Privacy Policy

This Privacy Policy applies to the iLinkAir Driver Hub mobile application (“App”), published on Google Play by ILINK247 SOFTWARE PTY LTD.

iLinkAir Driver Hub is a mobile application designed to help drivers efficiently complete checklists, store necessary documents, and streamline their daily operations within the iLinkAir ecosystem.

1.Applicability
WHG Telematics Pty Ltd (WHG) offers a wide range of asset tracking solutions, developed specifically for use within Australia, New Zealand, South Africa, Taiwan and the United States of America. WHG is registered in and subject to the law of Victoria, Australia.

In the context of law, information privacy, personal information, personally identifiable information and information pertaining to a data subject, refer to information that identifies or has the potential to identify an individual.

WHG services are all about information this kind of information and about security. We at WHG understand that information privacy, cannot exist without information security, so We strive to protect Your physical assets and Your information. In doing so it is important that we point out that:

THE VERY NATURE OF TELEMATICS SERVICES MEANS THAT YOU HAVE NO EXPECTATION OF PRIVACY. THE PROVISION OF TELEMATICS SERVICES INVOLVES A LIMITATION ON WHAT YOU MAY REGARD AS A RIGHT TO PRIVACY, BUT WHICH YOU CONSENT TO WAIVE TO SOME DEGREE IN EXCHANGE FOR ANOTHER BENEFIT, SUCH AS, FOR EXAMPLE, PERSONAL SECURITY, ASSET PROTECTION, RISK MANAGEMENT AND ECOMONIC EFFICIENCIES. IF YOU DO NOT CONSENT TO A LIMITATION ON WHAT YOU MAY REGARD AS A RIGHT TO PRIVACY AS DESCRIBED IN THIS POLICY AND THE RELATED TERMS OF OUR TELEMATICS SERVICES, YOU SHOULD CAREFULLY CONSIDER WHETHER TELEMATICS SERVICES ARE RIGHT FOR YOU. IF YOU DO NOT CONSENT OR IF YOU HAVE ANY QUESTIONS, YOU SHOULD NOT USE THE SERVICES OR, YOU SHOULD CONTACT US AT THE INFORMATION PROVIDED IN CLAUSE 10 BELOW SO THAT WE CAN ADDRESS ANY CONCERNS YOU MAY HAVE.

As asset tracking services are inseparable from information privacy, personal information, personally identifiable information and information pertaining to a data subject, and in order to provide high quality services and to earn the trust of customers, WHG (We, Our, Us) elect to comply with the Australian Privacy Act 1988 that regulates the handling of personal information in Australia. Our Privacy Policy (Policy) is published on Our website for the benefit of anyone interested.

2. Personal Information, Privacy and Employee Records
Our Privacy Policy concerns information or an opinion about an identified individual or an individual that
is reasonably identifiable. We make no distinction between employee records and other sources of
personal information. Nor do we discriminate between different forms of personal information (electronic
records, paper records, voice files etc.), nor between whether the information or opinions are true or not.
All personal information that We collect, hold (where We have possession or control of a record), use
and disclose (where the information is outside of Our possession or control) is treated with the same
respect.

For the purpose of this Policy ‘privacy’ and ‘personal information’ have the same meaning, and this
meaning concerns information privacy, personal information, personally identifiable information and
information pertaining to a data subject, information about Your assets, Your asset recovery, Our
telematics services.

3. Scope and Purpose of Collection
This scope of this Policy extends to all personal information that We collect, hold, use and disclose in
the course of providing the WHG services and in complying with law and managing risk.
In providing the services Our business activities include our client relationships, internal operations
(management, employees, temporary staff, contractors) and external operations (third parties such as
business partners and service providers).
The scope of this Policy extends to our services, external client-facing activities such as Our online
presence www.whg-telematics.com.au; www.gridtraqcentral.com.au; www.gridtraq.com.au ; and
https://default.gridtraqcentral.com/, and to the personal information that is collected through Our
Website and the use of email for general communications and marketing purposes.
This Policy does not extend to third party websites or to social media accessed via links on Our Website
or email communications. Use of third party links and social media will be governed by the privacy
policies and terms of use of the applicable service providers.

