “we”, “us” or “our”) to protect the privacy of our customers’ personal information and other personal information we receive in the conduct of our business.
2 What does our Privacy Policy do?
2.1 Our Privacy Policy describes how we look after the personal information we collect, including the kinds of personal information we collect, why we collect it, and how we hold, use and disclose it.
2.2 By using our products or services or by providing personal information to us, you agree to be bound by the terms of our Privacy Policy and consent to the use and dissemination of such information in accordance with this Privacy Policy.
2.3 We may need to change our Privacy Policy from time to time. If we do, we’ll post the updated version on this page and on each relevant retail brand website. The updated version will take effect from the date stated at the top of the Privacy Policy.
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.
2.5 We encourage you to check our website from time to time to ensure that you are aware of our current Privacy Policy and how it applies to you.
3 What information do we collect?
3.1 We collect information to provide better 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 Transurban or its Subsidiaries provide tolling or billing services, or if you have a customer account with us, we will collect additional personal 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 and use of public transport.
3.7 We may record and monitor telephone calls and other communications between you and us for training, quality control, verification and compliance purposes.
3.8 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.
3.9 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.
3.10 We collect information about people who visit our sites and our offices. This may include photographs and videos of you when you are in or near our sites or offices.
4 What information do we collect when you use our online services?
4.1 This section applies to use of online services that we control, such as websites, Apps, social media and other online services. We may receive information about you from third-party services, from our related companies and from our business and channel partners.
4.2 When using our online services, we and our technology partners may collect information about you and how you use our online services.
4.3 We may collect information such as:
(a) user name and password.
(b) which services you use and how you use them.
(c) device information, such as the model and ID of the device you use, operating system, telephone number and mobile phone network.
(d) server log information, such as details of how you used the service, IP address, hardware settings, browser type, browser language, the date and time of your use and referral URL.
(e) cookies that may uniquely identify your browser or your account (please see clause 4.4 below).
(f) location information (which we may use for location-based advertising, such as delivering ads regarding third-party services and offers near your location).
4.4 You can restrict our access to and collection of the location of your mobile device by disabling location-sharing on your mobile device, if that feature is available. Some of our online services may require access to and collection of the location of your mobile device. So, if you disable location-sharing, you may not be able to access or use certain of our online services.
4.5 Transurban and our third-party partners may use cookies and other similar tracking technologies (e.g., web beacons, device identifiers and pixels). Cookies are small pieces of data stored on the web browser of your device. These are used by us for site administration and analysis purposes and to deliver tailored content and online behavioral advertising. Online behavioral advertising involves collecting information about your online activities over time and across different websites and apps in order to infer your preferences and interests. Such advertising may include combining information from different browsers and devices. We may use the information we collect via cookies and similar technologies for retargeting, which involves delivering on Transurban and third-party digital services advertisements regarding offerings you have viewed on Transurban sites and apps. For example, if you review content regarding one of our mobile applications, we or our partners may deliver ads regarding the application when you access Transurban or other digital services. If you wish not to take advantage of cookies, you may configure your browser not to accept them (although this may disable or render unusable some of the features of our online services). We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. You can decide whether to accept or reject cookies. You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. You can learn more about online behavioral advertising and opt-out of receiving some targeted ads by visiting www.aboutads.info. If you do not want to receive online behavioral advertising in our mobile apps, you can limit or turn off mobile device ad-tracking in your device settings on each of the devices you use, if your devices have such settings. Alternatively, you can uninstall our apps from your devices.
4.6 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.
4.7 Our online services may use third-party services and we may disclose your personal information to such service providers, including Google services (such as Google Analytics, Google Ads, Invisible reCAPTCHA and Google Maps). For example, if you allow our online services to access to your device location, our website or App may use Google Maps to collect your location and locate nearby stores. For more about how Google collects and processes data, please see Google’s Privacy Policy, Google Terms of Service and their information on how Google uses your data.
4.8 From time to time, we may may collect, or 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. Once we receive personal information from third parties, we treat the information as subject to this Privacy Policy.
4.9 Our online services may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. The privacy practices applicable to other websites may differ substantially from ours. Please read the privacy policy of any other websites you visit before using them.
5 How do we collect information?
5.1 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, where we ask you to provide certain personal information, or when you are providing comments or feedback on any of our online services.
(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) mobile applications and websites, including where you have agreed to disclose information about your location while using one of our websites or Apps.
Please see section 4 above for information we collect when you use our online services.
(c) When you visit our sites or offices. For example, we may photograph 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, public 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 people who refer 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 their service providers.
