Privacy Policy

Bartco Traffic Equipment Pty Ltd ACN 109 386 316 and its subsidiaries (us, we, our) are subject to the Privacy Act 1988 (Cth) (Act), the Australian Privacy Principles (APPs) and we may also be subject to other privacy and data protection laws applicable in Australia (together, Privacy Laws). Your privacy is important to us and we are committed to ensuring that your personal information is handled and protected in accordance with all relevant Privacy Laws.

This Privacy Policy (Policy) sets out how we may collect, access, hold, use and disclose (together “process”) personal information in the course of providing our products and services (and operating our business).

We will only process your personal information in accordance with this Policy where we have a lawful basis to do so. If your consent to any processing of your personal information is required, we will ensure it is freely given, specific, informed and unambiguous. You will be provided with clear options to give or withhold consent before any personal information is processed.

This Policy also applies to personal information that we receive from our customers when they use our app or online portal (e.g., for the operation of our products), or when they receive other services from us.

If you have any questions or require any further information about this Policy or our privacy practices, you can contact our Privacy Officer. Their contact details are set out at the end of this Policy.

Bartco has a separate privacy policy in relation to personal information it collects in relation to individuals who are employees or independent contractors of Bartco (or who apply to become employees or independent contractors of Bartco).

What is personal information and sensitive information?

“Personal information” is any information (or an opinion) about an identified individual or an individual that is reasonably identifiable.
“Sensitive information” is a category of personal information and specifically refers to information or an opinion about more sensitive things like an individual’s racial or ethnic origin, religious beliefs or affiliations, sexual orientation or practices, criminal record, and health information.

Collection of personal information

What personal information do we collect?

The personal information that we may collect while providing our products and services (and marketing those products and services) includes the following (in each case, relating to our customers, potential customers, contractors, suppliers and their staff):
• contact information, such as name, position, office and postal address, email address and phone, facsimile and mobile telephone numbers;
• any business name and/or ABN associated or owned by an individual;
• position or title;
• information about devices (and number) requiring access to our app;
• usernames and email addresses;
• billing information, such as bank account details; and
• any other additional information provided to us by those entities and individuals.
We do not collect sensitive information, or information about individuals who are not directly involved in business transactions or product use.
How do we collect personal information?
The table below lists the main ways that we will collect personal information:

How we collect personal information & Examples of when this may occur

Directly from you
• When you contact us (e.g., by phone, email or online enquiry).
• When you create an account to use our app or online portal to remotely program Bartco products, or sign in to use our app or online portal.
• When you contact us seeking technical support relating to our products, app or portal, to make an appointment for a service call, or to carry out repairs or maintenance of Bartco products.
• When you subscribe to receive news and other marketing updates from us.
• When you attend any seminars or functions run by us.
• When we engage you or your employer as a contractor or service provider or we otherwise interact with you in the course of our general business activities.
From third parties
• When you are an employee or contractor of a customer of ours, and that customer creates an account for you to use our app or online platform, or nominates you as a contact person in relation to that customer’s account with us.
From automated services
• When our website stores a cookie in your browser.
• When our web-analytics services log your IP address.

All personal information that we collect is reasonably necessary for the purposes directly relating to providing our products and services to our customers and conducting our general business activities.

Where you voluntarily provide us with personal information, subject to applicable Privacy Laws, we will take this as your implied consent for us to collect your personal information. However, we will construe this implied consent narrowly and in accordance with Privacy Laws, and will not rely on it to handle your personal information in a manner that is not directly related to the purpose for which your personal information was provided, or for a purpose outside your reasonable expectations.

If someone other than you provides us with personal information about you that we did not ask for, and we determine that we could have collected this information from you had we asked for it, we will notify you as soon as practicable (unless to do so would be a breach of confidence). If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

Consequences if personal information is not collected

If we are unable to collect the personal information we reasonably require, then we may not be able to provide our products or services to you or any customer of which you are an employee or contractor (or otherwise interact with you or any such customer while carrying out our business activities).

Cookies

“Cookies” are small data files that may be downloaded to your computer when you visit a website, which may be used to track your use of that website. Cookies must be enabled in order to use web based software products offered by us and may be used to provide users of your computer with information that we think may interest the users of your computer.

