Privacy Policy

Roll and Ride Privacy Policy

Effective Date: July 16, 2025 Prepared for: Saarav Investments Pty Ltd Trading As Roll and Ride, Victoria, Australia.

Purpose: To outline how Roll and Ride collects, uses, discloses, and protects personal information of users of its wheelchair-accessible Commercial Passenger Vehicle (CPV) services, including riders and drivers via our rider and driver apps, ensuring compliance with the Privacy Act 1988 (Cth), Safe Transport Victoria regulations, and accessibility standards.

Privacy Policy

Saarav Investments Pty Ltd Trading As Roll and Ride (“Roll and Ride,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your personal information. As a registered booking service provider (BSP registration A348909) with Safe Transport Victoria, we provide wheelchair-accessible CPV services across Victoria, Australia. This Privacy Policy outlines how we collect, use, disclose, and protect personal information from users (“you” or “your”) of our platform, including our website (www.rollandride.com.au), rider app, driver app, and related services, in accordance with the Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs). This policy applies to both riders (passengers) and drivers (subcontractors using the driver app).

1. What is Personal Information

1.1 Personal information is defined under section 6(1) of the Privacy Act 1988 (Cth) as “information or an opinion (including information or an opinion forming part of a database), whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion.”

1.2 We collect personal information only when directly related to our activities as a BSP and necessary for providing safe, accessible CPV services, including wheelchair-accessible transport, and complying with Safe Transport Victoria regulations.

2. Information We Collect

We may collect the following types of personal information:

2.1 Contact Information: • Name, email address, phone number, and postal address (if provided for billing or communication).

2.2 Payment Information: • Credit/debit card details, bank account details, or Multi Purpose Taxi Program (MPTP) eligibility details for fare processing.

2.3 Trip Information: • Pickup and drop-off locations (including GPS coordinates), trip dates, times, duration, and accessibility requirements (e.g., wheelchair, assistance animal). • Passenger details (e.g., number of passengers, special assistance needs). • Cancellation details (e.g., time of cancellation, applicable charges: 100% up to 4 hours, 50% up to 12 hours, 25% up to 24 hours, 0% up to 2 days less $35.00 admin fee).

2.4 Device Information: • IP address, device type, operating system, browser type, and unique device identifiers.

2.5 Feedback and Complaints: • Feedback ratings, comments, or complaints submitted via the Roll and Ride rider app, driver app, or Complaints Management Register.

2.6 Accessibility Information: • Details related to disability or mobility needs (e.g., wheelchair type, assistance animal) to ensure compliance with the Disability Standards for Accessible Public Transport 2002.

2.7 MPTP-Related Information: • MPTP membership details, subsidy eligibility, and related trip data, as required by Safe Transport Victoria.

2.8 Location Information (App-Specific): • Real-time GPS location data collected via the rider app (e.g., during active trips for navigation, estimated time of arrival (ETA), and safety features) and driver app (e.g., for ride matching, route optimization, and compliance monitoring). • Historical location data, including trip routes and timestamps, for record-keeping and dispute resolution. • Background location access (with your consent) in the apps for features like trip resumption or geofencing alerts (e.g., arrival notifications). We minimize collection to only what is necessary and prompt for explicit permission during app onboarding.

2.9 Driver-Specific Information (via Driver App): • Driver’s license number, vehicle registration, insurance details, and accreditation status with Safe Transport Victoria. • Performance metrics (e.g., trip completion rates, average response time, safety incidents, and rider ratings). • In-app activity logs (e.g., login times, app usage patterns) for training and compliance.

2.10 Other App-Specific Data: • App crash reports, battery level, and network connectivity data (anonymized where possible) to improve app stability and performance. • Push notification preferences and interaction history (e.g., opened notifications).

2.11 We collect personal information directly from you whenever possible, such as when you create an account, make a booking, or contact us. If collected from third parties (e.g., Safe Transport Victoria for MPTP data), we ensure compliance with the APPs.