(iv) other U.S. toll-road operators to support your use of roads via roaming arrangements between operators.
(v) researchers.
(vi) suppliers of information products and services (such as companies that consolidate data from multiple public sources).
5.2 When you use or interact with social media tools on our services (e.g., using your social media credentials for single sign-on, or using like or sharing tools), the associated social media platform may share personal information with us, such as your publicly available profile information. The information we collect is determined by the privacy and account settings with the social media provider. Please consult your social media providers’ privacy disclosures and settings for more information.
5.3 If you provide us with personal information about someone else, you must only do so if that person consents to you doing so and to us collecting, holding, using and disclosing their personal information in accordance with our Privacy Policy.
5.4 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.
6 How do we use your personal information?
6.1 We use and disclose your personal information:
(a) to provide better products, services and information to our customers and to the community.
(b) for the purposes for which it was collected, which can include in certain circumstances, feedback and other online forms or comments that with notice to you and/or further consent from you, we may make public (e.g., your comments on online services supporting certain projects or initiatives, or where we offer interactive forums such as blogs or message boards). We may also provide your information to governmental entities or third parties not only as described in section 7 below but also for specifically stated purposes (e.g., if part of a petition process).
(c) in order to provide and improve our products and services.
(d) in order to operate and improve our roads and customer service experience, 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 or third parties’ products or services or the products or services of third parties, including from our retail brands, business or strategic 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 investigate or to pursue any legal claim that we may have against you.
(m) for road safety purposes.
(n) for security purposes.
(o) to assist the enforcement of laws.
(p) to undertake traffic planning and vehicle management services.
(q) to meet our obligations and perform our functions under applicable laws and agreements.
(r) to detect, prevent and investigate any fraud or crime (or suspected fraud or crime).
(s) to notify you of changes to our tolls, fees, charges, agreements, products or services.
(t) to otherwise contact you.
(u) as otherwise required or authorized by law.
6.2 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. In some instances, such analysis and initiatives may be undertaken by third-parties. As noted in section 6.1(b) above, we may post comments you submit in online forms or forums on our online services, which we will do after providing you notice and/or obtaining your consent. We may further disclose such information as described in section 7 below.
6.3 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.
6.4 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.
7 Who do we disclose your personal information to?
7.1 We may disclose your personal information:
(a) subject to any restrictions imposed by any relevant legislation, among the Transurban entities named in this Privacy Policy, their related entities (including related entities located in Australia) and their retail brands.
(b) to our related bodies corporate.
(c) under information sharing arrangements with the operators of other U.S. toll-roads.
(d) to government agencies, such as government agencies responsible for the operation of roads, transport or emergency services.
(e) to any entity responsible for the collection of tolls or the taking of enforcement action concerning use of our roads.
(f) to anyone who acquires or considers acquiring our assets or business (or any part of it).
(g) where you have consented, including to a secondary contact nominated on your account.
(h) as required or permitted by law, for example, in response to a subpoena, warrant, or request from a government law enforcement agency, or as required under legislation and regulations applying to our roads.
(i) to the Tolling Customer Ombudsman.
(j) to insurance companies in the event of a road incident or similar circumstance where your information is relevant to a potential claim.
(k) to our consultants, contractors, subcontractors, suppliers, service providers, professional advisers and agents, such as:
(i) call center operators.
(ii) mailhouse, printhouse and warehouse organizations.
(iii) marketing, advertising and information service providers including social media services and data supply companies.
(iv) legal and accounting firms.
(v) contractors that own or operate distribution outlets (such as convenience stores and electronic kiosks).
(vi) banks, financial institutions and payment processing providers.
(vii) towing, roadside support and maintenance and logistics contractors (such as if you or your vehicle are involved in or near a road incident).
(viii) engineers and surveyors.
(ix) researchers and investigators.
(x) debt collection companies and credit reporting bodies.
(xi) information technology suppliers that provide support, maintenance and upgrade services for our systems.
(xii) third-party business and strategic partners.
7.2 When you engage with social media tools on our digital properties (e.g., single sign on, or like or sharing tools), the associated social media provider may receive information about your interactions and activities on our properties. Please consult the privacy policies of your social media providers for more information.
7.3 In certain circumstances, you may declare that another person operated your vehicle on one of our toll roads. If this occurs, we may contact that person and inform them of your declaration.
7.4 Other U.S. operators. We may exchange certain personal information with other U.S. toll-road operators. For example, if you open an account with us, we may use and disclose your personal information for the purposes of facilitating your travel on our roads and any other U.S. toll-roads with whom we have roaming arrangements in place. Such roaming agreements allow the operators of those roads to obtain payment for travel when you travel on their roads.
