Reta Privacy Policy

1.1. This mobile application (Reta App) is created and controlled by Reta (Returns and Tracking) Pty Ltd (ACN 693 126 108) (we, us or our).

1.2. We are committed to ensuring your personal information is protected. We manage your personal information in accordance with the Australian Privacy Principles set out in the Privacy Act 1988 (Cth) (Privacy Act).

1.3. By accessing and using the Reta App, our website and any products and services made available through the Reta App you agree to this Privacy Policy.

1.4. This Privacy Policy outlines how we collect, store, use and disclose your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

1.5. This Privacy Policy outlines how Reta collects, stores, processes, shares, uses and discloses your Personal Information, and how you may access your Personal Information kept by us or how you may make a privacy complaint.

1.6. Unless defined in this Privacy Policy, capital terms have the meaning in the Driver Terms and Conditions and the Customer Terms and Conditions.

2.1. Personal information has the same meaning that it has under the Privacy Act, namely, information means information or an opinion about an identified individual or an individual who is reasonably identifiable, whether the information or opinion is true or not and recorded in a material form or not.

2.2. We will only collect and hold Personal Information about you that is reasonably necessary to undertake our business activities and functions, deliver the Reta App and our other products and services to you, or as otherwise permitted by law.

2.3. The type of Personal Information that we collect and use depends on the type of dealings that you have with us and includes the following:

1. Customer registration details (for example, full name, address, mobile and telephone numbers and email address) and account credentials (such as your username and password);
2. information relating to a Customer’s use of the Reta App (such as Reta Jobs published or posted on the Reta App, information relating to the Permitted Goods that are handled by our network of Drivers and a Customer’s geolocation information);
3. Driver registration details (for example, full name, address, mobile number and email address, profile picture, driver license, evidence of roadworthiness, and vehicle registration number, national police check, ride sharing driving history, insurance details and other information necessary to identify your suitability as a driver, dashcam footage and bank details) and account credentials (such as your username and password);
4. information relating to a Driver’s use of the Reta App (such as the Driver’s Reta Job history, the fees earned by Drivers for completing Reta Jobs and the service fees paid by the Driver to Reta and the Driver’s geolocation information collected when using Tracking Technology on the Reta App).
5. communications you send to us or other users of the Reta App (such as to report a problem or complaint about the Reta App, a Customer or Driver, or to submit queries, concerns, or comments regarding the Reta App or its content);
6. payment and billing information;
7. marketing data and information relating to your dealings, or enquiries you have made, with us, including information about:
   1. the products and services you have accessed and used;
   2. the third party products and services you have used or enquired about; and
   3. what features or functions of the Reta App you have used and how they have used such functions and features;
8. device information which is automatically collected from you when you visit and navigate through the Reta App and our website. Such information may include, but is not limited to, your device type, your device’s network connections, unique device identifier, your device’s name, your device IP address, screen size and calibration, information about your device’s web browser and internet connection you use to access the Reta App and our website, geolocation information, browser characteristics, device characteristics, operating system and language preferences, dates and times of visits to the Reta App and our website and other usage statistics; and
9. other information that you provide to us or that we may collect in the course of our relationship with you.

2.4. We may also collect some information that is not Personal Information because it does not identify you or anyone else. For example, we may collect anonymous answers to surveys or aggregated information about how users interact and use the Reta App.

2.5. We do not collect your Sensitive Information (as defined by the Privacy Act). If you have accidentally sent us Sensitive Information, please contact us to remove, delete or block the Sensitive Information using the details below.

3.1. We will collect Personal Information about you in a number of different ways. We may collect Personal Information directly from you or in the course of our dealings with you. For example, when:

1. you (as Customer and/or Driver) download, access and use the Reta App (including when you open or close an account or update your account on, or via, the Reta App);
2. a Customer posts, publishes or submits a Reta Job requiring the services of a Driver to return Permitted Goods on, or via, the Reta App, makes payment to us in connection with the Reta Job and when the Reta Job has been completed;
3. a Driver accepts, performs and completes a Reta Job and provides us with dashcam footage in response to a complaint, accident or investigation;
4. Customers and Drivers contact, connect or communicate with each other (in person or on, or via, the Reta App);
5. when you visit the Reta App and/or our website or when you submit information or a query through the Reta App and/or our website (including on, or via, our related social media accounts), contact us, or complete any online forms or documents or when you enter or participate in competitions, promotions, events, sweepstakes, surveys and questionnaires; and
6. when you lodge a complaint about another user, the Reta App or any other ancillary products or services made available through the Reta App; or
7. when otherwise legally authorised or required to do so.

