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.

Protecting your privacy and the confidentiality of your personal information is fundamental to the way we do business.

Wright Express has a long history of handling personal information confidentially. We treat very seriously the ongoing trust you have in us to protect your personal information.

We have robust systems and procedures in place to protect your privacy whenever we collect, store, use or disclose your personal information.

The Wright Express Privacy Policy explains how we protect your privacy, including:

• The importance of your consent before we disclose your personal information to third parties;
• how we respect your privacy in the course of using your personal information; and
• how your privacy is protected when you access our web sites via the Internet.

This Privacy Policy only covers the Australian operations of Wright Express.

We collect most personal information directly from you. For example, we may collect personal information when you open an account, fill in an application form, deal with us over the telephone, send us a letter, visit our web sites, or when you have contact with us in person.

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

We may use personal information for related purposes

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 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. Please allow a little time for your instructions to one part of Wright Express to flow through to the rest of Wright Express.

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 (02) 9955 8366
• write to us at Reply Paid 1659, GPO Box 5342, Malvern Vic 3144
• 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 Wright Express’s 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.

We have comprehensive security policies and procedures documented in our internal security policy. Your personal information will be recorded, amended and deleted only by authorised means.

In addition, all employees sign confidentiality agreements as a condition of working for Wright Express.

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 home or office.

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

Details relating to our web site security and privacy are available from the giftvouchers.com Web Site Security and Privacy Statement at: www.giftvouchers.com

We respond quickly to complaints

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.