1 Our Privacy Commitment
1.1 At Transurban (USA) Holdings Inc. and Transurban DRIVe Holdings LLC, we take privacy seriously. We consider this Privacy Policy to be an important document that provides clear guidelines for you to understand how we manage personal information and steps we take to protect your privacy.
1.2 This Privacy Policy (“Privacy Policy”) outlines the commitment of Transurban (USA) Holdings Inc., Transurban DRIVe Holdings LLC, and each of their respective subsidiaries, as well as our retail brands that operate under those Transurban entities, including but not limited to 95 Express Lanes, 395 Express Lanes, 495 Express Lanes and GoToll (collectively, “Transurban” or “we”, “us” or “our”) to protect the privacy of our customers’ personal information and other personal information we receive in the conduct of our business, including but not limited to when you travel on our toll roads or roads where we provide tolling services, use our mobile apps, register a customer account with us, visit our websites (www.transurban.com and www.gotoll.com), participate in surveys or competitions, or otherwise communicate with us (collectively referred to as “services”). Transurban’s corporate website complies with U.S. law. Depending on your state of residency, you may have additional rights, specifically:
(a) If you are a California resident, the entirety of this Privacy Policy applies to you, but please also read the “Your California Privacy Rights” section near the end for additional California-specific disclosures and information regarding your rights under California law.
(b) If you are a Virginia resident, the entirety of this Privacy Policy applies to you, but please read the “Your Virginia Privacy Rights” section near the end for additional Virginia-specific disclosures and information regarding your rights under Virginia law.
For privacy policies applicable to operations in other countries where we operate, please refer to those country-specific privacy policies which are available here: Australia and Canada.
2 What does this Privacy Policy do?
2.1 This Privacy Policy describes the kinds of personal information we collect, how we look after the personal information we collect, why we collect it, and how we hold, use and disclose personal information.
2.2 By using our products or services or by otherwise providing personal information to us, you agree to be bound by the terms of this Privacy Policy.
2.3 We may need to change this Privacy Policy. If we do, we’ll post the updated version on this page and on each relevant retail brand website. The updated version will take effect from the date stated at the top of the Privacy Policy.
2.4 If the changes are significant, we will aim to provide a more prominent notice of the change and, where possible, send our customers a notification of the changes.
2.5 We encourage you to check our website from time to time to be aware of the current Privacy Policy and how it applies to you.
3 What information do we collect?
3.1 We collect information to provide products, services and information to our customers and to the community.
3.2 We also collect information where we are required to do so to comply with the law.
3.3 The types of personal information we collect depends on the circumstances in which the information is collected and the purpose it was collected for.
3.4 The main types of personal information we collect include:
(a) your name and contact details.
(b) identification details (such as date of birth).
(c) your organization and position, where your organization has a business account or business dealing with us.
(d) information on your use of our products and services, including use of our roads, our websites and our apps.
(e) records of our communications and dealings with you, such as telephone, email, SMS, webchat, and other online and in-person communications.
3.5 When you travel on our roads or on roads where we provide tolling or billing services, or if you have a customer account with us, we will collect information such as:
(a) your license plate number.
(b) your vehicle make, model, year, color, registration, owner and in some instances, acquisition date.
(c) your trip details.
(d) photos and videos of vehicles, which may include occupants in vehicles or people on the roadside.
(e) tolls and fees charged, paid, not paid and owed.
(f) your account balance.
(g) your transponder details.
(h) your billing details.
(i) your payment methods, such as credit card and bank details.
(j) your driver’s license details.
(k) information to determine or verify if you are entitled to a discount or concession.
3.6 We may also collect information about use of your vehicle or your travel arrangements, such as other roads that you use, driving and travel patterns, parking locations, fuel purchase information and use of public transport.
3.7 We may record and monitor telephone calls and other communications between you and us for training, quality control, verification and compliance purposes.
3.8 When you communicate with us, we may collect additional information including the languages you speak, your family and living circumstances, your property, how best to manage communications with you and information about your dealings with us.