We may use cookies from time to time to:

• track your usage of our app, online portal or any software products;
• improve your experience within our app or online platform or any software products we supply;
• provide you with better service when you use our app, online platform or software products;
• authenticate your access to our app, online platform or software products; and
• recognise you when you return to our app, online platform or software products.
This information may be linked to any personal information you may provide and may be used to identify you. You can adjust your internet browser to disable or warn you when cookies are used.
However, disabling cookies may stop our app, online platform or software products from functioning fully.

Use and disclosure of personal information

Purposes for which we process personal information
In relation to personal information that we collect about you, we process that personal information for the following purposes:
• to provide and deliver our products or services to you and our customers;
• to communicate with you and administer our relationship with you;
• to discuss potential updates or advances to our products with you, and to keep you informed of relevant upcoming events and activities;
• to address any query, feedback or complaints you may have, and to record your marketing and communication preferences;
• to manage our business;
• to fulfil and comply with any legal, enforcement (including debt recovery), regulatory and contractual obligations; and
• to fulfil any other purpose that was made clear at the time of collecting that personal information.

If we hold personal information about you that was collected for a particular purpose, then we will not use or disclose that information for another secondary purpose (or in the case of sensitive information, a directly related secondary purpose) without your consent, unless:

• you would reasonably expect us to use or disclose the information for that secondary purpose; or
• that use or disclosure is required by law.

Disclosure to third parties

We will not disclose your personal information to any third party other than as set out in this Policy (or as required by law, to protect our rights or property, or to avoid injury to any person). In order to deliver the products and services that we provide to our customers (and for our app, online portal and software to function properly), we may need to disclose personal information to third party organisations. Any such disclosure is limited to the extent reasonably required to provide our products and services.
Key examples of third parties that may receive personal information from us are:
• contractors and service partners that we may engage to service, repair or maintain any products we have sold or otherwise supplied to you;
• cloud service providers used to host and deliver our online platform (refer to the “Storage and security” section below);
• other technology services that we have partnered with (or that our app, online portal or software integrates with) in order to deliver our products and services, such as
payment systems (e.g., EFT);
• any other service provider we engage to carry out our business functions and activities; and
• our related bodies corporate.

We take reasonable steps to ensure that any third party organisations that may receive personal information from us are bound by privacy and data security obligations in relation to the storage and protection of that personal information.
Transfer of personal information outside Australia

We will only transfer your personal information to our business partners and related bodies corporate who are outside Australia if:

• you consent to the transfer;
• we reasonably believe that the recipient of your personal information is subject to a law or binding scheme that protects personal information in a way that, overall, is at least substantially similar to the way in which the APPs protect the information, and there are mechanisms which you can access to take action to enforce the protection afforded by that law or binding scheme; or
• the recipient of your personal information is subject to the laws of a country that is prescribed by the regulations made under the Act (if any), or is a participant in a binding scheme that is prescribed by those regulations (if any) and, if any country or binding scheme is prescribed subject to conditions, those conditions are satisfied).
Countries to which we may transfer your personal information include the United Kingdom and may, in the future, include other jurisdictions (subject to the above).

External links

Our Site may from time to time contain links to other websites, and those third party web sites may collect information about you. You acknowledge that linked sites are not operated by us, and we take no responsibility for the content or privacy practices of the operators of other websites that are linked to our Site.

Marketing

You acknowledge and agree that by using our products or services we may, from time to time, use personal information collected by us for our marketing and research purposes. This may include sending updates and information related to us or our activities by post, telephone or any form of electronic communication. We may also share your personal information with our partners who may use any email address or other contact information you provide to us at any time for the purpose of contacting you about their products or services, or other offers or promotions.

By using our products or services, you are “opting-in” to us (or any third party partners to whom we may provide your personal information in accordance with this Policy), sending you communications as noted in the previous paragraph. You can, at any time, opt out of receiving our marketing material
by contacting us (or in the case of marketing material of a third party partner, by contacting that third party). Once you opt out of receiving marketing material from us, you acknowledge and agree that this removal from our distribution lists may take several business days after the date of your request to be removed. You acknowledge and agree that even if you opt out of receiving marketing material, we will still send you essential information that is necessary, or we are legally required, to send you relating to the products and services we provide (such as information relating to product recalls).