3.2. When we collect Personal Information directly from you, we will take reasonable steps to notify you (using a collection notice) at, before, or as soon as practicable after, the time of collection.

3.3. By providing your Personal Information to us, you acknowledge that you are authorised to provide such information to us.

3.4. We may also collect Personal Information about you from publicly available sources and third parties, including:

1. when you provide your Personal Information to our Third Party Providers or other third parties or when you provide Personal Information to other users of the Reta App;
2. when you use our social media sites or applications, pages or plugins or third party products or services that interact with the Reta App, our products and services (such as our third party payment processors).

3.5. When we collect your Personal Information from third parties, we shall take reasonable steps to make sure you are aware of the collection.

3.6. If you provide us with Personal Information about another individual (as their authorised representative), we rely on you to:

1. inform them that you are providing their Personal Information to us; and
2. advise them that they can contact us for further information.

3.7. You must take reasonable steps to ensure the individual is aware of, and consents to, the matters outlined in this Privacy Policy, including that their Personal Information is being collected, the purposes for which that information is being collected, the intended recipients of that information, the individual's right to access that information, and who we are and how to contact us.

3.8. Upon our request, you must also assist us with any requests by the individual to access or update the Personal Information you have collected from them and provided to us.

4.1. We only use, process and disclose your Personal Information for the purposes for which it is collected. We do not sell or trade your Personal Information. We use, process and disclose your Personal Information and Non-Personal Information to:

1. provide or deliver the Reta App and our products and services to you, including, without limitation, to provide the means through which Customers can connect with available Drivers for the purpose of engaging a Driver to return Permitted Goods. For example, we use and disclose:
   1. geolocation information of Drivers for the purpose: (i) providing Customers and Drivers with information relation to active Reta Jobs (such as where the Driver is and the Driver’s estimate arrival time at the collection point); (ii) of matching and assigning inactive Drives to Customers who have listed Reta Jobs; and (iii) of investigating any complaint or accident involving the transport of the Permitted Goods by the Driver; and
   2. dashcam footage of the Permitted Goods for the purpose of investigating a complaint or accident involving the transport of the Permitted Goods by the Driver;
2. determine an individual’s suitability to open a Driver Account or continue to hold a Driver Account;
3. provide or deliver our website to visitors or users;
4. informing you about the Reta App, our other products or services or about offers, competitions, promotions, events, sweepstakes, surveys, questionnaires about us, the Reta App or other matters which we believe are of interest to you (such as recruitment or job opportunities);
5. manage, administer, improve, test, develop and upgrade the Reta App and our other products and services, informing you about scheduled maintenance or outages and managing our relationship with you or to otherwise investigate complaints about the Reta App and/or other users of the Reta App;
6. share with our Third Party Providers;
7. charge and bill Customers and Drivers when they use the Reta App;
8. verifying your identity;
9. for internal record keeping;
10. for direct marketing purposes (see below);
11. complying with our legal and regulatory obligations;
12. for any purpose to which you have consented; and
13. for any other purpose notified to you at the time of collection.

4.2. In the event of a merger, acquisition or sale of the whole or part of our business or assets, we reserve the right to transfer your Personal Information as part of the transaction, without your consent or notice to you.

5.1. In order to provide or deliver our products or services to you we may disclose your Personal Information to:

1. our related bodies corporate, business partners, service providers, third party contractors, agents or suppliers, external business advisors or other authorised external service providers who perform functions on our behalf (such as credit reporting bodies, credit providers, third party payment processors, hosting companies, web developers, internet service providers, telecommunication providers, customer service providers, customer support specialists, fulfilment companies, external business advisors (such as auditors and lawyers), AI chatbot service providers, geolocation service providers, government agencies, public registries, search agencies, regulatory and licensing bodies, parties to whom you refer us to (for example, previous employers and referees), recruitment agencies and from publicly available sources of information (for example, online databases and social media) (collectively, Third Party Providers); and
2. law enforcement bodies or regulatory authorities to assist with their functions, or as otherwise required or authorised by law.

