Privacy & Credit Reporting Policy
Privacy Policy (Effective on and from 22nd of July 2016 and updated on 28 July 2025)
"Personal information" is information or an opinion that identifies, or could reasonably identify, an individual.
Custom Fleet Entities ("we" / "us" / "our") value your privacy and take our obligations to protect personal information seriously. We are bound by the Australian Privacy Act 1988 (Cth), the Privacy (Credit Reporting) Code 2024, and the New Zealand Privacy Act 2020, and all applicable privacy regulations.
About this Privacy Policy
This Privacy Policy explains how we manage your personal information, including:
- the kinds of personal information that we collect and hold;
- how we collect and hold personal information;
- the purposes for collecting, holding, using and disclosing your personal information;
- whether we will (or are likely to) disclose your personal information to overseas recipients and the countries where such recipients may be located;
- how you may access and/or correct your personal information held by us;
- how you may make a complaint about the way we collect, hold, use or disclose personal information, and how we will deal such complaints;
- our contact details;
- the consequences of not providing personal information; and
- how we use your personal information for marketing activities.
You may interact with us anonymously or by using a pseudonym if the interaction is general in nature. However, if the interaction is specific to an account or relates to your personal information we will need to identify you before we can engage in further discussions and correspondence.
This Policy will be kept up to date and published on www.customfleet.com.au and www.customfleet.co.nz
The types of personal information we collect and use
The types of personal information we collect and hold will vary and are entirely dependent on the nature of our interactions with you, as well as applicable laws and regulations. We may not collect all the personal information listed below about you, and we will only collect personal information that is required and relevant to our interactions with you.
Where applicable, the types of information we may collect and hold about you include:
- your full name and contact details, including your residential address;
- your date of birth;
- your drivers licence or other ID details;
- financial information and/or banking details;
- employment information;
- number of dependents and/or spouse details;
- details about your assets and liabilities;
- transaction and repayment history information;
- credit-related information (please also refer to our Credit Reporting Policy);
- information about your marketing preferences;
- information collected via cookies, analytics, telematics;
- and for job applicants and employees, information relating to background checks, qualifications, health, right-to-work etc.
If personal information about you that we request is not provided to us, it may result in us being unable to interact with, and/or provide goods or services to, you.
How we collect personal information
Wherever possible and practical we will collect personal information directly from you, whether in person, by telephone, mail, email, fax, or through a form (such as an application form).
Where lawful, we may also collect your personal information indirectly from a third-party. This will be limited to circumstances where it is impracticable or unreasonable for us to collect it directly from you, or you have authorised us to do so. The type of third-party who might provide information to us will vary depending on the nature of our relationship with you. Such third-parties may include (where legally permitted):
- customer representatives and proxies (e.g. individuals representing a company for the purpose of contract management)
- a credit reporting body (please also refer to our Credit Reporting Policy);
- one of our authorised representatives (e.g. brokers and agents);
- a government body;
- financial institution and/or credit provider;
- Custom Fleet Entities and/or their overseas affiliates;
- someone authorised to act on your behalf (e.g. financial adviser, executor, administrator, trustee, guardian, attorney, solicitor, accountant or consumer advocate);
- third-party platforms, service providers or intermediaries;
- a referee, or a current/past employer or recruitment consultants (e.g. for job applicants); and
- an introducer such as a broker, agent, dealer and our retail partners (who are not otherwise our authorised representatives).
We may also collect personal information from publicly available sources, to the extent permitted by applicable laws and regulations.
If we receive unsolicited personal information we would not have been able to collect under our standard collection practices, we will destroy or de-identify it in accordance with any legal obligations.
We will only collect sensitive information where reasonably necessary and with your express consent, unless otherwise permitted by law.
How we use personal information
We conduct our business with privacy and data protection in mind. We ensure that use of personal information has a legitimate basis and is compliant with applicable laws and regulations. You may be a customer, contractor, employee, job applicant, supplier, service provider, partner or party with whom we do or have done business, or may do business with in the future.
As a lease facility and management services provider the main (but not all) purposes for which we hold, use or disclose personal information are:
- to assess applications for lease facility or management services;
- to establish and manage lease and services arrangements;
- to establish and administer any credit-related insurance product;
- for fraud and crime prevention and investigation;
- to collect payments which are overdue;
- to report to various credit reporting bodies;
- for planning, product and service development;
- to enable contract performance;
- for research purposes;
- to conduct risk modelling;
- to comply with any applicable laws; and
- for job applicants and employees, to assess applications, verify identity and work eligibility, manage employment or contractor agreements and arrangements, and meet any legal workplace obligations.