3.9 If you participate in a survey or competition, or respond to a feedback request, we will collect the information that you provide in doing so and associated information such as when and how you submitted your response.
3.10 We may collect information about property ownership in relation to properties near our existing or proposed roads or above our existing or proposed tunnels and associated underground services.
3.11 We collect information about people who invest in Transurban stapled securities.
3.12 We collect information about people who are our contractors, suppliers and business partners, or who are employed by our contractors, suppliers and business partners. The information we collect focuses on information needed to conduct business with that individual or party.
3.13 When you do business with us, including if you have a corporate account with us, we may collect information about you from others, such as from referees or from others who do business with you.
3.14 We collect information about people who visit our sites and our offices. This may include videos of you when you are in or near our sites or offices.
4 Do we collect sensitive personal information?
4.1 We will only collect sensitive information about you with your consent and if the information is reasonably necessary for Transurban’s functions or activities, or if we are otherwise allowed or required by law to collect that information.
4.2 Information that could be considered sensitive information includes, but is not limited to, information about your health, racial or ethnic origin, religious beliefs, membership of a professional or trade association, membership of a trade union, biometric information that is to be used for the purpose of automated biometric verification or biometric identification, and criminal record.
5 What information do we collect when you use our online services?
5.1 This section applies to use of online services that we control, such as websites, apps, social media and other online services.
5.2 When using our online services, we and our technology partners may collect information about you and how you use our online services.
5.3 We may collect information such as:
(a) user name and password.
(b) which services you use and how you use them.
(c) device information, such as the model and ID of the device you use, your operating system, telephone number and mobile phone network.
(d) Server log information, such as details of how you used the service, your IP address, hardware settings, browser type, browser language, the date and time of your use and referral URL.
(e) cookies that may uniquely identify your browser or your account (please see Section 5.4 below).
(f) location information.
5.4 Transurban and our third-party partners may use cookies and other similar tracking technologies (e.g., web beacons, device identifiers and pixels). Cookies are small pieces of data stored on the web browser of your device. These are used by us for site administration and analysis purposes as well as delivering tailored content and online behavioral advertising to you. Online behavioral advertising involves collecting information about your online activities over time and across different websites and apps in order to infer your preferences and interests. Such advertising may include combining information from different browsers and devices. We may use the information we collect via cookies and similar technologies for retargeting, which involves delivering on Transurban and third-party digital services advertisements regarding offerings you have viewed on Transurban sites and apps. For example, if you review content regarding one of our mobile applications, we or our partners may deliver ads regarding the application when you access Transurban or other digital services. If don’t wish to take advantage of cookies, you may configure your browser not to accept them (although this may disable or render unusable some of the features of our online services). We make no representations regarding the policies or practices of third-party advertisers or advertising networks or exchanges or related third parties. You can decide whether to accept or reject cookies. When you first visit our website, you will be presented with a banner which offers you a choice about whether to accept or reject cookies or tracking technologies of different types, except for those cookies which are strictly necessary. If you wish to amend your choice at any time, you can do so using selecting the link here. You can also set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. You can learn more about online behavioral advertising and opt-out of receiving some targeted ads by visiting www.aboutads.info. If you do not want to receive online behavioral advertising in our mobile apps, you can limit or turn off mobile device ad-tracking in your device settings on each of the devices you use, if your devices have such settings. Alternatively, you can uninstall our apps from your devices.
5.5 Our online services may also detect and use your IP address or domain name for internal traffic monitoring and capacity management purposes or to otherwise administer the online services. The patterns of usage of visitors to the online services may be tracked for the purposes of providing improved service and content based on aggregate or statistical review of user traffic patterns.
5.6 Our online services may use third-party services such as Google services (such as Google Analytics, Google Ads, Invisible reCAPTCHA and Google Maps). For example, if you allow our online services to access your device location, our website or app may use Google Maps to collect your location and locate nearby stores. For more about how Google collects and processes data, please see Google's Privacy Policy, Google Terms of Service and their information on how Google uses your data.