Research and data analytics

We may, from time to time, conduct data analytics on data relating to the use of our app, online portal and software products. We may use data generated from data analytics processes for the purpose of interpreting the usage of our app, online portal and software products, to evaluate, improve and develop our app, online portal and software and other products, for our internal business purposes, and for research, development and trials.
Before we perform any data analytics we will carefully anonymise, de-identify, alter and/or aggregate any personal information (or we will procure that this is done) – so that individuals are no longer able to be identified and, as such, the relevant information will no longer be personal information (or, if applicable, sensitive information). The de-identification and data analytics processes may involve the use of third party machine learning, visualisation and/or AI tools in a secure environment.

Storage and security

We take reasonable steps to protect personal information from misuse, interference and loss, unauthorised access, modification or disclosure and to comply with the APPs and any other applicable Privacy Laws. This includes adhering to good industry practice in relation to data security and the prevention of data loss.
Digitally stored personal information is held securely and stored on infrastructure that is either owned or controlled by us or a third party service provider (for example, a cloud storage provider) and is encrypted. Temporary access is only provided to those of our employees, our related bodies corporate and their employees and third party service providers who require access to the records in the course of their duties in providing our customers with our products or services, such as troubleshooting and monitoring system functionality. Where we use a third party service provider, we take reasonable steps to ensure that they comply with the Act and any other applicable Privacy Laws.
Despite taking reasonable steps to keep information secure, security cannot be guaranteed and breaches may occur. In the event of a security incident, we have in place procedures to promptly investigate the incident and determine if there has been a data breach involving personal information, and if so, to assess if it is a breach that would require notification under applicable Privacy Laws. If it is, we will notify affected parties and the Office of the Australian Information Commissioner (OAIC), as applicable, in accordance with the Notifiable Data Breaches Scheme under the Act (or, where we do not have a direct relationship with the affected individuals, we will cooperate with the party who has the closest relationship with the affected individuals).
If you reasonably believe that there has been unauthorised use or disclosure of your personal
information, please contact us immediately.

Destruction and de-identification of personal information

Where we hold personal information, and the information is no longer needed (or no longer required by law to be retained by us), we will take such reasonable steps in the circumstances to destroy that personal information or to ensure that the information is de-identified.
Any files that are destroyed are done so through secure electronic destruction processes.
Please also refer to the “Right of erasure” section below.

Changes to this Policy

We may make changes to this Policy from time to time to take account of changes to relevant laws and technology, changes to our business operations and practices and general changes to the external business environment. A current copy of the Policy is maintained on our Site. All personal information held by us will be handled in accordance with the most up-to-date version of the Policy. Where we are permitted to do so under applicable Privacy Laws, if you acquire or use our products and/or services after a change is made to the Policy, we will take such acquisition and/or use as your consent to the updated Policy.

Contacting us

Access and accuracy of personal information
You have the right under the Act to seek access to or correct your personal information held by us if it is inaccurate, incomplete, out of date or misleading. If you want to access your personal information, or if you believe that it is inaccurate, incomplete, out of date or misleading, please contact us in writing (see below).
We will respond to any such request within a reasonable period and we will grant access, provided the request does not fall under one of the exceptions to access stated in the APPs. We may charge a reasonable fee for providing that information.
Access may be denied in certain circumstances permitted under the Act (such as where the request creates a serious threat to the life or safety, or is otherwise unlawful).

Right of erasure

You may request that we delete your personal information where:
• it is no longer necessary for the purpose for which it was collected;
• you withdraw your consent (where consent was the basis for processing); or
• the information was unlawfully collected.
We will assess and respond to such requests in accordance with the Act.

Enquiries and complaints

If you want to make a complaint about our management of personal information, to correct information or to request further information, please contact us. Our Privacy Officer will contact you about your complaint or request as soon as reasonably practicable and we will attempt to resolve it with you.
If you are not satisfied with the outcome of your complaint or request, you may refer the matter to the OAIC by visiting the website www.oaic.gov.au. Further information about the Act and the APPs is also available from the OAIC.
Legal remedies
You may also seek legal remedies for serious breaches by us of your privacy under the Act.

Contact details

If you wish to contact us in relation to any privacy related matter, please use any of the following methods of contact:

Email: privacy@bartco.com.au
Telephone: 1300 306 106
Address: 7 Westside Avenue, Port Melbourne, Victoria 3207 Australia

Last update to this Policy: October 2025