7.5 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.
7.6 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 Do we de-identify information?
8.1 We may de-identify information about an individual so that the information can no longer be related to that individual.
8.2 We may then use and disclose that de-identified information in the course of our business.
8.3 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.
8.4 We may then use and publicly disclose such aggregated information in the course of our business.
9 When do we disclose information overseas?
9.1 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 certain countries outside your jurisdiction and may disclose certain personal information to those contractors.
9.2 Those countries may not provide the same level of protection for personal information as your home country and the information may be available to local government agencies in those countries.
9.3 We may also disclose certain personal information to our related entities in Australia, 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.
9.4 We will only transfer personal information to a recipient in a foreign country in circumstances where the information will have appropriate protection. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy policy when transferred or stored outside of your country of residence. Where we have engaged international third parties to perform services in respect of any personal information collected from you, we will use contractual or other means to ensure such third parties offer a comparable level of protection in respect of the personal information.
10 How do we secure your information?
10.1 We use reasonable safeguards and security measures to ensure personal information we hold about you is protected from risks such as misuse, interference, unauthorized access, modification or disclosure. We use a number of technical, organizational, administrative, physical and electronic measures to protect your personal information.
10.2 However, the Internet is not a secure environment. We cannot guarantee the security of information provided to us via electronic means or stored electronically, consequently, using websites, Apps, social media and other online services is at your own risk.
10.3 Personal information is only retained for as long as is necessary for the identified purposes or as required by law.
11 How can you access and correct your information?
11.1 To request access to personal information that we have about you. You may do so by contacting us.
11.2 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. Prior to supplying you with access to your information, we will inform you of the estimate of the costs and allow you an opportunity to respond.
11.3 When you request access to personal information, we may need to take measures to verify your identity before providing you with such information.
11.4 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. And we may not provide you with personal information if collecting the information would prove burdensome (for example, it would be prohibitively costly to provide such personal information). If we do not provide access to the personal information held about you, we will tell you why.
11.5 We take reasonable steps to ensure the personal information we hold about you is accurate, complete, up-to-date, relevant and not misleading.
11.6 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.
11.7 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.
12 What information do we collect when you apply to work with us?
12.1 When you apply to work with us, we may collect certain information from:
(a) you.
(b) recruitment consultants.
(c) your previous employers.
(d) your references.
(e) other sources of relevant information, such as educational institutions, professional and trade associations, referees and publicly available sources.
12.2 The information we collect will assist us to decide whether to make an offer to you to work with us.
12.3 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
(c) skills.
(d) character.
(e) eligibility to work.
12.4 As necessary to comply with applicable laws or where appropriate for the position sought, we may require you to undergo certain medical checks. Where such information is relevant to the position sought, we may carry out screening checks (such as background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
13 Data Retention
13.1 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.
13.2 When we have no ongoing legitimate business need to process your personal information, we are committed to either deleting or de-identifying it.
14 Our Policy towards children
14.1 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.
15 Complaints and further information
15.1 If you want to talk to us about your privacy please contact the Transurban U.S. Privacy Officer by email on [email protected]. We are happy to discuss how we handle your personal information, how your personal information is collected or about any other aspect of our Privacy Policy.
15.2 If you are concerned about the way we deal with personal information, please contact us in writing. Please:
(a) include your contact details (such as email address, name, address and telephone number).
(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 U.S. Tolling Customer Ombudsman.
For further information about our Privacy Policy or practices, please visit our website at www.transurban.com and the website of the retail brand relevant to you.
Alternatively, you can contact the Transurban U.S Privacy Officer by email at [email protected].
You can also contact us.
This Privacy Policy applies to the following entities:
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each of Transurban (USA) Holdings Inc. and Transurban DRIVe Holdings LLC and each of their respective Subsidiaries.
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all the retail brands that operate under those Transurban entities, including but not limited to 95 Express Lanes, 395 Express Lanes, 495 Express Lanes and GoToll.
Subsidiary means, any corporation, partnership, limited liability company, trust or
other domestic or foreign form of business association or organization which Transurban (USA) Holdings Inc., or Transurban DRIVe Holdings LLC, directly or indirectly, either (a) has the power to vote or direct the voting of sufficient securities to elect a majority of the directors (or to control the operations and governance of such entity in a similar manner) or (b) in the case of a partnership, serves as the general partner or holds a majority of the partnership interests.
We are proud to operate the following retail brands: 95 Express Lanes, 395 Express Lanes, 495 Express Lanes and GoToll