4. About this Privacy Policy
This Policy is written in simple language so that it is easy to understand. If something is not clear, We
invite individuals to contact Us so that We can provide assistance. Our contact details are provided in
section 10 below. They will also be provided every time that We make contact with an individual.
This Policy outlines the current personal information handling practices of WHG. We will update this
Policy when Our information handling practices change and We will publish updates on Our Website
and through Our email lists.
Whilst We publish Our Privacy Policy on Our Website so that it is easily accessible, We also make
copies available on request in paper format. In most circumstances We do not charge a fee for providing
a copy of the Policy. If however a request is made for a copy in some other format (foreign language
requirements or those linked to disabilities such as sight or hearing impairment), special arrangements
may need to be made and a charge may apply.

5.Consent
In all cases where consent is required, whether it be express consent (verbal, in writing, click-wrap tick
box) or implied consent (browse-wrap without a tick-box and other behaviour which indicates consent
through continued use), it must be voluntary, current, specific and based upon adequate information
about the circumstances and choices available to an individual. Naturally, the individual must have the
capacity to understand, to give (for example be 18 years or older) and communicate consent.
Individuals who are not sure about giving consent are encouraged to contact Us. See section 10 for
contact details.

6.The Australian Privacy Principles Governing the Handling of Personal Information
WHG is committed to making every reasonable effort to manage personal information in an open and
transparent way.

6.1 Open and Transparent Management of Personal Information
To support this commitment, We have implement practices, procedures and systems to align Our
handling of personal information with principles that have been derived from Australian privacy law,
international standards and best practice.

These practices, procedures and systems are intended to regulate Our internal and external business
operations through the use of administrative, technical and physical controls. The legal notices
published on Our Website are examples of Our administrative controls. Technical and physical controls
are generally not made publically available for security reasons.

This Policy, together with Our Website Terms of Use and Email Legal notice, set out how We provide for
open and transparent management of personal information, and give individuals the ability to make
informed choices about the WHG services and communications with Us.

6.2 Anonymity and Pseudonymity
An individual can choose to remain anonymous (they cannot be identified and We do not collect
personal information), or choose to use a pseudonym (they can use a name, term or description that is
different from their own) when dealing with Us.

Circumstances where We give individuals the option to remain anonymous or to use a pseudonym
include, for example, where individuals prefer not to be identified, to be left alone, to avoid direct
marketing, to keep their whereabouts and choices from others, and to express views in the public arena
without being identified.

Examples of circumstances were We Will need to know the identity of the person that We are dealing
with relate to the provision of the WHG services, where identification is required or authorised by law,
where a refund is requested, for dispute resolution, where access to information is requested for
correction and where cost becomes excessive or impractical without knowing the identity of an
individual.

6.3 Collection of Solicited Personal information
We are committed to collecting personal information by lawful and fair means and wherever possible
only collecting it directly from the individual concerned.
We collect personal information from individuals where the information is reasonably necessary for one
or more of the WHG services, functions, activities and legal obligations relating to the service We
provide.

In providing the service to individuals and to organisations, it is generally not necessary to collect
sensitive personal information, unless of course it is directly related to the provision of a service, such as
health and safety related information.

For internal human resourcing, We do collect sensitive personal information, such as religious beliefs,
trade union memberships and health information when it is required for employment reasons, or by law.
We may solicit or request personal information from a third party such as en employment agency or
referees in the context of employment.

In most instances where We collect personal information, We only do so after a direct request to do so,
and with the consent of the individual to whom the information relates. In exceptional circumstance and
for human resourcing, or when authorised or required by law, We may collect personal information from
some source other than the individual themselves.

In circumstances where We provide the WHG service to an organisation, We may solicit personal
information from the organisation about an individual, but We still require the consent of each individual
before their personal information is shared with Us.

6.4 Dealing with Unsolicited Personal information
Personal information is sometimes provided to Us in circumstances where We have not requested it. In
these circumstances, where the information is unsolicited, We will examine whether it could have been
collected under the Policy outlined in section 6.3 above. We will then apply Our minds and decide
whether this unsolicited information should be retained, de-identified or destroyed. Having made that
decision, We will implement the decision within a reasonable time.

We do not actively seek to collect unsolicited information.

