Privacy Policy

1. About this Policy#

1.1 This Privacy Policy explains how Bellarine Drives Pty Ltd (Bellarine Drives, we, us or our) collects, holds, uses and discloses personal information, and how you may access or correct your information or make a privacy complaint.

1.2 It applies to personal information handled through bellarinedrives.com.au (Website), our enquiries and communications, our activities as a vehicle host on Turo, vehicle handover and support, and our general business operations.

1.3 We are committed to handling personal information responsibly and transparently. We comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles (APPs) and other privacy, surveillance, spam and data-protection requirements to the extent they apply to us.

1.4 This Policy should be read with our Website Terms and Conditions. Turo separately handles information under Turo's own privacy policy and platform terms.

2. Who We Are#

Bellarine Drives Pty Ltd (ACN 701 619 267; ABN 69 701 619 267) operates from the Bellarine Peninsula, Victoria and lists vehicles through Turo. Our privacy contact is available at info@bellarinedrives.com.au.

3. Meaning of Personal Information#

Personal information is information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information is true or recorded in material form. Some information may not identify you by itself but may become personal information when combined with other data.

Sensitive information is a more protected category and can include health information, biometric information, racial or ethnic origin, religious beliefs, sexual orientation and criminal record information.

4. Information We May Collect#

Depending on how you interact with us, we may collect:

• Identity and contact information, such as your name, email address, telephone number and general location.
• Enquiry information, including requested dates, vehicle preferences, collection or delivery requirements, accessibility needs you choose to disclose, and messages exchanged with us.
• Turo and trip information made available to us as a host, such as your Turo profile, booking reference, approved-driver status, trip dates, messages, check-in or check-out records, photographs, mileage, fuel or charge level, incident reports and reimbursement information.
• Licence and identity-verification information where lawfully required for vehicle handover or Turo's verification process. Wherever practicable, verification should occur through Turo rather than ordinary email or a general Website form.
• Payment-related information supplied through Turo, such as transaction status, fees, reimbursements and host earnings. We do not intentionally collect or store complete payment-card details through this Website.
• Vehicle and trip-operational information, such as vehicle condition, location or recovery information, distance, diagnostic events, warning codes, security events and other data described in section 10.
• Website and device information, such as IP address, browser, device type, operating system, referral source, pages viewed, access times, cookies and similar technical records.
• Communications and records, including emails, Turo messages, complaint information, reviews, feedback and lawful records relating to safety, damage, claims, tolls or infringements.
• Business and compliance information reasonably required for accounting, fraud prevention, insurance or protection processes, legal compliance and the establishment or defence of legal claims.

5. Sensitive Information#

5.1 We do not ordinarily seek sensitive information. Please do not provide it unless it is genuinely necessary.

5.2 If you disclose health, disability, accessibility or other sensitive information so we can consider a request, we will handle it only for the relevant purpose, with your consent or as otherwise permitted or required by law.

5.3 We do not use sensitive information for unrelated marketing.

6. How We Collect Information#

We may collect personal information:

• directly from you through Website forms, email, telephone, social media, Turo messaging, vehicle handover, trip photographs, incident reports or other interactions;
• from Turo when you view, request or complete a Booking involving a Bellarine Drives Vehicle;
• from an Approved Driver, authorised representative, additional guest, witness or person making an enquiry on your behalf;
• from vehicles, manufacturer services, security or telematics systems where disclosed, lawful and reasonably necessary;
• from payment, roadside-assistance, repair, toll, parking, claims, protection, professional-adviser or enforcement services;
• automatically when you use the Website, through server logs, cookies and any disclosed analytics or security tools; and
• from public records or publicly available sources where lawful and relevant.

If you provide another person's information, you must be authorised to do so and should make them aware of this Policy where reasonable.

7. If You Do Not Provide Information#

You may interact anonymously or using a pseudonym where lawful and practicable, such as when making a general question that does not require a response tailored to you. However, we may be unable to answer a specific enquiry, verify eligibility, release a Vehicle, administer a Trip, investigate an incident or meet legal obligations without the information reasonably required for that purpose.

8. Website, Cookies and Analytics#

8.1 The Website may use cookies, local storage, server logs and similar technologies to operate navigation and forms, remember preferences, maintain security, understand Website performance and improve our services.

8.2 Necessary cookies may operate automatically. If we use non-essential analytics, advertising or preference cookies, we will provide any notice or consent mechanism required by law.

8.3 Technical information may include your IP address, device and browser details, approximate location derived from IP, referring page, pages viewed, session duration and interaction events.

8.4 You can usually control cookies through your browser. Blocking cookies may affect parts of the Website. Privacy or ad-blocking settings may also limit analytics.

