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Privacy Policy
Version (1)

Last updated changes
We may change this policy from time to time. The policy was last updated on 7th June 2010.

Your Privacy
We respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take to keep your data secure and how we use it. We also explain the options you have regarding your personal data. When you request services from us or access our website, you consent to our collection, retention and use your personal data in the manner described in this policy and accept the risks outlined in the Security section. You can quickly review the key topics by reading this summary page. Alternatively, click on any of the headings below to read more about an issue or read the full policy.

Scope

1. Who we are
We are JP Just Properties international Pty Ltd Trading as GreenShareCar and its subsidiaries. This policy does not cover our licensees or affiliates.

2. Legal Issues
We aim to comply with the privacy laws applicable to the personal data we collect and use.

Retention

3. Storage
We generally retain personal data about our customers for as long as we believe appropriate for the purposes for which it was collected.

4. Security
We aim to maintain appropriate physical, procedural and electronic safeguards to protect your personal data.

5. Access
You may access and review the personal data we retain about you and correct any factual errors.

Collection

6. What we collect
We collect the personal data we need to provide the services you request from us.

7. Sources
We mostly collect your data directly from you and companies involved in our provision of services to you, including our licensees.

8. Websites
We use certain technologies on our websites, including cookies, to collect data about your visit. You may choose to restrict our use of cookies as suggested in this policy.

Use

9. Operational Uses
By providing your personal data to us, you consent to our use and disclosure of your data for the operational purposes listed in this policy.

10. Marketing Uses
We would like to use your personal data for our marketing purposes. We may also want to share your data with our business partners for their marketing purposes. You can choose to restrict these uses by following the instructions in this policy.

11. Contact Us
We hope this policy answers your questions about our collection and use of your personal data. If it does not, or if you have any questions, please contact us by following the instructions in the full policy.

12. Your Privacy
We respect your privacy and are committed to protecting the personal data we hold about you. This policy explains what data we collect about you, how we collect it, the measures we take to keep your data secure and the uses we make of it. We also explain the options you have in relation to your personal data.

When you request services from us or access our websites, you consent to our collection, retention and use of your personal data in the manner described in this policy and accept the risks outlined in the Security section.

13. Aim
This policy covers the personal data we collect about you for our vehicle and equipment rental business. It does not address data that does not personally identify you, such as aggregated anonymous data. We are free to use non-personal data as we wish. We do not knowingly obtain personal data from individuals under age 18 years.

14. Who We Are
We are JP Just Properties international Pty Ltd Trading as GreenShareCar and its subsidiaries, an Australian company based in Melbourne, and may also operate under the GreenShareCar brand in other parts of the world, which together with our subsidiary companies, provides vehicle rental services in Australia and or worldwide. All references in this policy to "we", "us" and "our" are to us and our subsidiaries. Our businesses generally operate under a "GreenShareCar" "when you need to drive" mark, including our affiliated companies under the Roscon Group of Companies, "the affiliated companies".

We operate a large network of licensees in provision of our services worldwide and are affiliated to many other companies through ownership. As our licensees and affiliates are independent companies, they are not owned or controlled by us and are not covered by this policy, although they may have their own privacy policies to govern the personal data they collect.

15. Subsidiaries
These companies are owned by The Roscon Group of Companies or affiliated by agreement or other arrangement, and are covered by this policy. The expressions "we", "us" and "our" apply to them.

16. Licensees
We have a network of independent companies licensed to operate vehicle rental businesses using the "GreenShareCar" "when you need to drive" name and business system. These companies may describe themselves as "GreenShareCar" "when you need to drive" "System Licensees" or "GreenShareCar" "when you need to drive" "Franchisees" to indicate that they are not our subsidiaries.

17. Affiliates
These companies either control us (through ownership) or are controlled by the companies that control us. They cover a range of businesses but are generally not involved in provision of our services to you.