IF YOU SUBSCRIBE TO OUR TELEMATICS SERVICES, WE COLLECT INFORMATION ABOUT YOU
AND YOUR ASSET, WHICH MAY BE A VEHICLE, INSEVERALDIFFERENT WAYS, FOREXAMPLE,
FROM:

− WHAT YOU, YOUR ASSET SUPPLIER, VEHICLE DEALER AND MANUFACTURERS

PROVIDE TO US WHEN YOU MAKE A PURCHASE AND SUBSCRIBE TO OUR
TELEMATICS SERVICES;

− BANKS AND FINANCE COMPANIES WHEN YOU BUY OR LEASE YOUR ASSET;
− YOUR USE OF THE SERVICES;
− CALLS, TEXT MESSAGES AND EMAILS BETWEEN US;
− THE INFORMATION YOU PROVIDE WHEN YOU REGISTER A SUBSCRIBER ACCOUNT

ON OUR WHG PORTAL AND SELECT NOTIFICATION PREFERENCES (ALERTS), AS
WELL AS INFORMATION ABOUT YOUR NEXT OF KIN OR PREFERRED CONTACT
PERSON. PLEASE MAKE SURE YOU HAVE CONSTEN TO SHARE THEIR PERSONAL
INDORMATION WITH US.

− OUR UNDERLYING WIRELESS CARRIER; AND
− YOUR ASSET ITSELF WHEN YOUR SYSTEM IS ACTIVE.

BECAUSE YOUR SERVICES ARE PROVIDED THROUGH WIRELESS NETWORKS, WE CANNOT
PROMISE THAT YOUR COMMUNICATIONS WILL NOT BE INTERCEPTED BY OTHERS. YOU
AGREE WE WILL NOT BE LIABLE FOR ANY DAMAGES FOR ANY PERCEIVED LOSS OF PRIVACY
OCCURRING IN COMMUNICATIONS OVER SUCH NETWORKS.

IF YOU DO NOT NOTIFY US OF THE SALE OR TRANSFER OF OWNERSHIP OF YOUR VEHICLE,
WE MAY CONTINUE TO SEND REPORTS OR OTHER COMMUNICATIONS ABOUT YOUR VEHICLE
SUBSCRIPTION ACCOUNT TO THE BILLING ADDRESS CURRENTLY ON FILE WITH US. IN SUCH
A CASE WE ARE NOT RESPONSIBLE FOR ANY PRIVACY-RELATED DAMAGES YOU MAY
SUFFER.

− INFORMATION ABOUT YOU:

∙ INFORMATION WE MAY GET ABOUT YOU INCLUDES THINGS SUCH AS YOUR
ADDRESS, YOUR PHONE NUMBER, YOUR EMAIL ADDRESS, LANGUAGE
PREFERENCE, AND WHETHER YOU ARE HEARING IMPAIRED.

− INFORMATION ABOUT YOUR ASSET, WHICH MAY BE A VEHICLE:

∙ INFORMATION WE MAY GET FROM YOUR VEHICLE INCLUDE THINGS SUCH
AS:

o DATA ABOUT ITS OPERATION (SUCH AS DIAGNOSTIC TROUBLE
CODES, OIL LIFE REMAINING AND ODOMETER READING);

o ABOUT YOUR USE OF THE SERVICES;

o ABOUT WHERE YOUR VEHICLE IS JUST BEFORE WHEN DURING
REQUESTS FOR LOCATION INFORMATION OR SERVICES THAT
INVOLVE A WIRELESS CONNECTION TO YOUR VEHICLE; AND

o DATA ABOUT ACCIDENTS INVOLVING YOUR VEHICLE (DEPENDING
ON YOUR SYSTEM, FOR EXAMPLE, THE DIRECTION FROM WHICH
YOUR VEHICLE WAS HIT AND WHICH AIRBAGS HAVE DEPLOYED).

6.5 Notification of the Collection of Personal Information
This Policy, other legal notices published on Our website and Our internal practices, procedures and
systems (administrative controls) are Our way to ensure that individuals know about the personal
information that WHG collects.

We are committed to making all reasonable efforts to inform individuals about the personal information
We collect before We collect it, for example by making this Policy and Our other Legal Notices available.
We will also inform individuals about collection at the time We collect personal information, for example
when individuals engage Us to provide the WHG services, through website activity (such as cookies and
payment gateways) and other forms of communication such as email.

