Redspot Car Rentals > Privacy Policy

Privacy Policy

Welcome to the Privacy Policy of Redspot Car Rentals. Throughout this document Redspot can be also referred to as “we,” “us,” “our,” or “Redspot” in this Privacy Policy. We also operate several franchisees within Australia of which a full list of these companies and contact details is included below: see Data Controllers & Contact Details.

The privacy of our customers, suppliers and contractors is of utmost importance to us. When you rent a car from us, we collect certain information directly from you to determine the terms and conditions of the Rental Agreement that should apply.

Please take the time to read this Privacy Policy as it is important for you to know how we collect and use your personal information. By “personal information” we mean all information that relates to a living individual and either identifies or may be used to identify, that individual.

We may change portions of this Privacy Policy from time to time, so be sure to check back. If we make a change that significantly affects your rights or, to the extent we are permitted to do so, significantly changes how we use your personal information, we will notify you by way of a prominent posting on our websites, e-mail and/or postal mail before the change becoming effective.

Getting Started

We want you to feel comfortable about giving us access to your personal information. Use this Privacy Policy to find out what happens to your personal information when you interact with us and what choices you have.

​This Privacy Policy does not apply to our independent licensees. Please review the privacy notices of our independent licensees for information on how they use the personal information that you provide to them.

This Privacy Policy covers the personal information that we collect, use, and disclose through your use of our products and services either online or offline.

​We need to collect personal information from you to rent a vehicle or provide our other services. We collect personal information when you give it to us, such as by telephone, fax, postal mail, email, at the counter, upon completion of an application or enrolment form or through your use of one of our websites or the use of our products and services.

Please be aware that, in certain circumstances, where you do not provide the personal information required by us, we will not be able to provide the products and services under our contract with you or may not be able to comply with a legal obligation on us. For example, when renting a vehicle with us we will require information such as your name, address, payment information and driver’s licence. If you fail to provide this information to us, we will be unable to rent a vehicle for you. You will be made aware, if this situation arises and what the consequences of not providing personal information will be.

​Sometimes, we will combine the personal information we receive from you with other information we received from other sources so we can provide you with a more customised and hassle-free experience or provide you with offers that are relevant to you. This information may include your name, contact information, travel itinerary, booking request and other information that is relevant to your booking or queries about bookings. These third parties include:

  • Travel agents or a third-party booking service that you used to make your reservation or seek information about your travel needs.

  • You’re employer or association if you are using a corporate account.

  • Our licensees and our affiliates, to create an corporate loyalty account or if you are making a booking in one location served by our affiliates or licensees for rental services in another location served by us; and

  • Police and other law enforcement agencies if you are involved in an accident during your rental, or suffer any loss, damage, or theft of the vehicle, or if you incur any speeding, parking, toll or other traffic-related fines or commit any traffic offences during your rental.

  • Our Licensor: to provide a more tailored global experience wherever you rent

  • Marketing Partners & Channels: to analyse on a macro level & create unique experiences that can best target & tailor for your online journey as well as individuals similar to you.

The purposes for which we use this information is set out in further detail in the rest of this Privacy Policy. There are several bases under the Australian Privacy Act that permit us to use your personal information for these purposes. These are:

  • that you have provided your consent to us using your personal information for that purpose (e.g. where you have given us your consent to send you electronic marketing);

  • that we need to use that personal information to fulfil our contract to provide products or services to you (e.g. using your information for vehicle rentals or join our frequent renter programme;

  • that the processing is necessary for our legitimate interests, provided we have balanced these against your rights and interests;

  • and where we need to comply with a legal obligation (e.g. responding to government or law enforcement information requests).

These legitimate interests are:

  • to ensure effective administration and management of your relationship with us, including any rentals with us;

  • to understand how our customers use our websites and Apps and identify any issues in how the websites and Apps are used and how we can improve the customer’s usage experience;

  • to carry out research and analysis on what services or products customers want or how they would like us to improve our services and products;

  • to understand how our customers use our services and to manage our vehicle fleet;

  • to tell our customers about the various products and services we can offer;

  • understand and respond to customer feedback;

  • to better tailor and personalise the promotions and benefits that we or others offer to our customers;

  • to prevent, detect, or investigate unauthorised use of our vehicles and systems and ensure we comply with the law and our policies;

  • and manage any disputes and accidents and take legal or other professional advice.

  • To tailor our messaging and activity to best meet for how you travel with us

We will collect technical information about your devices when you use our website and App where permitted.