5.7 From time to time, we may use third-party online services to collect personal information such as your name and email address or telephone number to administer online competitions, customer feedback and surveys.
5.8 Our online services may contain links to other websites. We are not responsible for the privacy practices or the content of other websites. The privacy practices applicable to other websites may differ substantially from ours. Please read the privacy policy of any other websites you visit before using them.
6 How do we collect information?
6.1 We collect your personal information in the following ways:
(a) You give it to us. We collect information when you or your representatives provide us with information. For example, this might happen when you’re setting up an account with us or where we ask you to provide certain personal information, including where you participate in a trial or survey.
(b) When you use our products or services. For example, when you use our roads, we collect information about your road use. We collect information through technological means, including:
(i) automatic incident detection systems (including traffic management and safety cameras).
(ii) vehicle registration detection systems.
(iii) electronic toll collection systems (such as a transponder attached to an individual's vehicle).
(iv) tolling cameras and CCTV.
(v) apps and websites, including where you have agreed to disclose information about your location while using one of our websites or apps.
Please see Section 5 above for information we collect when you use our online services.
(c) When you visit our work locations, sites, or offices. For example, we may video record people on or near our sites, accessing our work areas, or in our offices.
(d) From third parties. We may obtain information from outside sources such as generally available publications, information available online or through social media platforms and providers. This may also include collecting information from:
(i) other people associated with your toll account, such as your employer, family members or people jointly on the account.
(ii) other people such as referees you to us or from others who do business with you, if you have a corporate account with us.
(iii) government road and traffic authorities, and service providers to government authorities (such as companies that provide traffic camera services to police.
(iv) other U.S. toll-road operators.
(v) researchers.
(vi) other companies where you have consented to them providing your information to us, and
(vii) suppliers of information products and services (such as companies that consolidate data from multiple public sources).
6.2 You must only provide us with personal information about someone else, if that person consents to you doing so and to us collecting, holding, using and disclosing their personal information in accordance with this Privacy Policy.
6.3 If you choose not to provide certain personal information to us, we may not be able to fulfil your request or provide you with certain services or information relating to us.
7 How do we use your personal information?
7.1 We use and disclose your personal information:
(a) to provide products, services and information to our customers and to the community.
(b) for the purposes for which it was collected.
(c) in order to improve our products and services.
(d) in order to operate and improve our roads, and to undertake administrative or operational activities associated with designing, constructing, managing and operating our roads.
(e) in order to make special offers or to undertake promotions related to our products or services, including from our retail brands, business or partners or government road or traffic authorities, that we think may be of interest to you.
(f) in order to conduct surveys.
(g) to maintain our relationship with you.
(h) to verify your identity and personal information.
(i) to maintain and update our records.
(j) to calculate and recover tolls and fees.
(k) for debt collection and enforcement purposes.
(l) to investigate or to pursue any legal claim that we may have against you.
(m) for road safety purposes.
(n) for security purposes.
(o) to assist the enforcement of laws.
(p) to undertake traffic planning and vehicle management services.
(q) to meet our obligations and perform our functions under applicable laws and agreements.
(r) to detect, prevent and investigate any fraud or crime (or suspected fraud or crime).
(s) to notify you of changes to our tolls, fees, charges, agreements, products or services.
(t) as otherwise required or authorized by law.
7.2 Other U.S. operators. We may exchange certain personal information with other U.S. toll-road operators as necessary to provide services to you. For example, if you open an account with us, we may use and disclose your personal information for the purposes of facilitating your travel on our roads and any other U.S. toll-roads with whom we have information sharing arrangements in place. Such information sharing arrangements allow the operators of those roads to obtain payment for travel when you travel on their roads. When we share your personal information with other U.S. operators for toll collection and enforcement, your personal information may become subject to the privacy policies of those other operators. For example, when we share your personal information with the Transportation Corridors Agencies (“TCA”), which operate the toll roads in Orange County, California, your personal information will be subject to the TCA’s Toll Roads Privacy Policy.
