Privacy Policy
1. INTRODUCTION
1.1 . Ajen Monitoring Systems (ACN 132 153 694) trading as Smart Start Interlocks Australia (collectively Ajen, we our or us) takes its privacy obligations seriously. Ajen is committed to maintaining the privacy of personal information that is collected from customers, prospective employees, and all parties (each an individual) connected with Ajen.
1.2. This Privacy Policy has been created so individuals can fully understand how their personal information is collected, managed and used in Ajen’s business. It is important that Ajen is open and transparent about the personal information collected and how that personal information is, stored, used and disclosed.
1.3. This Privacy Policy covers all activities of Ajen and its Associated Entities in Australia.
1.4. Ajen handles personal information in an open and transparent manner consistent with the objectives of the Australian Privacy Principles and each other Applicable Law, recognises the importance and is committed to protecting the privacy of individuals through protection of personal information it holds.
1.5. By accessing or using our website, requesting we provide you with, or accepting, any service provided by us or our Associated Entities, or you make disclosure to us of your personal information, you agree to the collection, use, handling and disclosure of your personal information in the manner set out in this Privacy Policy and otherwise as permitted by Applicable Law.
1.6. We recommend that you carefully read this Privacy Policy before using or continuing to use our website, requesting or accepting the provision of our services, or disclosing any personal information to us.
2. WHAT IS PERSONAL INFORMATION AND SENSITIVE INFORMATION
Personal Information
2.1. Personal information includes any information or opinion about an identified individual, or where their identity can reasonably be ascertained from the information or opinion, whether the information or opinion is true or not, and whether the information or opinion is recorded in material form or not.
2.2. Personal information collected, held, disclosed or used by us may include:
2.2.1. your name, gender, date of birth, vehicle information, next of kin information, drivers licence details;
2.2.2. address, contact details, email address;
2.2.3. financial information;
2.2.4. photographs (where required under the applicable State Program);
2.2.5. the services which are to be provided by us to you;
2.2.6. data which is generated or obtained as a result of alcohol and other monitoring devices used in the provision of services to you and without limitation to the forgoing includes logged events and photographs (Monitoring Data);
2.2.7. other personal information (including sensitive information) which is reasonably required in order for us and our Associated Entities to lawfully provide services to you; and
2.2.8. records of transactions and communications between you, us, our Associated Entities, Regulatory Authorities and/or other third parties in connection with our supply of services to you.
What is sensitive information?
2.3. Sensitive information is a special category of personal information and includes any information or opinion about an individual’s racial or ethnic origin, political opinions, membership of apolitical association, religious belief or affiliations, sexual preferences or practices, criminal record or health information.
3. COLLECTION
We will collect personal information from you in the following ways:
3.1. directly from you, unless it is not reasonable or practical to do so;
3.2. from third parties including our Associated Entities, Regulatory Authorities and your representatives; and
3.3. by any lawful and fair means.
Collecting information from you
3.4. Ajen collects personal information where required or permitted under Applicable Law and it is reasonably necessary in connection with its supply of services and related products.
3.5. How Ajen collects your personal information will largely depend on whose information it is collecting. If it is reasonable and practicable to do so, Ajen will collect personal information directly from you.
3.6. Depending on how you choose to interact with Ajen, Ajen may collect your personal information when you:
3.6.1. interact with Ajen or its representatives by telephone, by email, through our website, during in-person communication or when you complete a form or document and provide it to Ajen;
3.6.2. utilise the devices made available to you by Ajen in connection with our services including any monitoring device; and
3.6.3. when you transact with Ajen in any other manner.
3.7. You acknowledge that any third party who drives or otherwise operates a vehicle fitted with a monitoring device may have their photograph taken by the device and it is your responsibility to notify any third party who may drive or operate the vehicle that the monitoring device is equipped with a camera and that their photograph may be captured during use of the motor vehicle.
Collecting information from third parties
3.8. In some instances, it may not be reasonable or practical to collect personal information, directly from you, including in an emergency, where Ajen may need to collect your background health information from relatives, health service providers or an applicable Regulatory Authority.
