Privacy Policy

1. Who we are

Club Plate Co. (“Club Plate Co.”, “we”, “us”, “our”) is a Victorian limited partnership, ABN 25 733 190 203. We operate the website and member application at clubplate.co (the “Platform”) and we are a car club approved by VicRoads to participate in the Victorian Club Permit Scheme (the “Scheme”).

This Privacy Policy explains how we collect, hold, use and disclose personal information about members, applicants, vehicle owners, partner businesses and their staff, and visitors to the Platform. It should be read with our Membership Terms and Conditions.

2. Our commitment

We handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (“APPs”). Club Plate Co. is a small business operator under the Privacy Act and is not legally required to comply with the APPs. We have chosen to comply with them anyway, because the information we handle as a VicRoads-approved club includes driver licence and vehicle identity details that warrant that standard.

We also comply with the Spam Act 2003 (Cth) in our electronic marketing and participate in the Notifiable Data Breaches scheme.

3. What personal information we collect

The kinds of personal information we collect depend on how you interact with us.

Members and applicants

• Identity details: full name, date of birth, and a photograph or copy of identity documents where we need to verify identity.
• Contact details: email address, mobile number, residential address and postal address.
• Driver licence details: licence number, state of issue and expiry date.
• Vehicle garaging address, which VicRoads requires for a club permit.
• Vehicle details: make, model, year of manufacture, body type, colour, VIN or chassis number, engine number, current and previous registration or permit numbers, build and compliance details, import approval details where relevant, modification details and any VASS approval certificate.
• Roadworthiness details: Certificate of Roadworthiness number, issue date and the licensed vehicle tester who issued it.
• Photographs of the vehicle in the views we request, and any supporting documents you upload.
• Scheme documents you prepare and sign through the Platform, including your club permit application, eligibility declaration and membership certificate, together with signing metadata such as the time, IP address and device used.
• Membership details: join date, renewal dates, membership status, permit and plate numbers once VicRoads issues them, and your history of applications and endorsements.
• Payment details: the amount, date and status of payments, and a payment token issued by our payment provider. We do not receive or store your full card number.
• Your communications with us, including emails, SMS, in-app messages and any complaints.

Partner businesses and their staff

• Business name, ABN, trading name and business address, which we verify against the Australian Business Register.
• Names, roles, email addresses and mobile numbers of the people who use the Platform on the business’s behalf, and the driver licence details of staff who are required to provide them.
• Payout account details held by our payment provider, and records of commission earned and paid.

Visitors and all users

• Technical and usage information: IP address, browser and device type, operating system, pages viewed, actions taken in the Platform, referring website, and the date and time of visits.
• Marketing attribution: the campaign, source or advertisement that first brought you to the Platform, stored in your browser.
• Cookies and similar identifiers, described in section 9.

Sensitive information

We do not ask for sensitive information such as health information, racial or ethnic origin or criminal history. Please do not include it in documents or messages unless it is necessary. If you do, we will handle it only for the purpose for which you provided it and with your consent.

4. How we collect personal information

We collect personal information:

• directly from you, when you create an account, apply for membership, add a vehicle, upload documents, sign forms, make a payment, contact us or attend an event;
• from a Partner acting on your behalf, where a workshop, mechanic or other business you have engaged prepares an application for you. Partners must have your authority to give us your information and must refer you to this Policy. You will always be asked to review and approve an application prepared for you before we act on it;
• from third parties, including Google if you sign in with a Google account, the Australian Business Register when we verify a Partner’s ABN, and VicRoads where it contacts us about a member or vehicle; and
• automatically, through cookies, analytics tools and server logs when you use the Platform.

If you do not provide the information we ask for, we may not be able to accept your membership, endorse your application or provide the Platform to you.

5. Why we collect, hold and use personal information

We use personal information for the following purposes:

• to assess your application for membership and administer your membership, including renewals and payments;
• to assess whether you and your vehicle are eligible under the Scheme, and to complete, sign and where applicable lodge club permit paperwork as a VicRoads-approved club;
• to maintain the register of financial members that VicRoads requires approved clubs to keep, and to meet our other obligations under the Scheme;
• to respond to requests from VicRoads about a member, vehicle or permit, and to notify VicRoads when a member’s financial membership ends;
• to verify identity, detect and prevent fraud, misuse of the Scheme, or the use of stolen or misrepresented vehicles;
• to process payments, refunds, and Partner commissions;
• to communicate with you about your account, applications, permits and renewals, by email, SMS and in-app notification;
• to provide support and respond to enquiries and complaints;
• to operate, secure, maintain and improve the Platform, including analytics about how it is used;
• with your consent or as otherwise permitted by law, to send you marketing about the Club and related offers, and to measure the effectiveness of our advertising; and
• to comply with our legal obligations and to establish, exercise or defend legal claims.

We may also use de-identified or aggregated information, which does not identify you, for any purpose.

6. Who we disclose personal information to

VicRoads (Department of Transport and Planning)

Because we are an approved club under the Scheme, we disclose personal information to VicRoads. This includes:

• the contents of your club permit application and eligibility declaration, which we endorse and which you or we lodge with VicRoads;
• confirmation of your name, address, licence details, vehicle details and membership status, and the dates your membership started or ended, when VicRoads asks us to verify a member, vehicle or permit, or audits the Club;
• notice that you have ceased to be a financial member, which the Scheme requires us to give; and
• information about suspected misuse of the Scheme, where we consider it appropriate to report it.

VicRoads handles the information it receives under its own privacy policy and Victorian privacy law.

Partners

If a Partner prepared your application, we share the status of that application with the Partner so they can support you. We do not give Partners access to your account, payment details or documents beyond those they provided.