5.2. We use a third party payment processor to process payments made to us or to you. In connection with the processing of such payments, we do not collect, process, use, share, store or disclose any Personal Information or payment information (such as credit card and bank account details). Rather, all such information is provided directly to our third party processor, Stripe whose use of your Personal Information is governed by their privacy policy, which may be viewed at https://stripe.com/au/privacy.

5.3. Prior to the disclosure of Personal Information to Third Party Providers, we will take such steps as reasonable in the circumstances to ensure that the Third Party Providers treat your Personal Information securely and otherwise complies with the relevant Australian Privacy Principles in relation to the Personal Information.

6.1. We may use and disclose your Personal Information to send you information about the products or services we offer, on or via, the Reta App, as well as other information that may be of interest to you. We may send this information in a variety of ways, such as by mail, email, SMS, telephone, social media or by customising online content and displaying advertising on our website.

6.2. If you do not wish to receive any of these marketing communications, you can opt out by following the unsubscribe instructions included in the relevant marketing communication, or by contacting us using the contact details set out in section 12 below.

7.1. In the course of providing you with our products or services, it may become necessary or desirable to disclose Personal Information to Third Party Providers located overseas. The countries in which these overseas recipients may be located will depend upon the individual circumstances. However, in the course of our ordinary business operations we commonly disclose Personal Information to:

1. our third party payment processor (Stripe) located in the Unites States and India;
2. our geolocation service providers (Google’s Places API) located around the world.

7.2. The laws where these overseas recipients may be located provide various levels of protection for Personal Information which are not always equivalent to the level of protection that may be provided for in Australia. Where we transfer your Personal Information overseas, we will take reasonable steps to ensure that your Personal Information is treated securely and the means of transfer provides adequate safeguards.

8.1. In the event of any loss, or unauthorised access or disclosure of your Personal Information that is likely to result in serious harm to you, we will investigate and notify you and the Australian Information Commissioner as soon as practicable, in accordance with notifiable data breach scheme contained in Part IIIC of the Privacy Act.

9.1. We take steps reasonably in the circumstances to ensure that the Personal Information it holds is protected from misuse, interference and loss and from unauthorised access, modification or disclosure.

9.2. The transmission of information via the Internet is not completely secure. We cannot guarantee the security of your data transmitted to our online services and any transmission is at your own risk.

9.3. We will permanently destroy Personal Information the earlier of 30 days after a Driver or Customer deletes or deactivates their account or in circumstances where it is no longer required, unless we are otherwise required or authorised by law to retain the information.

10.1. We take steps reasonable in the circumstances to ensure Personal Information we hold is accurate, up-to-date, complete, relevant and not misleading. Under the Privacy Act, you have a right to access and seek correction of your Personal Information that is collected and held by us.

10.2. If at any time you would like to access or correct the Personal Information we hold about you, or you would like more information about our approach to privacy, please contact us via the contact details set out in section 12 below. If we refuse your request to access or correct your Personal Information, we will provide you with written reasons for the refusal and details of complaint mechanisms.

11.1. Services that the Reta App will use include Apple Analytics, which transmits website traffic data to Apple servers. Apple Analytics does not identify individual users or associate your IP address with any other data held by Apple. We use reports provided by Apple Analytics to help us understand traffic and usage on the Reta App. By using the Reta App, you consent to Apple processing your data in the manner described in Apple’s Privacy Policy and for the purposes set out in this Privacy Policy.

11.2. Services that the Reta App will use include Google Analytics, which transmits website traffic data to Google servers. Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand traffic and usage on our website. By visiting and using the Reta App, you consent to Google processing your data in the manner described in Google’s Privacy Policy and for the purposes set out in this Privacy Policy.

11.3. Google may pass on cookies to its partners and other third parties to achieve its purposes. For more information on how Google uses the information collected from cookies, and how you can opt out of this feature please see Google’s Privacy Policy. You can also view Google Analytics’ currently available opt-out at https://tools.google.com/dlpage/gaoptout.

If you have any complaints or issues you wish to raise with us regarding the way we have handled your Personal Information, or would like to discuss any issues about our Privacy Policy, please contact us directly by:

1. email at reta@returnsandtracking.com; or
2. lodging a complaint or question via the ‘Help Centre’ page on the Reta App.

From time to time it may be necessary for us to review and revise our Privacy Policy. We may notify you about changes to this Privacy Policy by posting an updated version on our website. We encourage you to check our website from time to time to ensure you are familiar with our latest Privacy Policy.