3. How We Collect Information

3.1 Direct Collection: • Through the Roll and Ride rider app or driver app when you: o Create a Personal or Business Account. o Book CPV services, including wheelchair-accessible transport (riders). o Accept or complete trips (drivers). o Submit feedback, complaints, or inquiries via the apps, email (bookings@rollandride.com.au), phone (+61 468 844 099), or hotline (1300 12 05 05). o Apply for or use MPTP subsidies. o Request cancellation of a booking, with associated data (e.g., cancellation time, charges). • Location data is collected in real-time via GPS when the app is active and location services are enabled, with on-screen indicators and consent prompts.

3.2 Indirect Collection: • From Safe Transport Victoria for MPTP eligibility verification or driver accreditation. • From subcontractor drivers for trip data, per the Trip Record-Keeping Policy. • From third-party payment processors (e.g., Stripe, PayPal) for payment verification. • From mapping services (e.g., Google Maps API) for route data integrated into the apps.

3.3 Browsing and App Usage: • When you browse www.rollandride.com.au without submitting personal information, we do not collect identifiable data. Our internet service provider logs the following for statistical purposes: o Server address. o Top-level domain name (e.g., .com, .org, .au). o Pages accessed and documents downloaded. o Date and time of visit. o Previous site visited. o Browser type and whether you are a returning visitor. • In the apps, we collect anonymized usage data (e.g., screen interactions, session duration) via SDKs for analytics, without linking to personal identifiers unless necessary for support. We do not identify your activities unless required by a law enforcement agency with a warrant to inspect server logs.

4. Purposes of Collection

We collect personal information for purposes directly related to our activities as a BSP, including:

4.1 Providing and managing wheelchair-accessible CPV services.

4.2 Processing bookings, payments, MPTP subsidies, and cancellations (e.g., applying charges: 100% up to 4 hours, 50% up to 12 hours, 25% up to 24 hours, 0% up to 2 days less $35.00 admin fee).

4.3 Communicating with you about bookings, service updates, accessibility accommodations, or promotions (with your consent).

4.4 Responding to inquiries, feedback, or complaints per the Complaints Management Policy.

4.5 Complying with Safe Transport Victoria regulations, including trip data recording, incident reporting, and the 2025 CPV Industry Reform Package.

4.6 Analyzing usage trends to improve service delivery and accessibility.

4.7 Ensuring safety and compliance with the Commercial Passenger Vehicle Industry Act 2017 and Disability Standards for Accessible Public Transport 2002.

4.8 Location-Specific Purposes: Real-time location for ride matching, navigation, ETA calculations, and emergency response; historical data for safety audits and regulatory reporting.

5. How We Use Your Information

We use your personal information to:

5.1 Facilitate and improve CPV services, including matching you with suitable drivers and vehicles (e.g., wheelchair-accessible vehicles).

5.2 Process bookings, payments, MPTP subsidies, and cancellations, ensuring accurate fare and charge calculations per the Trip Record-Keeping Policy.

5.3 Communicate booking confirmations, updates, or accessibility accommodations via email, SMS, or phone.

5.4 Analyze usage trends to enhance user experience, accessibility, and service efficiency.

5.5 Comply with legal and regulatory requirements, including Safe Transport Victoria’s Trip Data Specification and incident reporting obligations.

5.6 Send promotional materials or newsletters (with your consent, which you may withdraw at any time).

5.7 Investigate and resolve complaints or incidents, per the Complaints Management Policy, and report to Safe Transport Victoria if required.

5.8 App and Location-Specific Uses: Use real-time location to optimize routes, monitor driver compliance, and enable safety features (e.g., SOS button in rider app); use driver performance data for training and quality assurance.

6. Information Sharing and Disclosure

We may share your personal information for the following purposes, ensuring compliance with the APPs:

6.1 Subcontractor Drivers: • Share booking and trip information (e.g., name, pickup/drop-off locations, accessibility needs, cancellation details) to enable service delivery. Real-time rider location is shared with matched drivers only during active trips for navigation.

6.2 Service Providers: • Share with third-party providers (e.g., payment processors, cloud storage, GPS providers like Google Maps) who assist in operating our platform, subject to strict confidentiality agreements compliant with the Privacy Act 1988 (Cth). Location data shared with mapping services is limited to trip-specific queries.