In exceptional circumstances where this does not happen, for example, when We receive unsolicited
personal information from a third party which We decide to retain, We will inform individuals as soon as
reasonably possible after the collection of personal information.
Through this Policy and other legal notices published on Our Website, We seek to ensure that
individuals are informed about the reasons for the collection, and that they know how to contact the
accountable office bearers at WHG. See section 10 below for details.

6.6 Use or Disclosure of Personal Information
Where We hold personal information about an individual that was collected for a particular purpose (the
primary purpose) We will not use or disclose the information for another purpose (a secondary purpose)
unless required or authorised by law, the individual has consented, or the individual would reasonable
expect Us to use or disclose it for a related purpose. An example of a related purpose in these
circumstances might be disclosure to a next-of-kin or health care provider in the case of an employee.

In some circumstances, for example, where We believe that the WHG service may be improved
through new technologies such as data science, (analytics) or where We see a benefit to individuals,
We may use personal information that has been provided to Us by the individual themselves or received
from third parties for a purpose that is different from the purpose for which it was given to Us in the first
place. Where We do this, We will use and/or disclose the personal information in a de-identified format.

Broadly speaking We use (handle and manage) personal information internally for 2 reasons:

− To provide the WHG service to organisations and to individuals:

o Examples include: Name, address (physical, postal, email and Internet Protocol
address), cookies, change management, assessments and reports [Add more]; and

− For internal human resourcing:

We do not collect biometric forms personal information such a fingerprints.
We also use and retain personal information records which are required to be retained for legal,
business and evidential reasons. Sometimes these come from external sources and third parties.
Broadly speaking We disclose personal information (release it outside of Our possession or control) for
the same primary reasons listed above, providing the service, for human resourcing and where there is
a legal obligation to do so.

IF YOU SUBSCRIBE TO OUR TELEMATICS SERVICES, WE SHARE AND MAY DISCLOSE
INFORMATION ABOUT YOU AND YOUR ASSET, WHICH MAY BE A VEHICLE, IN SEVERAL
DIFFERENT WAYS, AND YOU AGREE THAT WE, SUBJECT TO APPLICABLE LAW, CAN USE ANY
OF THIS INFORMATION THAT WE COLLECT TO:

− PROVIDE SERVICES TO YOU OR YOUR ASSET, WHICH MAY BE A VEHICLE (INCLUDING
BUT NOT LIMITED TO, SHARING THAT INFORMATION WITH ROADSIDE ASSISTANCE
PROVIDERS, EMERGENCY SERVICE PROVIDERS, OR OTHERS, AS NEEDED);
− COMMUNICATE WITH YOU ABOUT YOUR ACCOUNT;
− CHECK OR MAINTAIN YOUR SYSTEM;
− PROVIDE INFORMATION TO THE MAKER OF YOUR VEHICLE ABOUT THE VEHICLE’S
PERFORMANCE, AGGREGATE PRODUCT USAGE, AND INFORMATION GENERALLY TO
ENABLE THE MAKER OF YOUR VEHICLE TO COMPLY WITH LAW;
− PROVIDE INFORMATION ABOUT YOU TO DEALERS AND DEALER ASSOCIATIONS FOR
THEIR OWN USE;
− PROVIDE INFORMATION ABOUT YOU TO OUR BUSINESS PARTNERS (INCLUDING
THIRD PARTY SERVICE PROVIDERS) TO FULFILL ANY REQUEST YOU MAY MAKE AND
TO IMPROVE OUR SERVICE TO YOU;
− HELP YOU TO MAINTAIN YOUR ASSET OR VEHICLE;
− EVALUATE AND IMPROVE OUR SERVICE;
− ENFORCE THIS AGREEMENT WITH YOU OR OTHERS;
− PREVENT FRAUD OR MISUSE OF SERVICE;
− COMPLY WITH LEGAL REQUIREMENTS, INCLUDING VALID COURT ORDERS;
− PROTECT THE RIGHTS, PROPERTY, OR SAFETY OF YOU AND OTHERS;
− OFFER YOU NEW ADDITIONAL PRODUCTS OR SERVICES;
− PERFORM MARKET RESEARCH; AND
− RESPOND TO LEGAL REQUESTS FROM LAW ENFORCEMENT AND FINANCE
COMPANIES ABOUT THE LOCATION OF YOUR VEHICLE AS OTHERWISE PROVIDED IN
THIS AGREEMENT.
THIS LIST IS NOT MEANT TO BE EXHAUSTIVE.
YOU UNDERSTAND THAT FOR QUALITY ASSURANCE PURPOSES AND FOR MANAGING
BUSINESS RISK, WE (AND OUR THIRD-PARTY SERVICE PROVIDERS) MAY MONITOR AND
RECORD CONVERSATIONS BETWEEN OUR RESPECTIVE CONTROL CENTRES (INCLUDING
THIRD PARTY SERVICE PROVIDERS) AND YOUR VEHICLE’S OCCUPANTS. WE (AND OUR THIRD
PARTY SERVICE PROVIDERS) MAY ALSO MONITOR AND RECORD ANY CALLS COMING INTO
OUR (AND OUR THIRD PARTY SERVICE PROVIDERS) CONTROL CENTRE FROM ANY SOURCE.
THEREFORE, YOU AND YOUR VEHICLE’S OCCUPANTS AND ANYONE CONTACTING US ON
YOUR BEHALF:
− CONSENT TO ALL SUCH MONITORING AND RECORDING; AND,
− RELEASE US, THIRD PARTY BENEFICIARIES AND THEUNDERLYINGWIRELESS
CARRIER(S) FROM CLAIMS, LIABILITIES AND LOSSES THAT MAY RESULT FROM
ANY SUCH MONITORED AND/OR RECORDED CONVERSATIONS.
− ACKNOWLEDGE AND AGREE THAT WHILE YOU HAVE CERTAIN RIGHTS UNDER
VARIOUS WORKPLACE SURVEILLANCE LAWS IN AUSTRALIA, YOU ARE
CONSENTING TO SURVEILLANCE AND MONITORING.