​Renting a Vehicle

When you make a reservation, rent a vehicle or join one of our programs such as a corporate programme or our preferred renter programme, we collect information to provide you with our great services (for example, renting a vehicle, including performing the vehicle rental contract as set out in our General Conditions of Rental, Location Specific Conditions and Rental Agreement, providing any requested optional extras, taking payment, pre-authorisations and security deposits and providing discounts and offers or other benefits) and for our legitimate business interests (for example, research and development of new products and services, undertaking fraud and security checks and enforcing our legal rights). The information we collect includes:

  • name;

  • email address;

  • home address (for licence validation, to find new location to service your needs and billing);

  • employer details and business address (if you are a member of a corporate program);

  • telephone numbers at which we can reach you;

  • date of birth (for licence validation and legal requirements);

  • payment information such as your credit card (security code is obtained for transaction only – we do not keep it);

  • information from driver’s licence and/or other government-issued identification, including if you are an additional driver for the specific rental (for licence validation and legal requirements);.

  • information from another form of identification documentation such as a passport or national identity card if your driver’s licence does not include a photo, is not in English or is not recognisable as you and/or proof of address such as a utility bill (for security and anti-fraud purposes). The information we collect and retain will only include your photo ID where you are informed of this;

  • special discount codes, partner member numbers, association memberships, corporate rewards programs (if you request discounts, special privileges and loyalty programs);.

  • special requests and preferences, including:

    • your preferences regarding optional extras such as damage waivers and other protections;

    • where a delivery or collection service is available, the address where we will drop off or pick up the vehicle and any optional extras you requested; and

  • other information that may be required to rent you a vehicle and/or provide you with services.

Some vehicles come equipped with a global positioning system (GPS) or similar type tracking device that may also collect information about the vehicle. To learn about vehicle data we collect, scroll down to read about Vehicle Data.

If you have an accident, or suffer any loss, theft or damage to the vehicle during your rental or suffer any mechanical failure, we will collect information regarding such incident including your report of the incident and any police or other third-party report including details of those involved, together with the nature of any personal injuries and/or damage to the vehicle and optional extras. We will use this information to perform our contract with you (for example, the vehicle rental agreement and/or the terms of any optional extra like damage liability waivers); for our legitimate business interests (for example, in recovering the costs of any loss or damage caused to the vehicle); for complying with any legal obligation on us (for example, making any required notification of the incident to appropriate authorities); and establishing, exercising or defending legal claims arising as a result of such incident.

​During your rental, we will collect where and when you rented the vehicle, where and when you returned the vehicle, vehicle damage liability preferences, fuel consumption, mileage, accident history and other information related to the vehicle and your use of it. This information is required to provide you with the services you requested under the rental contract or for our legitimate business interests (for example to monitor the usage of our vehicle fleet).

​In addition to the purposes listed above, we use this information to better understand our customers and provide you with relevant offers.

We will also collect information about any speeding, parking, toll or other traffic-related fines that you incur or any traffic offences that you commit during your rental where these are provided to us by any law enforcement agency. We will use this information to deal with such fines or offences per the terms of your vehicle rental agreement with us.

​When you call us (from any phone), we may record or monitor the call for quality control, training, or similar purposes.

We will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact our customer service at the details set out in the Data Controllers & Contact Details section below.

Frequent Renter Programs

If you decide to join our frequent renter programs we will collect and retain your name, contact details, driver’s licence details, and date of birth to create an account for you per the terms and conditions of the program.

​We will use this information, along with information relating to your historic and future rentals, to allow you to take the benefits of membership of the program, including bypass the counter services, the ability to self-service elements of the rental through our Apps, and to provide you with further benefits to which you are entitled under the program such as free upgrades and free rental days.

​We also use this information to tailor the communications we may send to you and/or the promotions we may offer to you as a member of the program from time to time.

​We will also use this information for our internal analysis of how our customers use our services and to improve how we provide our services.

Vehicle Data

Some vehicles you rent from us may have been manufactured or equipped with on-board devices to be connected to the internet (referred to as “connected car,” “telematics,” or “Vehicle to Network V2N”) which allow us to send commands to and receive certain information from the vehicle, including geolocation data from a global positioning system (GPS). If you rent a connected car from us your personal information will be processed per this Notice and any applicable Connected Cars Privacy Addendum included in Part B of the Rental Terms and Conditions which forms part of your rental contract.

Photos & Video

Our rental locations may be equipped with video security surveillance systems as well as cameras that may record as our vehicles depart/enter our lots and these cameras may take images or photos of you, authorised drivers, and passengers.

We may take an image or photo of you and scan your driver’s licence, passport, or another identity document to confirm the information you provided us. In some instances, we use Optical Character Recognition technology to extract data recognised text on the scanned digital image of your identity document to improve processing speed and automatically crosscheck against relevant government databases for validation.

