Privacy Policy

Zilch Fleet Solutions Limited, trading as Zilch (Zilch, we, us, our), respects your privacy. This Privacy Policy sets out how we collect, hold, use and disclose your personal information, and your rights in relation to it.

Personal information is information about an identified, or reasonably identifiable, individual. All personal information we collect is handled in accordance with the New Zealand Privacy Act 2020 (Privacy Act), including the 13 Information Privacy Principles.

We may update this policy from time to time to reflect changes in the law or our practices. When we do, we will publish the updated policy on our website and update the "last updated" date. We encourage you to review it periodically.

Zilch details

• Registered entity: Carshare NZ Limited, NZBN 9429053681065
• Registered office: 181 Montreal Street, Christchurch Central, Christchurch 8011, New Zealand
• Privacy queries and complaints: support@zilch.co.nz

1. When we collect your personal information

We may collect your personal information (directly from you or through a third party) when you:

use, or apply to use, our services, including registering for and using the Zilch app;

are the driver of one of our vehicles, during your use of that vehicle;

provide services to us, or offer to;

apply for employment with us, or during your employment;

contact us for any reason, including to report a problem or seek assistance;

register or log in to our website, the Zilch app, or our social media pages; or

subscribe to updates, complete surveys, or take part in promotions we offer.

While we aim to collect your personal information directly from you, we may sometimes collect it from other sources, such as:

a public or commercial information services provider, for example when verifying driver's licence details or undertaking a credit check;

the New Zealand Transport Agency or a licence-verification provider, when validating your driver's licence;

another party assisting us to communicate with you, such as an IT services provider;

other businesses involved in dealings with both you and us, such as an insurer in the event of an accident; or

a current or previous employer, when you apply for employment with us.

2. What personal information we collect

The kinds of personal information we collect vary according to our relationship with you, and include:

Contact and identity information — your name, residential address, email address, phone number and date of birth.

Driver's licence and verification information — your driver's licence details and a photograph of your licence, together with a photograph of yourself (a "selfie") that we use to verify that you are the licence holder, and the results of driver-licensing checks.

Payment information — your credit or debit card details and payment history. Card details are processed securely by our payment provider, Stripe; we do not store full card numbers ourselves.

Account information — your username, password, preferences and settings, and your Zilch account balance and activity.

Booking, trip and vehicle information — details of your bookings and your use of our vehicles, including start and end times, and location, distance, route and driving-behaviour data generated by the vehicle's GPS and telematics equipment (for example hard acceleration or hard braking, and any incidents).

Device and usage information — information about your device, app and website use, IP address, and similar technical information, including through cookies and similar technologies.

Any other information you voluntarily provide, or that is otherwise lawfully obtainable under the Privacy Act.

3. If you don't provide your personal information

You are not obliged to provide your personal information to us. However, without certain information we may be unable to verify your eligibility, provide you with a vehicle, or otherwise deliver our services to you.

4. How we use your personal information

We may use your personal information to:

provide our services to you, including verifying your driver's licence and identity, accepting bookings, and giving you access to vehicles;

manage your account, process payments, and administer billing;

operate, maintain and improve the Zilch app, our vehicles and our services;

ensure the safety and security of our vehicles and users, and detect, investigate and prevent fraud, misuse or unsafe conduct;

assess, process and investigate insurance risks and claims, and manage accidents, breakdowns, infringements and recovery of amounts owing;

comply with our legal and record-keeping obligations;

carry out surveys about your experience of our services;

where you have consented, tell you about products, services and offers that may interest you; and

notify you about changes to our services or this policy.

5. How we disclose your personal information

We only disclose your personal information where we are legally permitted to do so, and under arrangements designed to protect it. We may disclose your personal information to:

moqo (our booking and fleet platform provider), which operates the Zilch app and processes booking, account and vehicle data on our behalf;

our other service providers and sub-contractors, including our payment provider (Stripe), our customer-support and communications providers, and our IT, hosting and data-processing providers;

our insurers and professional advisors, in connection with cover, claims and advice;

credit reporting agencies, debt-collection agencies and payment-system participants such as banks;

other parties involved in an accident with one of our vehicles;

authorities responsible for issuing, processing or handling traffic and parking offences, and regulatory bodies and law-enforcement agencies where required;

any of our group companies, on a confidential basis; and

a buyer or prospective buyer of us or any part of our business or assets.

We will not sell, lease, rent, loan or trade your personal information.

6. Telematics and location data

Our vehicles are fitted with GPS and telematics technology that communicates booking, location and usage information between the vehicle and Zilch. We use this information to operate and locate our vehicles, calculate distance-based charges, manage safety and incidents, support insurance and infringement processes, and produce reports and insights on vehicle usage and driving behaviour. Because this technology uses cellular and radio signals, we cannot guarantee the privacy or security of every transmission. Where we share telematics data with third parties other than as needed to perform our agreement with you, we do so on an aggregated basis that does not identify you individually.

7. Cookies and analytics

We collect information through our website and app using cookies and similar technologies, including analytics tools (such as Google Analytics), to understand how our services are used and to improve them. This information is generally aggregated and does not identify you personally. You can disable cookies through your browser settings, although some features may not work as a result.

8. Where we store your information

We may store or process your personal information in New Zealand and overseas. Some of our service providers hold or process personal information outside New Zealand — for example, our booking and fleet platform provider, moqo, is based in the European Union. Where personal information is disclosed overseas, we take reasonable steps to ensure it is protected by comparable safeguards, consistent with the Privacy Act 2020 (including Information Privacy Principle 12). Overseas recipients may be subject to the laws of their own jurisdiction. The service providers we use change from time to time; for a current list of the providers we rely on and the countries where your personal information may be held, please contact us at support@zilch.co.nz.

9. Direct marketing

We will only use and disclose your personal information for marketing purposes within the Zilch group of companies, and only where you have consented to receive such marketing. You can opt out of marketing communications at any time using the unsubscribe option in our messages or by contacting us. We do not sell your personal information to third parties for their direct marketing.

10. Security and retention

We hold your personal information in physical and electronic form, on our own systems and those of our service providers. We take reasonable steps to protect it from misuse, interference, loss, and unauthorised access, modification or disclosure. We will destroy or de-identify personal information when it is no longer required for the purpose we collected it, unless we are required to keep it for legal, accounting or record-keeping reasons, or to establish, exercise or defend legal claims.

11. Your rights

Under the Privacy Act you have the right to request access to the personal information we hold about you, and to request that we correct it if it is inaccurate. To make a request, contact us using the details below. We may need you to verify your identity before we release information, to protect your privacy and that of others. Please be as specific as you can about the information you require.

12. Complaints

If you wish to make a complaint about how we have handled your personal information, please contact us using the details below. We will investigate and inform you of the outcome. If you are not satisfied with our response, you may complain to the Office of the New Zealand Privacy Commissioner (privacy.org.nz).

13. Changes to this policy

We may update this Privacy Policy from time to time. We will publish the updated policy on our website and update the "last updated" date.

14. How to contact us

Please direct all privacy queries and complaints to us at support@zilch.co.nz, or by post to Carshare NZ Limited, 181 Montreal Street, Christchurch Central, Christchurch 8011, New Zealand.