8.5 If we activate a third-party analytics, advertising, embedded map, video, chat, reCAPTCHA or social-media tool that materially changes our information handling, we will update this Policy and any applicable cookie notice.

9. Turo Bookings and Independent Privacy Practices#

9.1 Vehicle Bookings are made through Turo. Turo independently collects, uses, holds and discloses information under its own terms and privacy policy. Bellarine Drives does not control all information collected by Turo or Turo's account-verification, payment, protection, fraud-prevention or platform systems.

9.2 Turo may share with us the information reasonably needed to consider and administer a Booking, communicate with a Guest, conduct handover, document vehicle condition, respond to incidents, request reimbursements and comply with host obligations.

9.3 We may provide relevant trip information back to Turo, including messages, check-in or check-out photographs, vehicle condition, distance, fuel or charge levels, damage, safety concerns, claims, tolls, infringements and suspected breaches of applicable rules.

9.4 For questions about information controlled by Turo, including Turo account data or payment credentials, use Turo's privacy and support processes.

10. Vehicle Technology, Location and Telematics#

10.1 A Vehicle may contain manufacturer systems or lawfully installed security, diagnostic or telematics technology that records or transmits information such as location, distance, speed, acceleration, braking, battery or fuel status, fault codes, warning events, locking activity, attempted tampering or other operational data.

10.2 We may access and use this information where reasonably necessary to locate or recover a Vehicle, respond to an emergency, protect safety or property, investigate suspected misuse, administer a Trip or claim, confirm compliance, maintain the Vehicle, or establish, exercise or defend legal rights.

10.3 We will limit access to people who reasonably need the information and retain it only as long as required for the relevant purpose or by law.

10.4 We will not use Vehicle technology to make audio or visual recordings of a Guest inside the passenger cabin unless that recording is specifically disclosed before the Trip, lawful, and subject to any consent or notice requirements.

10.5 A Guest must not disable or tamper with lawful safety, security, diagnostic or location technology. Concerns about a device should be reported to us or through Turo.

11. Why We Collect, Use and Disclose Information#

We may handle personal information to:

• operate, maintain and secure the Website;
• respond to enquiries and provide requested information;
• list Vehicles and administer our activities as a Turo host;
• assess availability, coordinate handover and return, and communicate about a Trip;
• verify identity or eligibility where Turo or law requires it;
• document Vehicle condition and Trip events;
• provide customer support and respond to safety issues, breakdowns, accidents, damage, theft, complaints and disputes;
• administer tolls, infringements, incidentals, reimbursements, claims and protection processes;
• prevent, detect and investigate fraud, misuse, security threats and unlawful activity;
• maintain, diagnose, secure, locate or recover Vehicles;
• conduct accounting, recordkeeping, auditing, business planning and service improvement;
• send direct marketing where permitted and honour opt-out requests;
• comply with Turo host requirements, contracts, court orders and Australian law; and
• establish, exercise or defend legal rights and manage business risk.

We may also use de-identified or aggregated information for analytics and business improvement where individuals are not reasonably identifiable.

12. When We Disclose Information#

We may disclose personal information where reasonably necessary to:

• Turo and its support, claims, protection, payment, verification or safety providers;
• our Website host, email provider, IT support, cloud storage, analytics, security and communication providers;
• vehicle manufacturers, connected-vehicle providers, roadside assistance, towing, repairers, detailers, secure parking or vehicle-recovery services;
• toll-road, parking and infringement administrators, police, emergency services, regulators, courts and government authorities;
• insurers, discretionary mutuals, claims administrators and professional advisers such as accountants, lawyers and auditors;
• a buyer, investor or adviser involved in a genuine proposed sale, restructure or transfer of our business, subject to appropriate confidentiality; and
• another person where you direct or authorise us, or where disclosure is required or permitted by law.

We do not sell personal information to data brokers. We require service providers to handle information only for legitimate purposes and with appropriate protections where reasonably possible.

13. Overseas Disclosure and Storage#

13.1 Some providers used by Bellarine Drives or Turo may store, process or access information outside Australia. Likely locations may include the United States and other countries in which Turo, cloud, email, website, analytics, vehicle-technology or support providers operate.

13.2 The exact countries can change as providers and infrastructure change. Where practicable, we take reasonable steps to assess providers and require appropriate contractual, technical or organisational safeguards.

13.3 Turo's independent overseas disclosures are described in Turo's privacy policy. Please review that policy before using Turo.

14. Direct Marketing#

14.1 We may send you offers, fleet news or other marketing only where we have consent or another lawful basis. Submitting a general enquiry does not automatically subscribe you to marketing.

14.2 Marketing email or SMS messages will identify the sender and provide a clear way to unsubscribe. You may opt out at any time using the supplied facility or by emailing info@bellarinedrives.com.au.