Images of personal identifiable documents are stored securely in line with the Australian Privacy Principles guidelines for no longer than 90 days after the rental vehicle is returned.

Online Data

When you download, visit, and use our websites and/or Apps, we automatically collect technical information. This section tells you more about what technical information we collect and why we collect it.

​IP Addresses & other information collected automatically: We may collect your IP address when you visit our websites to help us diagnose problems with our main computers, for system administration, to report aggregated information to our business partners, and to audit the use of our website. We do not normally link IP addresses to anything personally identifiable. In select circumstances, we may use IP addresses to help us identify you when we feel it is necessary to enforce compliance with our Website Terms and Conditions or to protect our service, site, users or others. We may also collect your browser type, Internet Service Provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/ or clickstream data to analyse trends in the aggregate and administer the site or to provide you with relevant offers.. Furthermore, this information can be utilized for analyzing particular website data in order to enhance your experience, and to optimize targeting and messaging, thereby providing a distinctive online experience for you and other individuals with similar interests both within and beyond our website.

​Session Replay: When you visit our website, we will sometimes also record information about your browsing session on the site, including which pages you visited and any forms on the website that you completed & how you engaged with the site. We review this information to identify any technical issues in the operation of our sites and to improve the user experience of our sites. We use a third party to help us with this service and this information will be passed to that third party for this purpose, but this information is not disclosed to any other third party.

​Cookies & other similar technologies: We may send cookies (pieces of programming) to your computer when you visit our websites. Cookies can be stored on your shared drive or another storage device (persistent cookies) or in memory (session cookies). Cookies enable us to enhance the web offerings to you and to optimise your online experience. We may, in some circumstances, collect your personal information with our cookies or match them to your identity. Persistent cookies identify pages accessed and provide personalised features, for example, choosing which page you would like to make your start page. They are used to help us develop the design and layout of the website, improve applications, measure their effectiveness and understand your personal preferences. Session cookies are used for security purposes as part of our customer identification process. These cookies allow you to be recognised once you have logged in and provide you with confidential access to your rental records. We may also allow third parties (such as Google Analytics) to collect statistical data from our sites using their persistent cookies.

Online Advertising

We use third parties to provide online or electronic ads on our behalf and behalf of our partners. These third parties use data about your visits to our websites and usage to send you customised ads that may be of interest to you. This information is collected using cookies, scripts, pixel tags, tags, web beacons and other similar technologies by us and our third-party advertising partners per our Cookie Policy. Our third-party advertising partners may be located overseas and process data in countries including Singapore, United Kingdom and the United States of America.

Marketing

We may share personal information with third parties (as detailed in the Information Sharing section) to help us with marketing and promotional projects, such as managing our social media pages, running contests, sweepstakes, and other promotions, or sending marketing communications.

​We will only use your personal information to analyse &/or send you marketing where you have given us your consent to receive marketing, or we are otherwise permitted by the applicable law to do so. This marketing will be sent to you either electronically or to your postal address.

Don’t want to receive promotional and marketing posts, emails and text messages from us and our partners? No problem! You can withdraw your consent to direct marketing or tell us you do not want to receive such marketing at any time. See the Your Choices section to find out how.

Analytics

We use analytic software, such as Adobe Analytics, Google Analytics and others, to help us to better understand the functionality of our software on our websites on your device. These software tools record technical information including about your device together with useful information such as how often you use our website or App, which features you use or don’t use in the website App or which pages you visit on the website, aggregated usage, performance data, where the App was downloaded from and information about your visit to the site, including details of some of the URL clickstream to, through and from our website. 

Information Sharing

We may use and share your personal information and vehicle data with affiliated and non-affiliated organisations as follows:

Third party recipient Purpose of disclosure Legal Basis for Processing
Independent licensees / franchisees and network providers in order to perform our contract with you and to understand how you use our services and to improve our business • Make and confirm your rental reservation;
• Provide our rewards program and update partner points and rewards;
• Connect with your corporate and commercial accounts;
• Assist with navigation assistance or itinerary planning;
• Provide customer assistance;
• Resolve toll, traffic or parking violations;
• Processing any claims relating to accidents and/or injuries;
• Providing roadside assistance services;
• To protect or defend the rights or well-being of us, our employees, customers or others;
• Verify safe driver criteria for qualified drivers.		 • Performance of Contract;
• Legitimate Interests;
• Legal obligation;
• Consent; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Your employer or organisation to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business • Verify drivers licences or other government identification.
• Verify eligibility to use designated account and discount codes;
• Connect with your corporate and commercial accounts.		 • Performance of Contract;
• Legitimate interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Travel agents to perform our contract with you when you use a travel agent and to understand how you use our services and to improve our business • Make and confirm your rental reservation;
• Process payments and refunds;
• Assist with navigation assistance or itinerary planning;
• Provide customer assistance;
• Providing roadside assistance services;
• To protect or defend the rights or well-being of us, our employees, customers or others.		 • Performance of Contract;
• Legitimate Interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Brokers to perform our contract with you when you book a rental through their service and to protect our business from fraud and bad debts • Make and confirm your rental reservation;
• Process payments and refunds;
• Provide customer assistance;
• Handle debt collection;
• Fraud check.		 • Legitimate Interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Our franchisor Enterprise Holdings Inc and other Enterprise Companies in the United States and United Kingdom. • Make and confirm your rental reservation;
• Process payments and refunds;
• Connect with you to obtain after rental surveys via phone, text or email;
• Assist with navigation assistance or itinerary planning;
• Provide customer assistance;
• Connect with your corporate and commercial accounts.		 • Legitimate Interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Credit card issuers to obtain payment from you • Process payments and refunds;
• Fraud check;
• Handle debt collection.		 • Performance of Contract;
• Legitimate Interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Booking engines to perform our contract with you when you use a booking engine and to understand how you use our services and to improve our business • Make and confirm your rental reservation.
• Verify eligibility to use designated account and discount codes;
• Process payments and refunds;
• To protect or defend the rights or well-being of us, our employees, customers or others.		 • Performance of Contract;
• Legitimate Interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Corporate account manager to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business If you are renting with a corporate, membership or other similar commercial entity account, we may share personal information with the organisation that manages the account for their own purposes. We recommend you review their privacy policy to learn more about their privacy practices. • Performance of Contract;
• Legitimate interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Marketing agent to provide you with benefits of a corporate or association program and to understand how you use our services and to improve our business • Provide our rewards program and update partner points and rewards;
• To protect or defend the rights or well-being of us, our employees, customers or others.		 • Performance of Contract; Legitimate Interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
IT service providers including IT platform providers and website analytics service providers to perform our contract with you and to understand how you use our services and to improve our business • Support our IT systems and infrastructure;
• Provide maintenance services for our IT systems and infrastructure;
• Provision of data hosting and other data processing services;
• Provide analytics services relating to your use of our website to identify any technical or user interface issues and/or improvements in connection with the website		 • Legitimate interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Government, regulatory and law enforcement agencies to meet our legal obligations • To verify your driver’s licence and ensure you meet our safe driver criteria;
• As requested by these agencies if the disclosure is required or permitted by law;
• To take action regarding illegal activities, traffic offences or violations of terms of service;
• If we have a good faith belief that there is an emergency that poses a threat to the safety of you or another person; and
• As otherwise required or permitted by law.		 • Legal requirement;
• Legitimate interests; or
• We may disclose personal information for other purposes permitted under the Australian or New Zealand Privacy Principles.
Insurance companies and claims handlers in respect of any insurance product or coverages you purchase in connection with your rental • Provide and service the insurance product or coverages you have requested;
• Manage any claims that may be made under the relevant insurance policy		  

We may also transfer or assign your personal information to third parties because of, or in connection with a sale, merger, consolidation, change in control, transfer of assets, bankruptcy, reorganisation, or liquidation. Or if we are involved in defending a legal claim, information about you that is relevant to such claim may be disclosed to third parties because of, or in connection with, associated legal proceedings.

We may, per the Marketing section, share your information with business and promotional partners (where you have provided your consent to such information-sharing) to send you information about products and services you may like. If you decide you no longer want to receive such promotional and marketing messages, please read the Your Choices section to find out how you can opt out.

Your Choices

If you want to opt-out of receiving promotional and marketing emails, text messages, posts, and other forms of communications from us or our promotional partners concerning which you might receive per the Marketing section, you can best opt-out by using one of the following ways:

  • Click “unsubscribe” at the bottom of an email we sent you.
  • Go to our Data Controllers & Contact Details By Country section to email the customer service representative suited for you.

If you do opt-out of receiving promotional and marketing messages, we can still contact you regarding our business relationships with you, such as account status and activity updates, survey requests in respect of products and services we have provided to you after you rent from us, reservation confirmations or respond to your inquiries or complaints, and similar communications.

Please also see your rights set out in the “Your Privacy Rights” section.​

Safeguards

The security of your personal information is important to us. We take reasonable steps to make sure your information is protected from unauthorised use, access, disclosure, alteration, destruction or loss. For financial or payment information, we use firewalls and Transport Layer Security (TLS) encryption. We take security extremely seriously but as no system is 100% secure, we can’t completely guarantee the protection of your personal information, any more than any other organisation can.