18. Changes

We may change this policy from time to time. If we do so, the amended policy will take effect when we post it on our website. We will amend the "last updated" notice on the first page of this policy whenever we make a change.

If any change makes the policy less protective of your personal data, it will not apply to data we collected about you before the change was made. The only exception to this is where we have told you about the changes and given you the opportunity to tell us not to apply them to your personal data.

19. Legal Issues

We do business in many countries and aim to comply with the privacy laws applicable to the personal data we collect and use in the particular country in which we operate.

20. Collection
We collect a range of data about you from a variety of sources for the purposes of our business. The examples we provide here are illustrative rather than a complete list of our practices.

21. What We Collect

We collect the data we need to provide the services you request from us, which may include:

1. Name, address and contact details, including telephone and mobile number, and email;
2. Date and place of birth, passport number and driver's license number;
3. Employer(s) name and address;
4. Credit card information;
5. Frequent flyer and other membership reward program information;
6. Affiliations with companies, associations, colleges or cities;
7. Location data such as geographic location of electronic devices used to contact us;
8. Rental charges you incur and other information relating to your transactions; and
9. Information about your credit history from consumer reporting agencies.
10. Date of birth, driving history.

We may collect personal data which is regarded as sensitive data in some countries, such as data about health conditions or membership of a trade union, which we are unable to process without your consent.

22. More about Sensitive Data
Data about your health conditions is regarded as sensitive in many countries. Your membership of a trade union or similar organization is regarded as sensitive and we may need to process this information.

Please note that if you wish to rent with us or our licensees and need to provide sensitive data, you consent to that data being collected, used and disclosed for our Operational Uses. We will not use sensitive data about you for marketing purposes.

23. Sources

We collect personal data directly from you when you make a reservations or bookings or rent a vehicle, including information you provide:

1. When you call our reservation, customer contact or member care centers;

2. On our websites;

3. At the rental location; and

4. When you join GreenShareCar as a member under different classifications, such as Gold Members, Platinum Member, Life Member or Corporate Member.

24. Other Sources

We also gather personal data about you from a variety of other sources, including:

1. Reservations you make with us through licensees, hotels and resorts or other authorised representatives of GreenShareCar;
2. Transactions you complete with us and our licensees, including options you take, charges you incur and any incidents or accidents that may occur; and
3. Other companies that have business relationships with us, such as our affiliates and business partners, including airlines and hotels.

Website

25. Our Website
We use certain technologies on our websites to collect data about your visit, as follows:

26. Cookies
A "cookie" is a set of data sent to your computer by our web server that enables the server to recognize your computer.
Cookies help us improve the quality of your visits to our websites by making the reservation process faster and smoother. The information they provide helps us develop content and features that we think will be of interest to you.

We use cookies to:

• Track your use of our websites during a single visit, remember the data you provide and the choices you make as you progress from page to page ("session cookies"); and

• Recognize you at your next visit ("persistent cookies").

27. More about Cookies
By adjusting your browser or installing certain software, you can restrict our use of cookies. If you do this, you should be aware of the following:

1. If you restrict our use of session cookies you will not be able to use our websites or certain features of our e-mail messages. You should be aware that session cookies are generally deleted or made unavailable to us as soon as you close your browser.
2. If you restrict our use of persistent cookies you may still enjoy the full workings of our websites and e-mail messages but will need to re-enter some data when starting a new website session. Although persistent cookies will neither automatically be erased nor made unavailable to us upon closing your browser, they will typically "expire" after a number of years.
If you are still unsure about cookies, please note that the data that makes up one of our cookies will typically have no meaning to anyone other than us. Also, a cookie is unable to retrieve other data from your computer's hard drive or pass on computer viruses.

28. Pixel Tags
In addition, we may use "pixel tags" or similar technologies that enable us to track your actions as a user of our websites or recipient of our e-mail messages.

Pixel tags are used to collect anonymous data to help us determine popular destinations, average rental prices, quote and conversion rates, click-through and other information to improve our service. We also use them to identify which online advertisement or email has brought a customer to our website.

