Traffio Pty Ltd has created this privacy policy to explain to you how Traffio uses, collects, discloses and protects your Personal Information when you use our traffic management software, public website, our applications and related services (the “Service”). By using the Service, accessing our websites or accessing our mobile application, you consent to the privacy practices described in this policy.

 

At Traffio, we take privacy very seriously.  We are aware that we operate in an increasingly international marketplace where the protection of all kinds of Personal Information is of paramount importance.  In light of Traffio’s continuous growth across different jurisdictions, we are mindful of the need to periodically update this Privacy Policy to take into account the leading standards in privacy and data protection including the global benchmarks set by the General Data Protection Regulation (EU) 2016/679 (“GDPR”).[1]  For all data processing taking place in Australia we continue to comply with the Australian Privacy Act including its 13 Privacy Principles.

 

This privacy policy sets out how we treat your information in the clearest way possible. We encourage you to read this Policy carefully. It will help you make informed decisions about sharing your information with us.

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​What Personal Information do we collect?

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When you use the Service which Traffio provides, it necessarily involves the processing of certain Personal Information relating to individuals.  "Personal Information" is information about an identifiable individual and may include information such as the individual’s name, email address, telephone number, their IP address, date of joining, social media identifiers, or may comprise employee or client lists, key contact persons, job titles, and certain payment data, order history or account information.  When it comes to our valued employees, the Personal Information collected can also include payroll information, qualifications, Cvs, personnel matters and related staffing records.

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We collect Personal Information when you register for an account with Traffio or correspond with us via emails or other messaging service. Some of the Personal Information is collected directly from you when you subscribe to our newsletter or give us feedback.

 

​Traffio’s Lawful Bases & Limited Purpose for holding Personal Information

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​Traffio collects your Personal Information so that we can provide you with the Service and any related information or support you may request from us.  At all times we recognise the six potential lawful bases flowing from the standard set by GDPR for holding on to your Personal Information.  We summarise these in the diagram below:

Processing of Personal Information under GDPR:
The 6 Lawful Bases for Traffio:

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Applying these to Traffio’s public website, we are confident we have at all times the consent of the various data subjects whose Personal Information we hold through the website. 

For our primary product, software and platform, we are obliged to process much of the Personal Information we receive in order to fully perform our contractual terms with our growing number of partners, suppliers and of course our customers (including their clients and end users).

 

We also possess in collecting and using your Personal Information, having taken time to study the three essential tests required for any “legitimate interests” examination. As a result, we believe the collation of limited Personal Information is integral and necessary for our business to function in the business sectors in which Traffio operates, and for us to provide the Traffio Service to our customer-base. We have also considered alternate modes of operating without our software solutions and weighed the balance of the impacts of our secure data processing on individuals. We take the view that there is minimal or no likelihood of harm to the rights and freedoms of the individuals whose Personal Information we hold.

 

We also process Personal Information where we need to comply with – for example those connected with how we provide for our valued employees and any obligation arising from any regulatory request made of us by a tax authority, or a data protection regulator such as the NDC in Australia or the Information Commissioner’s Office (ICO) in the UK.

 

Our Limited Purposes for the Personal Information we hold 

 

Traffio may use the Personal Information we have collected from you for purposes related to the Services including to:

 

• administer the Service,

• notify you of updates, or new or changed services offered in relation to the Service,

• assist with the resolution of technical support issues or other issues relating to the Service,

• marketing purposes such as to inform you of products or services or features or training or knowhow that may be of interest to you (it is important to note that we will apply appropriate opt-in / opt-out choices which honour your prerogative to give your consent to marketing, in line with appropriate laws);

• comply with laws and regulations in applicable jurisdictions, and

• communicate with you clearly and on matters of relevance.

 

We are aware of the practice of re-purposing data and will make efforts to make sure Traffio maintains its usage of Personal Information in keeping with all published purposes.​ By using the Service, you consent to your Personal Information being collected, held and used in these ways and for these purposes and for any other purposes you authorise.

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Traffio can aggregate your non-personally identifiable data

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By using the Service, you agree that Traffio can access, aggregate and use non-personally identifiable data Traffio has collected from you.  Aggregated Data can include analytical data, often arranged to provide statistical or demographic information about traffic patterns or fleet management trends we see.  Aggregated Data will not be considered Personal Information when it does not directly or indirectly reveal a person’s identity.