Personal information may also be used or disclosed to provide you with information about products and services that we believe may be of interest to you (for example, by letter, email or phone).
If you do not want your personal information to be used for direct or indirect marketing purposes, please contact us so that we can action this request. This is referred to as "opting out" of direct and indirect marketing. You can "opt-out" of direct and indirect marketing by contacting us using the details in the 'Contact Us' section of our website.
How we hold personal information
We understand the importance of protecting personal information. We take reasonable steps to ensure personal information is free from misuse, interference, loss, unauthorised access or modification by applying appropriate technical, organisational and administrative measures. This may include access controls, staff training, anonymisation, as well as technology solutions to secure systems and facilities.
How we share personal information
We may share and disclose personal information to:
- manufacturers, distributors and/or suppliers of goods in connection with your lease facility or management services;
- insurers who provide insurance in relation to the lease facility;
- service providers, such as customer service organisations, repairers, IT service providers, fuel card and other payment product providers, telematics providers, mobile and telecommunication providers, call centres, mailing houses, researchers, collections agents, statement producers, asset disposal service providers, property valuers, data analysts, professional advisers, auditors, organisations providing services and delivery companies;
- other organisations as required or authorised by law, for example, to government or regulatory bodies for the prevention or detection of unlawful activities;
- Custom Fleet Entities and/or their overseas affiliates;
- credit reporting bodies or other businesses or organisations that provide personal credit or commercial credit information consistently with the relevant Australian and New Zealand privacy laws;
- other financial institutions and credit providers;
- any current employee who you have named to verify your personal information;
- organisations through whom you choose to make payments to us;
- organisations wishing to acquire an interest in any part of our business for assessing or implementing any such acquisition;
- lenders, trustees, investors and other entities in connection with our funding activities; and
- any person who guarantees or proposes to guarantee your obligations to us or provide security in relation to such obligations for the purpose of allowing that person to assess whether to act as your guarantor and /or security provider.
We may also share additional information about our disclosure of personal information specific to that type of disclosure in a relevant privacy collection notice.
We will not share your personal information unless it is necessary for the purpose for which it was collected, and either you have consented to the disclosure, it is required or authorised by law, it is reasonably necessary for business function or activities, or another legally permitted exception applies. We will only share information that is required to fulfil the purpose for the disclosure.
If a disclosure includes sensitive information, we will only disclose it with your consent and otherwise in accordance with applicable laws and regulations.
We do not and will not sell your personal information.
How we share personal information internationally
As is the case throughout the financial services industry and other major industries, technology allows for services to be provided by different service providers, including some that are located overseas. Custom Fleet is also part of a global company group, with overseas affiliates.
As such, personal information may be transferred to, accessed by or stored overseas, either to/by third-parties, or Custom Fleet Entities and their overseas affiliates.
It is likely that the countries to which personal information may be disclosed will include Australia, New Zealand, the United States and Canada, and/or countries which we believe have privacy laws which are substantially similar to Australia and New Zealand.
If we disclose personal information to recipients in any other jurisdiction we will take reasonable steps in the circumstances to ensure that the overseas recipient is subject to, and the personal information protected by, enforceable mechanisms (i.e. such as contractual provisions).
How long we keep personal information
In order to satisfy our legal obligations, we may need to retain your information after a transaction or a relationship has ended. However, we will not retain your identifiable personal information longer than is reasonably necessary for the purposes for which it was collected, or as otherwise permitted or required under relevant Australian and New Zealand laws and regulations.
Once personal information is no longer permitted or required to be retained, we will delete or anonymise it in a way that it is no longer able to identify you.
How to access and control your personal information
You are entitled to access or correct the personal information we hold about you. The 'Contact Us' section of our website contains details of the ways you can contact us in respect of privacy matters.
Subject to legal and other permissible considerations, we will make every reasonable effort to respond to your request as soon as possible, or inform you if we require further information to fulfil your request. We may need to ask you for additional information to verify your identity before processing a request.
In some cases the ability to access or correct your personal information may be limited, or we may not be able to process your request, as required or limited by appliable law. If you have requested the deletion of your personal information, we will meet your request where legally required or otherwise agreed.
A fee may be charged in relation to the request where legally permitted.