7.3 Road incidents. If your vehicle is involved in or in the vicinity of a road incident, we may disclose your personal information to emergency services, insurance providers and towing, roadside support and maintenance and logistics contractors. This information may include images and video footage of the incident and the vehicles involved, as well as the details of any vehicles and occupants. A road incident also includes property and road damage caused by your vehicle or a vehicle that you are in.
7.4 Required by law. We may disclose your personal information to the police and to other government law enforcement agencies where it is required by law or where we believe it is reasonably appropriate to do so. We may provide police with real time access to our systems, for example, to access and view footage from our cameras.
8 Direct marketing and research.
We may use and disclose your personal information to carry out consumer, market, community and traffic research, compile demographics and perform other analysis so that we can develop and implement initiatives to improve our services, improve the design, construction and operation of our roads and identify people likely to be affected by or interested in our roads and services.
8.1 We may use and disclose your personal information for marketing purposes. We may contact you about our products and services, the products and services of other Transurban retail brands, the products and services of other people, or related special offers from our rewards partners and/or business partners, that we think may be of interest to you. This information may be sent to you by email, SMS or by other means. You can opt-out or unsubscribe from receiving these types of promotional communications by:
(a) following the “unsubscribe” link in the communication.
(b) changing your account settings.
(c) contacting us here.
8.2 Unsubscribing from promotional communications will not stop service- related communications from us, such as administrative alerts in relation to your account and notifications in relation to road closures.
9 Who do we disclose your personal information to?
9.1 We may disclose your personal information:
(a) subject to any restrictions imposed by any relevant legislation, among the Transurban entities named in this Privacy Policy, their related entities (including related entities located in Australia and Canada) and their retail brands.
(b) under information sharing arrangements with the operators of other U.S. toll-roads.
(c) to government agencies, such as government agencies responsible for the operation of roads, vehicle registration, transport or emergency services.
(d) to any entity responsible for the collection of tolls or the taking of enforcement action concerning use of our roads.
(e) to anyone who acquires or considers acquiring our assets or business (or any part of it).
(f) where you have consented to that disclosure, for example to a secondary contact nominated on your account or to one of our rewards partners.
(g) as required or permitted by law, for example, in response to a subpoena, warrant, or request from a government law enforcement agency, or as required under legislation and regulations applying to our roads.
(h) to the Tolling Customer Ombudsman.
(i) to insurance companies.
(j) to our consultants, contractors, subcontractors, suppliers, service providers, professional advisers and agents, such as:
(i) call center operators.
(ii) mailhouse, printhouse and warehouse organizations.
(iii) marketing, advertising and information service providers including social media services and data supply companies.
(iv) legal and accounting firms.
(v) contractors that own or operate distribution outlets (such as convenience stores and electronic kiosks).
(vi) banks, financial institutions and payment processing providers.
(vii) towing, roadside support and maintenance and logistics contractors (such as if you or your vehicle are involved in or near a road incident).
(viii) engineers and surveyors.
(ix) researchers and investigators.
(x) insurers.
(xi) delivery supply contractors.
(xii) information technology suppliers that provide support, maintenance and upgrade services for our systems.
9.2 In certain circumstances, you may nominate by way of statutory declaration a person who operated your vehicle on our toll road. If this occurs, we may contact that person and inform them of the details of your nomination.
10 When do we de-identify information?
10.1 We may de-identify information about an individual so that the information can no longer be related to that individual.
10.2 We may then use and disclose that de-identified information in the course of our business.
10.3 We may also aggregate information on the use of our services and roads (for instance, traffic information) in such a way that the information can no longer be related to the specific individuals.
10.4 We may then use and publicly disclose such aggregated information in the course of our business.
11 When do we disclose information overseas?
11.1 We may disclose information to recipients that are located in a different jurisdiction to you and to recipients located outside of the United States. We may disclose personal information to contractors outside of the United States and may use off-shore servers for the purposes of data storage. We have engaged contractors in We have engaged contractors in Australia, the Philippines, Portugal, France, India, Canada, New Zealand, South Africa, Sweden and certain other countries and may disclose certain personal information to those contractors.