6.7 Direct Marketing
When We provide a service to individuals and to organisations, We ask for consent to communicate
directly with the individuals concerned in order to provide information and to promote Our service.
Whenever We do, We allow individuals to opt-out of receiving direct communications and direct
marketing notifications. When individuals request Us to stop communicating with them, We will comply
with that request.

If an individual requests information about how We came to have their personal information, We will
respond, and provide the source of an individual’s personal information wherever possible. We will
respond to these requests within a reasonable time (thirty (30) business days).
We do not disclose, sell or share personal information to third parties for direct marketing purposes.

6.8 Cross-border Disclosure of Personal Information
WHG operates from offices in Australia. These operations include all aspects of internal operations
that support the service that We provide as well as the provision of ‘live’ services (where personal
information travels over telecommunications lines) and the storage of static personal information in
data warehouses and on information systems.

Subscribers to the WHG Telematics Services are located in Australia, New Zealand, South Africa,
Taiwan and the United States of America, but may also be located in or travelling through other
countries, with the result that personal information may flow through these and other jurisdictions..
WHG relies on various third party service providers such as telecommunications providers, and
Internet Service Providers. These are primarily based in Australia, but may also be located in other
countries.

Because information systems enable Our service, personal information may be located or disclosed in
transit and in a static format in countries outside Australia. Whilst We do not currently employ ‘Cloud’
technology services, individuals are nevertheless cautioned to consider how their personal information
moves and is stored on global information systems and to make appropriate choices.

6.9 Adoption, Use or Disclosure of Government Identifiers
We do not adopt, use or disclose government identifiers of an individual as Our own identifiers.
We do use and disclose government identifiers such as Australian Tax File Numbers, for example, for
human resource purposes and where required or authorised by law.

6.10 Quality of Personal Information
We are committed to taking such steps as are reasonable in the circumstances to ensure that the
personal information We collect, hold, use and disclose is, having regard to the purpose of the use or
disclosure, accurate, up-to-date, complete and relevant.

To do this, We ask individuals to assistance Us. We provide various technical means, including email
notifications and user registration access where individuals can access, verify and update personal
information records that We hold. We ask individuals to participate by ensuring their information is
accurate, up-to-date, complete and relevant. Individuals are also encouraged to use the access and
correction facilities that We provide. See sections 6.12 and 6.13.

6.11 Security of Personal Information
We are committed to taking reasonable steps to protect personal information that We hold from misuse,
(wrong or improper use) interference (access even where the content is not necessarily modified) and
loss (accidental, inadvertent, misplaced personal information).