 

Traffio may use this aggregated non-personally identifiable data to assist us to better understand how our customers are using the Service, provide our customers with further information regarding the uses and benefits of the Service, and, otherwise to improve the Service.

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​Where we hold your Personal Information

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All data that is entered into the Service is transferred to Traffio's servers as a function of transmission across the Internet.  By using the Service, you consent to your Personal Information being transferred to our servers as set out in this Policy.

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Our servers hosted by Amazon Web Services. Australian and New Zealand-based customers have their data stored in Sydney. UK and EU-based customers have their data stored in London.   Your Personal Information will be routed through, and stored on, those servers as part of the Service.  The majority of structured data is stored and located on a MYSQL database, hosted on Amazon Web Services RDS. 

  

​Data Security: steps to protect your Personal Information

 

Traffio is committed to protecting the security of your Personal Information and we take all reasonable precautions to protect it from unauthorised access, modification or disclosure.

 

Your Personal Information is stored on secure servers that have SSL Certificates issued by leading certificate authority Amazon, and all data transferred between you and the Service is encrypted.

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However, the Internet is not in itself a secure environment and we cannot give an absolute assurance that your information will be secure at all times.  You also have a role to play with respect to data security.  It is your responsibility to keep your logon credentials and password to the Service safe.  You should notify us as soon as possible if you become aware of any misuse of your password, and immediately change your password within the Service.

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Transmission of Personal Information over the Internet is at your own risk and you should only enter, or instruct the entering of, Personal Information to the Service within a secure environment.

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We will react swiftly (in line with GDPR response-times) upon discovering or being advised of a security breach where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.

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Traffio only discloses your Personal Information in limited circumstances

 

​Traffio will only disclose the Personal Information you have provided to us if it is necessary and appropriate to facilitate the purpose for which your Personal Information was collected pursuant to this Policy, including the provision of the Service. 

We enclose below some privacy statements and related information from our international partners and third party service providers, for your further information.

 

The following partners assist us with integrations or support for either our website or for the platform and business we operate:

 

Google Analytics: https://analytics.google.com/analytics/web/provision/#/provision

Pipe drive: https://www.pipedrive.com/en/privacy

Fresh desk: https://freshdesk.com/gdpr

Xero: https://www.xero.com/uk/about/legal/privacy/

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​Our network of partners and service providers also means we are able to send you information about certain products and services that we think may be relevant to you, including but not limited to third-party platforms that integrate with Traffio such as payroll, accounting, GPS, training, onboarding, work site management and other related platforms.

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Transferring Personal Information - Overseas

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At all times Traffio will ensure that wherever in the world your Personal Information is stored or processed, it will be done so in full adherence to prevailing law. 

What this means for data belonging to people located in the EU or UK is that appropriate safeguards will be taken to ensure adequate protections are in place with regards to any “third country” (including Australia) we use for key headquartered functions and processes.  We shall continue to remain in compliance with the GDPR and to this end, we shall include Traffio’s use of the EU’s Standard Model Clauses for international transfers of Personal Information where appropriate. 

 

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Your Rights

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You have the following rights under this Policy, and by law these are known as subject access rights if you are within the EU or the UK, to:

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Request access to your Personal Information.

 This enables you to request for access to your Personal Information in our possession or control or for information about the ways in which your Personal Information has been or may have been used or disclosed by us.  You may request access to the information we hold about you, by setting out your request in writing and sending it to us at privacy@traff.io.

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Request correction of the Personal Information that we hold about you.

This enables you to have any incomplete or inaccurate information we hold about you corrected.

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Request erasure of your Personal Information. 

This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right, if you are within the EU or UK, to ask us to delete or remove your Personal Information where you have exercised your right to object to processing (see below).

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Object to processing of your Personal Information. 

This right exists where we are relying on legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your Personal Information on this ground. You also have the right to object where we are processing your Personal Information for direct marketing purposes.

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Request the restriction of processing of your Personal Information. 

This enables you to ask us to suspend the processing of Personal Information about you, for example if you want us to establish its accuracy or the reason for processing it.

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Request the transfer of your Personal Information.

 If you are within the EU or UK, we will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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Withdraw consent. 

This right only exists where we are relying on consent to process your Personal Information. If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

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Make a complaint and seek a remedy. 