6.3 Safe Transport Victoria: • Disclose trip data, MPTP details, cancellation records, or incident reports to comply with regulatory requirements, including the 2025 CPV Industry Reform Package and Public Register obligations. This may include anonymized location trends for safety analysis.

6.4 Legal Purposes: • Disclose to comply with Australian laws, regulations, legal processes, or government requests (e.g., court orders, Safe Transport Victoria audits).

6.5 Business Transfers: • Share in the event of a merger, acquisition, or sale of Roll and Ride’s assets, ensuring continued protection of your information under the APPs.

6.6 We do not sell or share your personal information for marketing purposes without your explicit consent.

7. Data Security

7.1 We implement appropriate technical and organizational measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction, including: • Password protection and encryption for electronic files, with end-to-end encryption for location data in transit via the apps. • Secure storage of paper files in locked cabinets. • Physical and digital access restrictions. • Secure socket layer (SSL) encryption for data transmission via the Application.

7.2 Contact details for email lists, online forms, or inquiries are stored in password-protected databases compliant with the Privacy Act 1988 (Cth). Location data is encrypted at rest and access-logged.

7.3 We conduct regular security audits and train staff and subcontractors on data protection, per Safe Transport Victoria’s requirements.

8. Data Quality

8.1 We take reasonable steps to ensure personal information is accurate, up-to-date, and complete, including: • Updating records when you notify us of changes (e.g., via bookings@rollandride.com.au). • Verifying MPTP eligibility with Safe Transport Victoria. • Cross-referencing trip data with subcontractor driver records per the Trip Record-Keeping Policy. • Validating location data against known trip parameters to prevent errors.

9. Data Retention and Deletion

9.1 We retain personal information only for as long as necessary to fulfill the purposes outlined in this policy or as required by law (e.g., Safe Transport Victoria’s 7-year record-keeping requirement for trip data). Real-time location data is deleted immediately after trip completion, while historical data is retained for 7 years for compliance.

9.2 When you cease using our services or if you have not made a booking, visited our website, or purchased services for 6 months, we will securely destroy or de-identify your personal information, unless required by law to retain it. Driver performance data is retained for 2 years post-relationship end for reference.

9.3 Cancellation-related data (e.g., charges applied: 100% up to 4 hours, 50% up to 12 hours, 25% up to 24 hours, 0% up to 2 days less $35.00 admin fee) is retained per the Trip Record-Keeping Policy for compliance purposes.

10. Cookies and App Tracking

10.1 Our website may use cookies to enhance user experience (e.g., remembering preferences, analyzing site usage).

10.2 In the rider and driver apps, we use similar tracking technologies (e.g., SDKs for analytics) to monitor usage and performance. You can manage app permissions (e.g., location access) in your device settings, but disabling them may affect functionality, such as booking or navigation.

10.3 We use analytics tools (e.g., Google Analytics) to collect non-identifiable data for improving services, with data handled per our security measures.

11. Your Choices and Rights

11.1 Under the Privacy Act 1988 (Cth), you have the right to: • Access personal information we hold about you. • Request correction of inaccurate or incomplete information. • Request deletion of your personal information, subject to legal retention requirements (e.g., Safe Transport Victoria’s record-keeping obligations). For location data, you can revoke app permissions at any time. • Opt out of marketing communications by emailing bookings@rollandride.com.au with “unsubscribe” in the subject line.

11.2 To exercise these rights, contact our Privacy Officer (details in Section 13). We will respond within 30 days, unless a lawful reason (e.g., Freedom of Information Act 1982 (Cth)) prevents access or correction.

11.3 You may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) if you believe we have breached your privacy rights.

12. Updates to this Privacy Policy

12.1 We may update this Privacy Policy to reflect changes in our practices, Safe Transport Victoria regulations, or legal requirements.

12.2 Material changes will be notified by posting the updated policy on www.rollandride.com.au or via the rider and driver apps, with an effective date at least 14 days after posting.

13. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, contact:

• Privacy Officer Saarav Investments Pty Ltd Trading As Roll and Ride

Email: bookings@rollandride.com.au

Phone: +61 468 844 099 Hotline: 1300 12 05 05

Website: www.rollandride.com.au