We are also committed to securing personal information from unauthorised access (by someone that is
not permitted access the information), modification (alteration by someone that is not permitted to do
so, or who acts beyond the scope of their authority to modify personal information) and unauthorised
disclosure (where personal information is released from Our effective control without authority).

To comply with law and manage risk, Our practices, procedures and systems aim to protect the
confidentiality, integrity and availability of Our information systems and information, especially the
personal information, that We collect, hold, use and disclose.

Where there is no legal obligation to retain records and evidence, and in circumstances where We no
longer need personal information to provide the WHG services or for any purpose for which the
information may be used or disclosed under Australian law, We take reasonable steps to destroy the
information or to ensure that the information is de-identified.

Our information security and privacy practices include circumstances where Our data handling practices
are outsourced to third parties. Because of this We endeavour wherever possible to bind third party
service providers through appropriate legal agreements. We also endeavour to monitor their privacy and
security practices where possible.

Whilst there is no current obligation upon WHG to notify individuals or regulators of a breach of
personal information, Our policy, in the event of a breach is to inform affected parties in order for them
to better protect themselves from possible damage, for example, by changing passwords.

6.12 Access to Personal Information
Where We hold, or have the right and power to deal with personal information (for example, where it is
stored by one of Our third party service providers), We will, on request by an individual, normally give
that individual access to their information.

We do this so that individuals know what information We hold on them and because it assists Us to
ensure that the personal information that We hold is up-to-date, complete and relevant.
In considering a request for access to personal information by an individual, We will require
identification. We reserve the right not necessarily to give access to an individual to their personal
information in circumstances, for example, where provided for in law, in instances of commercial
sensitivity and where a third party may be negatively affected.

We will respond to an individual’s request for access to their information within a reasonable time (thirty
(30) business days), and We will consider reasonable requests for access to be given in a particular
format, for example, through user registration login, by facsimile, email and postal services. As a matter
of courteousy, We will provide reasons for the refusal if access is refused.

No charge will apply when an access to information request is received. We do however reserve Our
rights to charge a fee where We incur costs, for example, for photocopying, postage and costs
associated with using an intermediary if one is required.

6.13 Correction of Personal Information
Where We hold personal information, We will take reasonable steps to correct it to ensure that, having
regard to the purpose for which We hold it, it is accurate, up-to-date, complete, relevant and not
misleading.

An individual may request that We correct personal information that We hold about them in
circumstance where they believe that the information is inaccurate, out of date, incomplete, irrelevant or
misleading.

In considering a request for the correction of personal information that We hold, We will require
identification of the requesting individual. We reserve the right not necessarily to effect the changes
sought, but undertake to consider reasonable requests and to associate a statement to the record
reflecting Our refusal to correct the failed request for correction if We consider refusal the appropriate
action.

We will respond to a request to change information within a reasonable time (sixty (60) business days)
although changes sought may take longer, for example, because We may need to contact and notify
other organisations and individuals about the request.

No charge applies for making a request, correcting personal information or associating a statement for
refusal to change a record.

As a matter of courteousy, We will provide reasons for the refusal if correction is refused, and also a
reminder of the complaint process available to individuals that feel aggrieved by the refusal.

Complaints, Enquiries and Access to Information Requests
In most circumstances, the Australian Information Commissioner will not investigate a complaint if an
individual has not first raised the matter with Us. For this reason, We ask individuals to agree to submit
all complaints relating to this Policy to Us first, so that We have an opportunity to resolve complaints
before they proceed to any relevant authority. Individuals are asked to direct all complaints and
enquiries to Us at info@WHG.com.au and to see sections 8 and 10 below for further details.

How to make a Complaint, Enquiries and Access to Information Requests
Individuals can make general enquiries, request access to their information and complain to Us in
writing. This includes email communications.
We will respond to complaints within a reasonable time (thirty (30) business days). As in the case of
requests to change information, a longer response time may be needed, for example, because We may
need to contact and notify other organisations and individuals affected by the complaint. In this case We
will endeavor to respond within sixty (60) business days.

Skill, Diligence, Care
WHG will exercise reasonable skill, diligence and care as may reasonably be expected from a
similar service provider.