Under GDPR you have inalienable rights to (i) be informed about your right to complain through this Policy, (ii) make an actual complaint to your relevant supervisory authority depending on where you live (such as the Information Commissioner’s Office in the UK), and (iii) to receive an effective judicial remedy if your rights need to be upheld or enforced.

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​Traffio will process your subject access request as soon as reasonably practicable, provided we are not otherwise prevented from doing so on legal grounds. If we are unable to meet your request, we will let you know why.

 

In some circumstances, it may be necessary for us to seek to arrange access to your Personal Information through a mutually agreed intermediary (for example, the account holder).  We aim to only keep your Personal Information for as long as we require it for the purposes of providing you with the Service.

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Marketing & opting out of any email communications

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Traffio sends billing information, product information, Service updates and Service notifications to you via email.  Our emails will contain clear and obvious instructions describing how you can choose to be removed from any mailing list not essential to the Service. When you provide your Personal Information when you contact us, you may be given the option to provide your consent for us to contact you by email for direct marketing communications. You will only receive these communications if you have given your consent.  If you provide your consent for direct marketing, you have the right to unsubscribe at any time. You can do so using the ‘unsubscribe’ link included in the marketing emails for email marketing. Traffio will remove you at your request.

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​Traffio’s Use of Cookies

 

In order to improve our traffic management software, the customer experience and our overall Service, we collect data by way of “cookies”. A cookie is a small text file containing small amounts of information which are automatically downloaded into your computer (or other electronic devices) when you access our Service. Cookies help us to measure the number of visits, average time spent, page views and other statistics relating to your access to our app and the Wix website.  Therefore, generally, we use cookies to:

• recognise your browser as a previous visitor and save any preferences that may have been set during your last visit to this Site;

• Help your session load faster

• Keep you signed in

• Monitor how you use the website

• track website analytics and carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitors’ or customers’ requirements and interests;

• customise and target our marketing and advertising campaigns and those of our partners more effectively by providing personalised interest-based advertisements;

• measure and research the effectiveness of our interactive online content, features, advertisements, and other communications;

• make your online experience more efficient and enjoyable.

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What type of cookies do we use?

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Traffio uses functional cookies to recognise you on our website and remember your previously selected preferences. These could include what language you prefer to use and your location. A mix of first-party and third-party cookies are used.  The exception to functional cookies is where the cookies are strictly necessary in order for us to operate this Site and/or to provide you with a service you have requested.

Further information about cookies, including how to see what cookies have been set on your computer or device and how to manage and delete them, visit www.allaboutcookies.org and www.allaboutcookies.org.

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Third-Party Cookies

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Third-party cookies are set by a third-party site separate from Traffio. We work with third-party service providers who are authorised to place third-party cookies and may also set cookies on this Site. These third-party service providers are responsible for the cookies they set on this Site. If you want further information, please go to the website of the relevant third party. If you would like to opt-out of all other types of technologies we employ on this Site, you may do so by changing your browser settings to block, delete or disable these technologies as your browser or device permits.

In light of changes to cookies practices in 2021 (with respect to the disablement of third party cookies on some browsers) we include below an updated list of the more popular browser types with hyperlinks showing how to adapt their cookie settings accordingly:

• Google Chrome

• Microsoft Edge

• Mozilla Firefox

• Microsoft Internet Explorer

• Opera

• Apple Safari

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Updating this Privacy Policy and Contacting Us

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Traffio reserves the right to change this Policy at any time, and any amended Policy is effective upon posting to this Website.   Traffio will make every effort to communicate any significant changes to you via email or notification via the Service. Your continued use of the Service will be deemed acceptance of any amended Policy.

 

Contact details for any agent or representative we engage in your particular jurisdiction (e.g. in the EU for GDPR matters) shall be made available upon request in writing to us.

How to contact us

If you have any questions about our company privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to call us.

Email: info@traff.io

Call us: 1300 022 999

In the event of a complaint, please use the above email address to contact us directly.  In the event you remain dissatisfied after raising an issue with us in connection with this privacy policy, you are free to contact the relevant data protection regulator in the jurisdiction where you are located.

 

[1]Traffio complies with GDPR standards when we deal with people and partners in the EU and UK. We also continue to apply data protection laws applying in specific jurisdictions where we operate (e.g. Australia and its Privacy Act).