Wright Express Australia Pty Ltd (Wright Express) infrastructure provides a platform for a full range of quality card based services, including the development of proprietary label cards. Wright Express is committed to the delivery of a range of sophisticated, customised solutions designed to suit the changing needs of Australian businesses and an increasingly high level of service.

Wright Express Prepaid Cards Australia Pty Ltd, is committed to protecting your privacy and the confidentiality of your personal information.

We are bound by the Privacy Act 1988 (Commonwealth) as amended, and the principles set out in that Act.

This Privacy Policy outlines how we manage your personal information.

We collect information from you when:

• you open an account;
• you fill in an application form; and
• you deal with us over the telephone, send us a letter, visit our web sites, or when you have contact with us in person.
Via our website Our system automatically collects some information from your computer when you complete an application and when you log in to our system through one of our websites. Generally, the information that we collect in this way is not personal information and cannot be used to identify you.

The person information we collect always includes your name and may also include your mailing address, telephone number, e-mail address, date of birth and your financial details.

Our system automatically collects the unique network address of your computer, generally called the "IP address", so that our system can send information to your computer. It is possible to determine the general geographical location of a computer from its IP address. But in all other respects an IP address is anonymous.

We only collect your email address when you voluntarily submit it to us. We do not use your email address and IP address to personally identify you.

For security and record keeping purposes, we use "cookie" technology to collect and retain information about the session between your computer and our system.

What is a "cookie"? A cookie is a small text file stored by a web site on your computer to keep track of information about your browsing on that site.

We also collect non-identifying information about your use of one of our websites, such as the www.giftvouchers.com. We aggregate this information with information collected from other users so that we can evaluate and improve the services provided through our system.

We collect your personal information to provide you with a particular product or service; for example, opening a giftvouchers.com account.

If you do not provide us with all of the personal information that we request, we may not be able to provide you with the product or service you have requested.

We may also use or disclose your personal information for purposes related or ancillary to the main reason we collect it, such as:

• servicing our relationship with you;
• internal accounting and administration;
• regulatory reporting and compliance;
• protecting you and Wright Express from error and fraud; and
• helping us to identify and inform you about other products or services that may be of benefit to you.

We may contract out some of our functions and activities; for example, we may provide names and addresses to a mailing house to mail account statements to you. In these situations, we prohibit the third parties from using personal information about you except for the specific purpose for which we supply it.

We do not use any Commonwealth agency identifiers, such as Medicare numbers, as your account, policy or application number.

We have a duty to keep confidential all personal information we hold about you, including:

• your name, address, and financial data;
• the debit or credit balance in your account; and
• details of transactions on your account.

Our duty of confidentiality applies except where disclosure of your personal information is:

• compelled by law

For example, disclosure to various Government departments and agencies such as the Australian Taxation Office, and disclosure to courts under subpoena.

• in the public interest

For example, where a crime, fraud or misdeed is committed or is suspected, and disclosure against the customer’s rights to confidentiality is justified.

• in Wright Express’s interest

For example, disclosure to a court in the event of legal action to which Wright Express is a party; or necessary disclosures.

• with your consent.

Your consent is important.

Your consent can be express or implied.

Your express consent can be verbal or written.

Your consent is implied when we can reasonably conclude that you have given consent by some action you take, or when you decide not to take action. For example, if you use our telephone service and continue the call after hearing the recorded message telling you that the call may be monitored for training purposes, you have given us your implied consent to monitor your call.

Except where it is required by law, we only disclose personal information to third parties with your express or implied consent.

Wright Express does not disclose names and addresses to third parties for the purposes of allowing them to direct market their products and services unless you have given your prior consent. From time to time our website hosts links to the websites of other business that we think could offer products and services to our customers. If you access those websites or give those business information, this will be governed by the privacy policies of those third parties. We are not responsible for information privacy and data security practices of these businesses. We recommend that you read the privacy policy of any business that you deal with before you give personal information.

Sometimes, we give your personal information to service providers contracted by us so that they can help us provide services to you. The service providers are contracted to fulfil a specific function and we only disclose such personal information to them as is necessary to fulfil that function. Our services providers must comply with the Privacy Act 9188 (Commonwealth) in the management of your personal information.

We may, from time to time, transfer to and store your personal information with contracted service providers located in the United States of America. If we do transfer your personal information to our service providers in the United States of America, it will be managed in accordance with the terms of the Privacy Act 1988 (Commonwealth) and with this Privacy Policy.

From time to time we may use the personal information we have collected from you to identify products and services, which may be of interest to you. We may then contact you by phone, post or electronic means to let you know about these products or services.

If you do not wish to receive direct marketing information, you can tell us at any time. Just call us on 03 9274 9100.

If we have accurate personal information about you, it enables us to provide you with the best possible service. Please contact us if any of your personal information changes. We take reasonable steps to ensure that your personal information is accurate, complete and up-to-date whenever we collect or use it.

You can request access to the information we hold about you. The type and quantity of information requested dictate the time it will take us to supply personal information. We will contact you regarding your request within three working days of receipt to advise you of the expected response time. Please be aware that the provision of some types of information may incur a fee. You will be advised of any charges after we have reviewed your written request.

You can contact us in the following ways

• call our Customer Relations Team on 03 9274 9100
• Write to us at Reply Paid 1659 GPO Box 5342, Melbourne, VIC, 3001
• e-mail us at privacy@wrightexpress.com.au

We protect any personal information that we hold from misuse and loss. We also protect it from unauthorised access, modification and disclosure.

Only authorised users can access your personal information, and access is only for approved purposes.

Your personal information may be stored in hardcopy documents, as electronic data, or in our software or systems.

We maintain physical security over our paper and electronic data stores and premises, such as locks and security systems. We also maintain computer and network security. For example, we use firewalls (security measures for the Internet) and other security systems such as user identifiers and passwords to control access to computer systems.

The Internet has rapidly changed the way we do business. It allows Wright Express to provide services that you can access from the convenience of your own office, home or via a mobile device.

We understand that you may be concerned about the confidentiality and security of the personal information we collect about you online. Accordingly, we have systems in place to ensure our online dealings with you are as secure and confidential as your dealings with us in person, or on the telephone.

Data collected and transferred through the secured member log in section of this site uses Secure Socket Layer (SSL) technology. This protects information being transmitted on-line by automatically applying to the message an encryption code that is "unreadable" to a computer that is not the intended recipient.

This site uses 128-bit encryption and authentication tools to protect your personal information. Encryption is the standard means of protecting information transferred between two parties over the Internet.

In the event that your personal information is transferred to a service provider in the United States of America, the data transferred is also protected by SSL technology. In addition, it is protected by an advance security method based on dynamic data and encoded session identifications, and is hosted in a secure server environment that uses firewalls, intrusion detection systems and other advanced technology to prevent interference or access from outside intruders.

If you believe that the privacy of your personal information has been compromised, you are entitled to complain. We will respond to your complaint as soon as possible but within 2 working days, to let you know who is responsible for managing your complaint. We will try to resolve the complaint within 10 working days. When this is not possible, we will contact you within that time to let you know how long we estimate it will take to resolve the complaint.

We have also appointed a Customer Advocate who will objectively and impartially investigate your complaint if you are dissatisfied with our internal complaints process.

If you have a complaint about the handling of your personal information, you are entitled to complain. We will take responsibility for your complaint at the point where the problem occurs. If your complaint is not resolved to your satisfaction, you can then contact our Privacy Officer between 9am and 5pm Eastern Standard Time, to deal with your complaint.