29. Other Company Websites
Our websites and e-mail messages may contain links to websites operated by other companies. You should be aware that the collection and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this policy.

30. Retention
We try to ensure that the personal data we retain about you is stored securely and is as accurate, current and complete as necessary for the purposes we use it for.

31. Storage

We generally retain personal data about our customers for as long as we believe appropriate for the purposes for which it was collected or as otherwise required by applicable law.

Our principal databases for storing the personal data we collect are located in Melbourne - Australia, Toronto - Canada.

32. Security

As you may be aware, there is no completely secure method of transmitting or storing data. Although their physical characteristics are different, postal mail, telephone calls, text messages, faxes and transmissions over the Internet all present possibilities of loss, misrouting, interception and misuse of the data that is transmitted.

We aim to maintain appropriate physical, procedural and electronic safeguards to protect your personal data, including:

1. Restricting access to personal data to our employees on a "need to know" basis;
2. Enforcing policies and procedures for our employees in their handling of personal data; and
3. Using technologies designed to safeguard data during its transmission, including SSL encryption for the data you provide on our websites.

If you have reason to believe that any account with us is no longer secure, you must immediately contact us by following the instructions at the end of this policy.

33. More about SSL Encryption
"SSL" stands for Secure Sockets Layer encryption. We use this protection for the data you submit to us on our websites. SSL encryption seeks to ensure that you are actually sending your data to GreenShareCar and that no-one else can read or tamper with it during transmission.

When you are asked to provide your personal data to us on our website, you will see that our "http" website address changes to read "https". The additional "s" denotes that the site is secure for that data transfer. You may also see a closed padlock symbol on your screen, again denoting a secure site.

34. Security of Communications
We try to strike a balance between the security of your data and your convenience. As a result, we may sometimes use a method of communication that is less secure than a less convenient alternative.

For example, we will send you e-mail or text message in unencrypted form (i.e. instantly readable) because many of our customers are unable to access encrypted (i.e. coded) e-mail. This means that our email, if misrouted or intercepted, could be read more easily than encrypted e-mail. For this reason, please do not include confidential information, such as your credit card number, in any e-mail you send to us.

For a more secure way to communicate with us over the Internet, please click on the "Contact Us" link at the bottom of any page on www.greensharecar.com.au and follow our instructions.

35. Access
You may access and review your personal data and correct factual errors as follows:

1. If you are a member of GreenShareCar, such as Gold Members, Platinum Member, Life Member or Corporate Member or similar, you may update your member profile in our website at www.greensharecar.com.au
2. If you are not a member of GreenShareCar or your interest is broader than your membership data, or you wish us to delete certain particulars of your personal data, please contact us by following the instructions at the end of this policy.
To protect your privacy and the security of your personal data, we will take steps to verify your identity before granting you access or making corrections to the data we store about you.

36. Uses
By enrolling as a GreenShareCar member or making a reservation with us, you consent to our use and disclosure of your personal data for the operational uses listed below. We would also like to use your data for our marketing purposes.

37. Operational Uses

The examples provided below are illustrative and not a complete list of our practices:

38. Provision of Services
We will share your personal data among ourselves, our agents, and our licensees and other companies to provide services to you, including to:

1. Make your rental reservations;
2. Process your transactions;
3. Provide you with enhanced rental services, such as GreenShareCar Membership of Life Member and or similar services;
4. Provide you with customer assistance;
5. Bill and collect amounts owed to us for your rentals and membership; and
6. For customer satisfaction and market research purposes to help us improve our services.

39. Disclosure to Companies You Use
We will also share your information with companies you use in connection with your rental, including:

1. Your credit card provider and other companies that process your charges;
2. Any company or organization that is paying your rental charges;
3. Any intermediary you use, such as a travel agent, broker or hotel, in relation to any aspect of your rental; and
4. Any operator of a membership program for which you are rewarded for renting with us, such as a frequent flyer program.