We do not ask for financial or payment information, such as your credit card number, passcode, account number or PIN, in an e-mail, text or any other communication that we send to you.

You are responsible for keeping your account passcode, membership numbers and PINs safe and secure. Don’t share those with anyone. If there is unauthorised use or any other breach of security involving your information, you must notify us at the customer service contact information below as soon as possible.

Information Retention

We keep your personal information for no longer than is reasonably necessary or required by law. How long we keep it depends very much on the type of information and purpose.

The criteria we use to determine the retention period for certain categories of data is as follows:

  • the length of time that you are a member of our frequent renter programme or any other loyalty scheme that we operate or a member of any corporate programme;
  • how frequently you rent with us or when your most recent rental occurred;
  • whether there are contractual or legal obligations that exist that require us to retain the data for some time;
  • whether there is an ongoing legal claim that relates to any rental you have made with us, or that is otherwise related to your relationship with us;
  • whether any applicable law, statute, or regulation allows for a specific retention period;
  • whether the personal information is a special category of personal information, in which case a shorter retention period generally would be applied; and
  • what the expectation for retention was at the time the data was provided to us.

International Transfers

Rentals
As we offer the ability to rent vehicles and benefit from our services in many locations globally, we will transfer your personal information to our affiliates, independent franchisees, and travel agents in these locations to fulfil your rental request and/or enter into a rental agreement or provide you with services and other offers.

​Many of the countries to which your personal information may be transferred for these purposes that are located outside Australia or New Zealand do not benefit from an adequate decision issued by the EU Commission regarding protection afforded to personal information in that country. Details of these specific countries can be found here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.

​These transfers are made either as they are necessary for the performance of a contract to which you will be a party, or for pre-contractual measures. Alternatively, the adequacy of data protection is ensured by standard data protection clauses that we have in place with the relevant recipient.

​Business operations
In addition, the information we collect from you may be transferred to and stored by, IT vendors who operate on our behalf. These include our booking engine hosting provider that is in the United States. We also transfer information to several providers of business applications – such as CRM and marketing applications – as well as marketing service providers. These providers are primarily located in the United States.

Adequacy of data protection is instead ensured by standard data protection clauses we have in place with that third party.​

Your Privacy Rights

You may have – per applicable data protection laws – the following rights when it comes to our handling of your personal information:

  • Right of access – you may have the right to request a copy of the personal information we have about you and to request supporting information explaining how the personal information is used.
  • Right of rectification – you may have the right to request that we rectify inaccurate personal information about you.
  • Right to withdraw consent – where we process your personal information based on consent (including direct marketing consents), you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal, we may continue to use your personal information as permitted or required by law.

Right to complain:

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Data Protection Officer in any of the ways set out in the Data Controllers and Contact Details and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period depending on the complexity of the complaint.

Companies

This privacy policy applies to the following companies, which are all entities of the Australian and New Zealand franchise.

Redspot Head Office Pty Ltd: 60 607 643 416

Rent A Car Holdings Pty Ltd: 44 611 220 207

Redspot New Zealand Pty Ltd: 9429042239932

Redspot Franchising New Zealand Pty Ltd: 9429042239956

Redspot Franchising Pty Ltd: 13 164 739 708

WCC QLD Pty Ltd: 64 603 065 729

WCC NSW Pty Ltd: 41 604 481 021

WCC VIC Pty Ltd: 50 604 464 931

JR Car Rentals Pty Ltd: 12 629 047 909

Eagers ACT Rentals Pty Ltd: 50 658 934 224

Hastings Co-Operative Pty Ltd: 86 601 035 121

Cedrent Enterprises Pty Ltd: 32 611 325 912

Cedrent Enterprises (WA) Pty Ltd: 22 645 551 640

Redspot Fleet Pty Ltd: 27 606 584 614

Top Dog Finance Pty Ltd: 33 603 281 812

Waterloo Car Centre Pty Ltd: 19 003 616 420

Data Controllers and Contact Details

If you are making a rental or visiting a local country version of our websites or mobile sites in the following countries, the data controller is listed in the table below.

You can also contact our Data Protection Officer in respect of any issues or questions you have regarding our processing of your personal information. They act as the Data Protection Officer in respect of all the data controllers listed below and can be contacted at:

Email: [email protected] 

Postal Address: Data Privacy Officer, Redspot Head Office, 7 Coleman Street, Mascot, NSW 2020

Telephone: +61 (2) 8303 2293

Updated: 23/11/2023