14.3 We will action unsubscribe requests within the period required by the Spam Act 2003 (Cth). We may still send non-marketing messages reasonably necessary to respond to an enquiry, administer a Trip, address safety or comply with law.

14.4 We do not use sensitive information for direct marketing without the consent required by law.

15. Storage and Security#

15.1 We may hold personal information in Turo systems, business email, cloud storage, accounting or recordkeeping systems, security or telematics platforms, and limited paper records where necessary.

15.2 We take reasonable steps appropriate to our size and activities to protect personal information from misuse, interference, loss, unauthorised access, modification and disclosure. Measures may include access controls, authentication, software updates, secure providers, backups, staff or contractor confidentiality, and limiting access to those who need it.

15.3 No internet transmission or storage system is completely secure. You should not send payment-card details, passwords, licence images or other highly sensitive documents through a general Website form or ordinary email unless specifically requested through a suitable process.

15.4 If you believe your information or a Bellarine Drives communication has been compromised, contact us promptly.

16. Retention and Destruction#

16.1 We retain personal information only for as long as reasonably necessary for the purpose collected, a related lawful purpose, Turo requirements, dispute or claim management, safety, accounting, tax, insurance or other legal obligations.

16.2 Retention periods vary. Trip and financial records may need to be retained for several years, while unsuccessful general enquiries and routine technical logs may be kept for shorter periods.

16.3 When information is no longer required, we take reasonable steps to delete, destroy or de-identify it, subject to backup cycles, legal holds and information controlled independently by Turo or another provider.

17. Access and Correction#

17.1 You may request access to personal information Bellarine Drives holds about you or ask us to correct information that is inaccurate, out of date, incomplete, irrelevant or misleading.

17.2 Send your request to info@bellarinedrives.com.au and provide enough information for us to identify you and the relevant records. We may need to verify your identity before responding.

17.3 We will respond within a reasonable period. We will not charge to make a request and will only charge a reasonable cost of providing access if permitted by law and advised in advance.

17.4 Access may be refused or limited where permitted by law, including where disclosure would unreasonably affect another person's privacy, reveal legally privileged material, prejudice an investigation, be unlawful, or create a serious safety risk. Where required, we will explain the refusal and available complaint options.

17.5 For information controlled by Turo, submit the request directly through Turo's privacy process.

18. Privacy Complaints#

18.1 If you believe we have mishandled your personal information, contact our privacy contact at info@bellarinedrives.com.au. Please describe what happened, relevant dates, any Booking reference and the outcome you seek.

18.2 We will acknowledge the complaint, investigate it fairly, seek any further information reasonably needed, and respond within a reasonable period.

18.3 If you are not satisfied and the Privacy Act applies, you may contact the Office of the Australian Information Commissioner at oaic.gov.au/privacy/privacy-complaints. You may also have rights through Turo, Consumer Affairs Victoria or another regulator depending on the issue.

18.4 Complaints about Turo's independent handling of personal information should first be directed to Turo.

19. Data Breaches#

19.1 If we become aware of a suspected data breach, we will take reasonable steps to contain it, assess the likely consequences and reduce potential harm.

19.2 Where the Notifiable Data Breaches scheme or another notification requirement applies, we will notify affected individuals and the relevant regulator as required.

19.3 If a breach involves a third-party provider or Turo, we will reasonably cooperate with the responsible organisation and follow applicable notification and response processes.

20. Children and Young People#

20.1 The Website is directed to adults considering vehicle services. We do not knowingly collect personal information directly from children for marketing.

20.2 A person booking or driving through Turo must satisfy Turo's current age, account, licence and Approved Driver requirements.

20.3 Information about a child, such as a request for a child-seat Extra, should be limited to what is reasonably necessary. Do not send a child's identity documents or sensitive information unless specifically and lawfully required.

21. Third-Party Websites and Social Media#

The Website may link to Turo, maps, social media or other services. Those providers operate independently and may collect information under their own privacy policies. We are not responsible for their privacy practices, security or content. Check the destination and its privacy terms before supplying information.

22. Changes to this Policy#

22.1 We may update this Policy when our Website, vehicles, systems, providers, Turo relationship, business practices or legal obligations change.

22.2 The current version will be posted on the Website with an updated effective date. Material changes will be communicated in another appropriate way where required by law.

22.3 We recommend reviewing this Policy periodically.

23. Contact Us#

Bellarine Drives Pty Ltd
ACN 701 619 267
ABN 69 701 619 267
Email: info@bellarinedrives.com.au
Website: bellarinedrives.com.au

If you need this Policy in another reasonably accessible form, contact us and we will take reasonable steps to assist.