How you can contact us and/or make a complaint, and how we will deal with privacy-related complaints
If you have a privacy related concern, complaint or question you can contact us:
- in writing:
- Australia: Send a notice addressed to Attn: Privacy Officer, Custom Fleet, Level 11, 83 Clarence Street, Sydney NSW 2000, or by email at privacy@customfleet.com.au
- New Zealand: Send a notice addressed to Attn: Privacy Officer, Custom Fleet, 8 Tangihua Street, Auckland 1010, or by email at privacy@customfleet.co.nz
- by phone, by contacting your Relationship Manager or Custom Fleet representative (whichever is applicable).
The Contact Us section of our website also contains details of the ways you can contact us.
If you want to make a complaint about our handling of personal information we ask that you contact us first. We will then followour Internal Dispute Resolution (IDR) process. For more detailed information on our complaint handling process please refer to our Customer Feedback and Complaints web page.
We aim to review and resolve your enquiries as quickly and fairly as possible. We will keep you informed of our progress. We will do all we can to provide you with the most suitable response specific to your situation and ensure, where possible/applicable, that your complaint is resolved to your satisfaction.
If the complaint remains unresolved, you may refer it to the Australian Financial Complaints Authority ("AFCA") in Australia or the Insurance & Financial Services Ombudsman (“IFSO”) in New Zealand (as applicable). AFCA & IFSO independently and impartially resolve disputes between customers and participating members on matters including privacy matters. Their contact details are:
Australian Financial Complaints Authority |
Insurance & Financial Services Ombudsman Scheme Free phone: 0800 888 202 Telephone: 04 499 7612 Email: info@ifso.nz |
Alternatively, you may refer the matter to the Office of the Australian Information Commissioner (the "OAIC") in Australia or the Office of the Privacy Commissioner in New Zealand (the “OPC”) (as applicable). The contact details for the OAIC andthe OPC are:
The Office of the Australian Information Commissioner |
The Office of the Privacy Commissioner |
Other information
Online servicing or access
When you register to access products or services online, the information collected is compared with the details we may already have stored, this might include your name and date of birth. This allows us to verify who is seeking access. If this information is not provided you will not be able to access your personal information online.
Tracking information on the web
For statistical purposes, we may collect information on website activity such as the number of users who visit our websites, the date and time of visits, the number of pages viewed, navigation patterns, what country and what systems users have used to access the site and, when entering one of our websites from another website, the address of that website. This information is obtained through the use of 'cookies' (refer below for more information about 'cookies').
Our websites may also contain links to non-Custom Fleet websites. While these links are provided for convenience, if you are navigating these sites please be aware that the information handling practices of the linked websites may differ from ours. While we try to link only to sites that share our high standards and respect for privacy, we are not able to guarantee the privacy practices of other websites.
Website security
Custom Fleet has implemented industry leading technologies and best practices to protect our customer’s data. To ensure the confidentiality of all data sent and received from your computer to Custom Fleet’s systems all data including personal information is protected using strong encryption. The security level of a web page can be viewed by clicking on the internet browser's padlock or key icon.
Cookies
A 'cookie' is a packet of information that allows a website to identify and interact more effectively with a computer. Cookies do not identify you, but they do identify your browser type and Internet Service Provider.
Your browser can be individually set to accept all cookies, reject all cookies, or notify when a cookie is sent. If cookies are rejected, there may be limits on how our websites can be used. To evaluate the effectiveness of our website advertising, we may use third parties such as Google Analytics and Company 360 to collect statistical data. No personal data is collected on these occasions.
Website advertisements
From time to time we place Custom Fleet advertisements on non-Custom Fleet websites. This may involve installing a cookie on a computer when our advertisement is viewed. This simply allows us to keep track of how many unique visitors we have to our site and from what advertisements they entered. This then allows us to measure the effectiveness of different advertisements. The privacy policies of the websites which install the cookies should provide additional information about the use of cookies.
It is important to remember that a browser can be set to reject cookies.
Custom Fleet Entities
The Custom Fleet entities are:
- in respect of our Australian customers, Custom Service Leasing Pty Ltd ABN 60 073 245 084, Custom Fleet Pty Ltd ABN 69 005 093 701, Element Fleet Services Australia Pty Ltd ABN 14 119 426 612 Element Financial (Australia) Pty Ltd ABN 14 119 426 612 and EFN (Australia) Pty Ltd ABN 90 607 344 650; and
- in respect of our New Zealand customers, Custom Fleet NZ Company no. 621355, EFN (New Zealand) Limited Company no. 5759228 and EFN Fleet NZ Limited Company no. 5869341.