Service providers

We use third-party providers to operate the Platform. They may access personal information only to perform services for us, and are bound by contract to keep it confidential and secure. At the date of this Policy our providers include:

Function	Provider	Information involved
Payments, subscriptions and Partner payouts	Stripe	Name, email, payment details, transaction history, Partner payout details
Electronic signatures	DocuSeal	Content of signed Scheme documents, signer name, email, signing metadata
Transactional email	Resend	Email address, message content
SMS	Cellcast	Mobile number, message content
Product analytics	PostHog	Usage and device information, account identifier
Advertising measurement	Meta (Facebook) Pixel	Browser identifiers, pages viewed, conversion events
Sign-in and address lookup	Google	Google account identifier and email if you sign in with Google; address text entered for lookup
Content management	Directus	Platform content; limited account identifiers
Internal operational alerts	Discord	Limited event details, such as a new application or payment, visible only to our team
Hosting and infrastructure	Railway, Vercel	All Platform data in transit and at rest
ABN verification	Australian Business Register	Partner ABN and business details

We will update this table when providers change. You can ask us for a current list at any time.

Others

We may also disclose personal information to:

• our professional advisers, insurers and auditors;
• law enforcement, courts, regulators or other government bodies where required or authorised by law, or where we reasonably believe disclosure is necessary to prevent a serious threat to safety or to investigate unlawful activity;
• a person who acquires or proposes to acquire the Club or the Platform, subject to confidentiality obligations; and
• any other person with your consent.

We do not sell personal information.

7. Overseas disclosure

Personal information we hold is stored and processed in Australia and the United States. Providers that store or process information in the United States include PostHog, Meta, Google, Stripe, Resend, DocuSeal and our hosting providers. We do not disclose personal information to recipients in any other country.

Before disclosing personal information overseas we take reasonable steps to ensure the recipient handles it consistently with the APPs, including through contractual terms. By using the Platform you consent to these overseas disclosures. Overseas recipients may be subject to foreign laws and may not be bound by the Privacy Act.

8. How we hold and protect personal information

Personal information is held in encrypted databases and file storage hosted by the providers listed above. We protect it through access controls limited to staff and Authorised Officers who need it, encryption in transit and at rest, logging, and regular review of our systems. Payment card details are held by Stripe, not by us.

No method of transmission or storage is completely secure. If you believe your account has been compromised, contact us immediately.

9. Cookies, analytics and advertising

The Platform uses cookies and similar technologies to keep you signed in, remember your preferences, understand how the Platform is used and measure our advertising.

• Product analytics. We use PostHog to record how people use the Platform. Analytics requests are routed through our own domain, and the data is stored by PostHog in the United States.
• Advertising measurement. We use the Meta Pixel to measure whether our advertising on Meta platforms leads people to join. Meta may combine this with information it holds about you under its own privacy policy. You can manage this through your Meta ad preferences.
• Attribution. When you first arrive we store the source, campaign or referrer in your browser so we know which channel brought you to us.

You can control cookies through your browser settings, including blocking or deleting them. If you block cookies, some parts of the Platform may not work, in particular signing in.

10. Direct marketing

We may send you marketing by email or SMS about the Club, member benefits and related offers, where you have consented or would reasonably expect it. Every marketing message includes an easy way to opt out. You can also opt out at any time by emailing [email protected] or updating your preferences in your account.

Opting out of marketing does not stop service messages about your account, applications, permits and renewals, which we must send while you are a member.

11. How long we keep personal information

We keep personal information for as long as it is needed for the purposes described in this Policy and to meet our legal obligations, including our record-keeping obligations as an approved club under the Scheme and under tax law.

As a guide:

• membership records, Scheme documents, vehicle details, photographs and payment records are kept for the duration of your membership and for 7 years after it ends, which also satisfies tax record-keeping requirements;
• analytics, usage and communication records are kept for 7 years from collection; and
• marketing preferences and opt-out records are kept for as long as needed to honour them.

When information is no longer needed we delete it or de-identify it. You may ask us to delete your information sooner. We will do so where no legal or Scheme obligation requires us to keep it.

12. Access and correction

You may ask for access to the personal information we hold about you, and ask us to correct it if it is inaccurate, out of date, incomplete, irrelevant or misleading. Most account, contact and vehicle details can be viewed and updated directly in your account.

To make a request, email [email protected]. We may need to verify your identity. We will respond within 30 days. We do not charge for making a request, but may charge a reasonable fee for providing copies of large volumes of information. If we refuse a request we will explain why in writing and tell you how to complain.

Because signed Scheme documents are legal records, we will not alter a signed document. If you identify an error in one, we will note the correction on your file and help you lodge a corrected document with VicRoads if needed.

13. Data breaches

If we experience a data breach that is likely to result in serious harm to individuals, we will notify the Office of the Australian Information Commissioner and the affected individuals as required by the Notifiable Data Breaches scheme, and tell you what steps you can take.

14. Children

The Platform is for people aged 18 and over. We do not knowingly collect personal information from anyone under 18. If you believe we have, contact us and we will delete it.

15. Complaints

If you have a concern about how we have handled your personal information, contact us at [email protected]. We will acknowledge your complaint within 5 business days, investigate it, and respond in writing within 30 days.

If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner:

• Web: oaic.gov.au
• Phone: 1300 363 992
• Post: GPO Box 5288, Sydney NSW 2001

16. Changes to this Policy

We may update this Policy from time to time. We will publish the current version on the Platform and notify members of material changes by email. The version date at the top of this Policy shows when it was last updated.

17. Contact

Club Plate Co.
ABN 25 733 190 203
Email: [email protected]
Web: clubplate.co