11.2 We may also disclose certain personal information to our related entities in Australia and Canada, although such information will typically only relate to employees and internal corporate matters and not customer information or the operation of our roads in the United States.
11.3 We will only transfer personal information to a recipient in a foreign country in circumstances where the information will have appropriate protection. We will take all steps reasonably necessary to ensure that your personal information is treated securely and in accordance with this privacy policy when transferred or stored outside of your country of residence. Where we have engaged international third parties to perform services in respect of any personal information collected from you, we will use contractual or other means to ensure such third parties offer a comparable level of protection in respect of the personal information.
12 How do we secure your information?
12.1 We use reasonable safeguards and security measures that are designed to protect personal information we hold about you is protected from risks such as misuse, interference, unauthorized access, modification or disclosure. We use a number of physical and electronic measures to protect your personal information.
12.2 However, the Internet is not a secure environment. Although due care is taken, we cannot guarantee the security of information provided to us via electronic means or stored electronically.
12.3 Personal information is only retained for as long as is necessary for the identified purposes or as required by law.
13 How can you access and correct your information?
13.1 You have a right to access the personal information that we hold about you. You may do so by contacting us.
13.2 We will not charge you a fee for your access request, but we may recover from you our reasonable costs of supplying you with access to this information.
13.3 When you request access to personal information, we may need to take measures to verify your identity before providing you with such information.
13.4 In some circumstances it may not be possible for us to provide you with all of your personal information. For example, we may not be able to give you access if it would unreasonably affect someone else’s privacy. If we do not provide access to the personal information held about you, we will tell you why.
13.5 We will take reasonable steps to only hold personal information about you that is accurate, complete, up-to-date, relevant, and not misleading.
13.6 If you think that any personal information we hold about you is inaccurate, you may contact us. We will take reasonable steps to make sure that the information is corrected.
13.7 We reserve the right to refuse to correct your personal information in some circumstances. If we refuse to correct any personal information about you, and we cannot reach a subsequent agreement, you may request that a note or statement regarding the correction requested be attached to the file that contains your personal information.
13.8 If you are a California resident, please read the “Your California Privacy Rights” section for additional disclosures and information regarding your rights under California law.
13.9 If you are Virginia resident, please read the “Your Virginia Privacy Rights” section for additional disclosures and information regarding your rights under Virginia law.
14 What information do we collect when you apply to work with us?
14.1 When you apply to work with us, we may collect certain information from:
(a) you.
(b) recruitment consultants.
(c) your previous employers.
(d) your referees.
(e) other sources of relevant information, such as educational institutions, professional and trade associations, referees and publicly available sources.
14.2 The information we collect will assist us to decide whether to make an offer to you to work with us.
14.3 In addition to the information set out above (see paragraph 3.4), the information we collect may include information about your:
(a) work history.
(b) education and other qualifications or licenses
(c) skills.
(d) character.
(e) eligibility to work.
14.4 As necessary and where appropriate, we may carry out screening checks (such as background, directorship, financial probity, identity, eligibility to work, vocational suitability and criminal record checks).
14.5 Some of the personal information we collect may be considered sensitive information under certain privacy regulations. For example, we may collect:
(a) health information (such as medical checks on job applicants, information relevant to COVID-19 vaccination status if the information is reasonably necessary for Transurban’s functions or activities)
(b) criminal information (such as police checks on job applicants)
(c) union memberships and affiliations (such as membership information about your industry union)
14.6 Subject to privacy regulations, we may sometimes collect sensitive information about you from a third party. If you think we have received your sensitive information in error, you may contact the Transurban U.S Privacy Officer by email at USprivacy@transurban.com.
15 Data Retention
15.1 We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements.
15.2 When we have no ongoing legitimate business need to process your personal information, we are committed to either deleting or de-identifying it.
15.3 When you close your account or request that we delete your personal information, we may retain your personal information for up to 180 days (a) in order to facilitate the final reconciliation of your account, and (b) for archival, audit, disaster recovery, legal, or regulatory purposes, subject to our data retention policies.