You may quote a special discount code, called Member Discount Program "MDP number" or "Special promotion Code SPC" when you rent with GreenShareCar, entitling you to the special rate or benefits we may have negotiated with your company, association, credit card company or travel club. We have specific rules governing our sharing of your data with the sponsors of these CDP or SPC rates.

GreenShareCar members may enroll for membership under a Promotional Code or affiliation with a building, housing estate, college, company, association or city. GreenShareCar may use these organizations to help administer the car sharing program. By enrolling, you consent to our disclosure of your personal data to them for their and our administrative purposes. These organizations are not allowed to use the data for marketing purposes.

40. More about MDP or SPC Sponsors
If you rent using a MDP or SPC (Member Discount Program or Special promotion Code) number, you consent to our disclosure of your personal data to the MDP sponsor to:

• Confirm your eligibility to rent using that MDP or SPC number;

• Determine our compliance with the terms of the program;

• Establish your compliance with the sponsor's rental policies;

• Enable the sponsor's payment of your rental costs (if applicable); or

• For any other uses reserved by a MDP or SPC sponsor in its agreement with you.

MDP or SPC Sponsors are required to treat all personal data as confidential. They are not allowed to use the data for marketing purposes.

If you do not wish us to disclose your personal data to a MDP or SPC sponsor for the above purposes, you must not use their MDP or SPC number for your rental. This will mean, however, that you will not be able to receive the benefits associated with that MDP or SPC number.

If you do not wish us to disclose your personal data to a Promotional Code or affiliation sponsor of the GreenShareCar business, do not enroll in GreenSharecar Member Discount Programs.

41. Protective and Legal Uses
We may use and disclose your personal data as we believe appropriate, in compliance with applicable law, to protect our business. For example, we may share your personal data with credit reporting and fraud checking agencies. We may also share your data with organizations to enforce the "member user agreement" and recover any monies due, such as debt collection agencies.
In addition, we may share your personal data for legal reasons, including:

1. Cooperating with law enforcement agencies, to identify individuals who may be involved in illegal activities;
2. Responding to governmental and administrative bodies in relation to charges arising during the rental, such as parking and traffic fines, tolls and congestion charges; and
3. To comply with applicable law.

42. Disclosure to our Agents
We may use other companies as our agents to act on our behalf and assist us in the conduct of our business, performing services for us under our instruction. These services may include hosting certain websites or databases, running promotions for us, sending marketing communications, carrying out data analysis and conducting customer satisfaction surveys or other research. We will require our agents to maintain appropriate security standards to protect your personal data and use the data only for the purposes we specify.

43. Disclosure for Corporate Transactions
We may disclose your personal data to other companies in relation to the sale, merger or transfer of one of our businesses to enable the other company to decide whether to proceed with the transaction. If the transaction is completed, the company will be required to observe the relevant provisions of this policy with respect to the data provided.

44. Marketing Uses
We may aggregate your personal data and use it to develop targeted marketing programs and service offerings that we believe may be of interest to you. We would like to send these to you by email or by mail. We would also like to share your personal data with our licensees, affiliates and business partners for their marketing purposes. You have choices in relation to our marketing uses of your personal data as follows:

45. Australian Residents
We may use your personal data for the above marketing purposes, although you can choose to limit or restrict our mailings and our sharing of your data for these uses by following the instructions at "Marketing Options" below.

46. EU Residents
We will only use your personal data for our marketing purposes with your prior consent, which may be collected from a number of sources.
If you do not receive marketing messages from us and would like to do so, or if you want to limit or restrict our mailings or sharing of your data for marketing purposes, please follow the instructions at Marketing Options below.

47. Residents of Other Countries
Our use of your personal data for marketing purposes will comply with your local law. You can instruct us how we can use your personal data for marketing purposes by following the instructions at Marketing Options below.