16 What information do we collect about you when you work for us?
16.1 In addition to the information we may collect when you (i) apply for employment with us and (ii) commence working with us, we may collect information about your:
(a) training
(b) employee benefits
(c) banking details
(d) emergency contacts
(e) employment performance
(f) conduct
(g) use of Transurban's facilities, IT (including software applications) and communications resources
(h) leave, and
(i) tax.
16.2 We collect this information to train and manage our employees and meet our legal obligations.
16.3 Some of the personal information we collect may be considered sensitive information under certain privacy laws. For example, we may collect:
(a) health information (such as in connection with road incidents, impact of construction work, sick leave or medical checks on job applicants and employees, information relevant to COVID-19 vaccination status if the information is reasonably necessary for Transurban’s functions or activities),
(b) criminal information (such as police checks on job applicants and employees),
(c) union memberships and affiliations (such as membership information about your industry union), or
(d) biometric information for the purpose of identity verification.
16.4 Subject to privacy laws, we may sometimes collect sensitive information about you from a third party. If you think we have received your sensitive information in error, you may contact the Transurban U.S. Privacy Officer by email on USprivacy@transurban.com.
17 Our Policy towards children
17.1 Our websites, apps, social media and other online services are not for use by individuals under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that a child under the age of 16 has provided us with personal information, we will take steps to delete such information. If you become aware that a child has provided us with personal information, please contact us.
18 Complaints and further information
18.1 If you want to talk to us about your privacy please contact the Transurban U.S. Privacy Officer by email on USprivacy@transurban.com. We are happy to discuss how we handle your personal information, how your personal information is collected or about any other aspect of our Privacy Policy.
18.2 If you are concerned about the way we deal with personal information, please contact us in writing.
Please:
(a) include a method for us to contact you.
(b) clearly describe your concerns.
We will aim to respond as soon as we can. If you are not satisfied with our response, you may also contact the relevant regulator or the U.S. Tolling Customer Ombudsman.
Alternatively, you can contact the Transurban U.S Privacy Officer by email at USprivacy@transurban.com.
You can also contact us.
19 Definitions
19.1 This Privacy Policy applies to, and a reference to “we”, “our” or “us” means, the following entities to the extent they collect, use and disclosure personal information in or from the United States the following entities:
(a) each of Transurban (USA) Holdings Inc. and Transurban DRIVe Holdings LLC and each of their respective subsidiaries.
(b) all the retail brands that operate under those Transurban entities, including but not limited to 95 Express Lanes, 395 Express Lanes, 495 Express Lanes and GoToll.
We are proud to operate the following retail brands: 95 Express Lanes, 395 Express Lanes, 495 Express Lanes and GoToll.
20 Your California Privacy Rights
20.1 California law requires businesses to use specific terms when describing the types of information we collect. Please note that we collect the same personal information from California residents as we do from residents of other states as described above, and we use all personal information as described above. For purposes of our disclosures under California law, we collect the following types of personal information:
(a) Identifiers (such as name, email or physical address, online identifiers, date of birth, IP/MAC address, vehicle registration information, log-in credentials, account information including transponder number)
(b) Financial account information (such as payment card information)
(c) Geolocation data (specifically precise location when you are traveling on toll roads or roads for which we handle toll billing)
(d) Commercial information (such as a record of our services for which you have registered an account or other purchasing history or tendencies)
(e) Demographic and profile information (such as information in your publicly available social media profile)
(f) Internet or network activity information (such as browsing history, your interaction with our websites and apps, and your engagement with advertisements)
(g) Protected characteristics (such as sex, gender, race, ethnicity, citizenship, or nationality, in connection with your application to work for us)
(h) Education information (in connection with your application to work for us)
(i) Professional or employment-related information (such as your current or past employer and job title, whether in connection with a business account with us or your application to work for us)
(j) Audio, electronic, visual, or similar information (such as photographs of you moving through our toll roads or recordings of your telephone conversations with our customer service representatives)
(k) Inferences drawn from any of the above information
20.2 We use and disclose your personal information:
(a) to provide products, services and information to our customers and to the community.