Marketing Options

48. Members of GreenShareCar
If you are a member of GreenShareCar Gold Members, Member or Life Member or a similar program or other membership types which may be introduced in the future, you will have made marketing choices when you enrolled to become a GreenShareCar Member. These choices are now recorded in your Profile. You can review and amend your selections by accessing your Profile at the www.greensharecar.com.au you can review and amend your Membership rental options by accessing your Profile on the My Account section on our website.

Alternatively, please complete the My Privacy Choices form at the end of this policy and mail it to us, following the instructions at contact us below.

49. Non-Members
If you are not a member of one of our programs, you can record your marketing choices by enrolling, free of charge, in GreenShareCar Expression of Interest section or you may wish to receive GreenShareCar – Updates via email.

When you enroll, as a member or the recipient of our GreenShareCar – Up Dates we will provide you with a GreenSharecar number and ask you to quote it when you rent a vehicle from GreenShareCar.

50. Alternative Opportunities to Opt-out
Our marketing emails contain an unsubscribe option. If you do not want us to continue to send marketing emails to your email address, click on unsubscribe and we will not send further marketing emails to that address, although you may still receive emails at other addresses for which you have not unsubscribed. If you subsequently wish to override your choice to unsubscribe, you will need to either amend your Profile (see Members of GreenShareCar) or, if you are not a member of GreenShareCar, follow the instructions for Non-members above.

52. Important Points to Note
Please note the following points about the marketing choices you make:

1. If you change your marketing choices, we will always observe your most recent choice associated with your GreenShareCar membership number. Although we aim to process your choices promptly, you may still receive marketing communications prepared before we received your request to unsubscribe;
2. If you change your address, we will continue to follow your directions for your most recent address provided from your ‘unsubscribe' click above, your Profile, or the My Privacy Choices form you completed that is associated with your GreenShareCar membership number. In order for us to continue to follow your directions at a new address, you will need to update your Profile online or complete another My Privacy Choices form with your updated information and provide it to us with your changed contact information; and
3. If you choose not to receive marketing messages from us, you may not be able to receive certain benefits connected to your membership, such as GreenShareCar -Awards® points and free rental days (if applicable). You will, however, continue to receive program updates and other membership information; and
4. If your Profile contains a Member Discount Program or Special Promotional Code (MDP or SPC) number or you enrolled with GreenShareCar Promotion Code or affiliation, you're (MDP or SPC) or affiliation sponsor may have made marketing choices for users of that number. If the sponsor's choices are more restrictive on our use of your data than your choices, we will observe the choices made by the sponsor.

53. Contact Us
We hope this policy answers your questions about our collection and use of your personal data. If you have additional questions or want to contact us for a specific purpose, please select from the following:

54. Access/Corrections:
Please send any request to access, amend or delete certain personal data we hold about you to the most convenient address below.

55. General Questions:
You should send any questions you may have about this policy to the most convenient address below. If you feel our response is not satisfactory, we will refer you to a neutral and independent dispute resolution organization.

56. Marketing:
Send a completed "My Privacy Choices" form (at the end of the policy) to the address below. We aim to process your choices promptly on receipt, but you should please allow a number of days for your choices to become effective.

57. Security:
If you have reason to believe that the personal data we hold about you, such as your GreenShareCar Profile, or other membership choices you make form time to time is no longer secure, you must immediately notify us of the problem by either clicking "Contact Us" at the bottom of any page on www.greensharecar.com.au or contact us as follows:

58. Contact Addresses:

• Customers anywhere in Australia: 1300 575 878
• Privacy Compliance Officer, JP Just Properties International Pty Ltd Trading as GreenShareCar, 150 Sydney Road Coburg Victoria (Australia) 3058

59. My Privacy Choices

Please complete this form and send it to us by following the instructions at Contact Us above.

60. Updates
Please update your information in your Profile online, or use the form below for changes. Click here for a downloadable PDF version of "My Privacy Choices" form.