(b) for the purposes for which it was collected.
(c) in order to improve our products and services.
(d) in order to operate and improve our roads, and to undertake administrative or operational activities associated with designing, constructing, managing and operating our roads.
(e) in order to make special offers or to undertake promotions related to our products or services, including from our retail brands, business or partners or government road or traffic authorities, that we think may be of interest to you.
(f) in order to conduct surveys.
(g) to maintain our relationship with you.
(h) to verify your identity and personal information.
(i) to maintain and update our records.
(j) to calculate and recover tolls and fees.
(k) for debt collection and enforcement purposes.
(l) to investigate or to pursue any legal claim that we may have against you.
(m) for road safety purposes.
(n) for security purposes.
(o) to assist the enforcement of laws.
(p) to undertake traffic planning and vehicle management services.
(q) to meet our obligations and perform our functions under applicable laws and agreements.
(r) to detect, prevent and investigate any fraud or crime (or suspected fraud or crime).
(s) to notify you of changes to our tolls, fees, charges, agreements, products or services.
(t) as otherwise required or authorized by law.
20.3 We retain personal information we collect from you where we have an ongoing legitimate business need to do so. For example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements. When we have no ongoing legitimate business need to process your personal information, we are committed to either deleting or de-identifying it. When you close your account or request that we delete your personal information, we may retain your personal information for up to 180 days (a) in order to facilitate the final reconciliation of your account, and (b) for archival, audit, disaster recovery, legal, or regulatory purposes, subject to our data retention policies.
20.4 Some of the personal information we collect may be sensitive personal information under California law, including precise geolocation and driver’s license number. We do not sell sensitive personal information or disclose it for cross-context behavioral advertising. You may limit the use of your sensitive personal information to the extent necessary to perform our services or as otherwise permitted by California law. To do so, click on Limit the Use of My Sensitive Personal Information.
20.5 We disclose the personal information listed in Section 20.1 with our service providers, affiliates, and subsidiaries for business purposes. Services providers include data storage providers, payment processors, email providers, data security providers, professional advisors, advertising partners and platforms, data analytics providers, and any other entity that provides services to us in connection with operating our business and providing services to you. We also share identifiers with other road operators to enable you to use your transponder on those other roads. Additionally, we disclose identifiers and geolocation information to government entities in connection with their operation of toll roads.
20.6 We do not sell personal information in exchange for any monetary consideration; however, we may share personal information for purposes of cross-context behavioral advertising (also known as targeted advertising). You have a right to direct us not to sell or share your personal information. If you opt out, we will not disclose your personal information to third parties for purposes of targeted advertising.
20.7 We described ways you can access and correct your information in the above section, “How can you access and correct your information?” If you reside in California, you may have the right to access specific pieces of your information, the right to know further details about our processing of your information, the right to request deletion of your personal information, the right to have inaccurate personal information corrected, the right to prevent the sharing of your personal information with third parties in certain circumstances, and the right to not be denied our services for exercising these rights.
(a) You can exercise these rights by:
(i) Emailing us at customercare@expresslanes.com
(ii) Calling us at 855-495-9777
(iii) Visiting our “Contact us” webpage
(b) We may need to verify your identity before fulfilling your request to exercise your rights.
(i) If you hold an account with us, we will verify your identity by having you log into your account or verify account-specific activity or information including through a channel other than your account.
(ii) If you do not have an account with us, you will need to provide information to establish your identity to the degree of certainty required by law. Such information may include name, email address, or other information relating to your use of your websites, apps, or services.
(c) We accept consumer rights requests from authorized agents received through the designated methods set forth above, as required by law. While we will fulfil your rights request through an authorized agent where we can verify the authorized agent’s authority to act on your behalf, we may notify you as the consumer of the agent’s request on your behalf, and we also may require that you as the consumer verify your identity before we fulfil the request through your agent.
(d) We will retain certain information relating to your rights requests to demonstrate our compliance with applicable law, as well as to improve our consumer request and response processes.
21 Your Virginia Privacy Rights
21.1 Virginia law requires us to limit the collection of personal information (referred to as “personal data” in the Virginia Consumer Data Protection Act and in this Section 21) to what is adequate, relevant, and reasonably necessary. Please note that we collect the same personal data from Virginia residents as we do from residents of other states as described above, and we use all personal data as described above. For purposes of our disclosures under Virginia law, we collect the following categories of personal data:
(a) Identifiers (such as name, email or physical address, online identifiers, date of birth, IP/MAC address, vehicle registration information, log-in credentials, account information including transponder number)
(b) Financial account information (such as payment card information)
(c) Geolocation data (specifically precise location when you are traveling on toll roads or roads for which we handle toll billing)
(d) Commercial information (such as a record of our services for which you have registered an account or other purchasing history or tendencies)
(e) Demographic and profile information (such as information in your publicly available social media profile)
(f) Internet or network activity information (such as browsing history, your interaction with our websites and apps, and your engagement with advertisements)
(g) Protected characteristics (such as sex, gender, race, ethnicity, citizenship, or nationality)
(h) Education information (in connection with your application to work for us)
(i) Professional or employment-related information (such as your current or past employer and job title, whether in connection with a business account with us or your application to work for us)
(j) Audio, electronic, visual, or similar information (such as photographs of you moving through our toll roads or recordings of your telephone conversations with our customer service representatives)
(k) Inferences drawn from any of the above information
21.2 Some of the personal data we collect may be sensitive personal data under Virginia law, including precise geolocation.
21.3 We disclose the personal data listed in Section 21.1 with our service providers, affiliates, and subsidiaries for business purposes. Services providers include data storage providers, payment processors, email providers, data security providers, professional advisors, advertising partners and platforms, data analytics providers, and any other entity that provides services to us in connection with operating our business and providing services to you. We also share information with other road operators to enable you to use your transponder on those other roads. Additionally, we disclose identifiers and geolocation information to government entities in connection with their operation of toll roads.
21.4 We do not sell personal data, as defined by Virginia law.
21.5 We described ways you can access and correct your information in the above section, “How can you access and correct your information?” If you reside in Virginia, you may have the right to confirm whether we are processing your personal data, access specific pieces of your data, have inaccurate personal data information corrected, request deletion of your personal data, obtain a copy of your data information previously provided to us in a readily usable format, to the extent technically feasible, and opt out of the processing of your personal data for purposes of targeted advertising and profiling. Please note that the right to opt out of profiling is contingent on such profiling presenting a reasonably foreseeable risk of (i) unfair or deceptive treatment of, or unlawful disparate impact on, consumers; (ii) financial, physical, or reputational injury to consumers; (iii) a physical or other intrusion upon the solitude or seclusion, or the private affairs or concerns, of consumers, where such intrusion would be offensive to a reasonable person; or (iv) other substantial injury to consumers.
(a) You can exercise these rights by:
(i) Emailing us at customercare@expresslanes.com
(ii) Calling us at 855-495-9777
(iii) Visiting our “Contact us” webpage
(b) We may need to verify your identity before fulfilling your request to exercise your rights.
(i) If you hold an account with us, we will verify your identity by having you log into your account or verify account-specific activity or information including through a channel other than your account.
(ii) If you do not have an account with us, you will need to provide information to establish your identity to the degree of certainty required by law. Such information may include name, email address, or other information relating to your use of your websites, apps, or services.
(c) We accept consumer rights requests through authorized agents, as required by law. While we will fulfil your rights request through an authorized agent, we may notify you as the consumer of the agent’s request on your behalf, and we also may require that you as the consumer verify your identity before we fulfil the request through your agent.
(d) We will retain certain information relating to your rights requests to demonstrate our compliance with applicable law, as well as to improve our consumer request and response processes.
(e) You may appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to USprivacy@transurban.com.