3.9. You acknowledge and where applicable give your consent to the applicable Regulatory Authority providing, and Ajen collecting, your personal information for the purpose of Ajen delivering the required services to you, and in connection with the applicable State Program. For example, a Regulatory Authority may disclose to Ajen:
3.9.1. your licence number and date of birth (including in circumstances where the information you provide Ajen does not match the Regulatory Authority’s records);
3.9.2. licence information, including any suspension, cancellation, restriction or condition applicable to the applicable State Program;
3.9.3. vehicle registration information, for the purpose of determining registration status; and
3.9.4. your contact information including phone number, email address, mailing address.
3.10. Ajen may also collect personal information from other third parties relating to your credit worthiness, solvency and/or bankruptcy status where you give your express consent or Ajen is otherwise permitted to do so under Applicable Law.
Collecting information by lawful and fair means
3.11. Ajen must only collect personal information by lawful and fair means.
3.12.. For the purposes of this Privacy Policy:
3.12.1. ‘lawful’ collection is a collection that does not breach any Applicable Law.
3.12.2. ‘fair means’ is collection without intimidation or deception, and in a way that is not unreasonably
Notification of collection
3.13. Ajen will take reasonable steps to notify you of certain matters (Collection Notice), generally before or at the time of collection of personal information, to ensure you are aware of:
3.13.1. the fact personal information is being collected about you;
3.13.2. the purpose for Ajen collecting the personal information;
3.13.3. the consequences (if any) of you not consenting to the collection of your relevant personal information, or such personal information not being accurate and up to date, which may include Ajen and its Associated Entities being unable to provide services to you and your participation in the applicable State Program being unable to be recorded, monitored and assessed;
3.13.4. how you can gain access to the personal information which we have collected and hold in relation to you.
3.14. If it is not practicable to provide you with a Collection Notice before or at the time of collecting your personal information, then a Collection Notice shall be given to you as soon as practicable afterwards.
Unsolicited information
3.15. If Ajen receives personal information that it has not requested, or it determines that the personal information received is not reasonably necessary to provide its services, Ajen will, if required by Applicable Law, take reasonable steps to de-identify or destroy any record of that personal information.
4. USE, RETENTION, AND DISPOSAL
4.1. Ajen will only collect, hold, use or disclose personal information:
4.1.1. for the primary purpose of providing our services to you, including in accordance with any requirements, or to perform any function, arising under the applicable State Program;
4.1.2. for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure;
4.1.3. if Applicable Law requires or authorises Ajen to do so, including without limitation, in relation to any mandatory reporting or notification requirements;
4.1.4. for the purpose of research being undertaken to facilitate improvement in the services being provided by us under each State Program; and
4.1.5. for the purpose of informing, you about our services, promotions and events, or other opportunities that may interest you (Direct Marketing). Ajen will not:
(a) collect, hold, use or disclose any of your sensitive information or any personal information which is collected from a Regulatory Authority or other third party for the purposes of Direct Marketing; or
(b) engage in any Direct Marketing with you where it is prohibited under a State Program or Applicable Law, you have opted out’ or if you have asked us to cease doing so at any time by contacting us using the contact details under section 14
4.2. All personal information which we collect from you is retained by Ajen throughout the period in which we provide services to you (Service Period).
4.3. After the expiry of the applicable Service Period, all documents containing personal information which are:
4.3.1. physical documents are retained by Ajen for a period of not less than seven (7) years and we will only destroy or dispose of those documents after the expiration of that period, with the permission of the relevant Regulatory Authority; and
4.3.2. digital or electronic in nature are retained indefinitely.
5. STORAGE AND DATA SECURITY
5.1. Ajen will take reasonable steps to securely store and protect the personal information collected by us from misuse, loss, theft as well as against unauthorised access, modification or disclosure, alteration and destruction.
5.2. Ajen stores and archives physical documents containing personal information in accordance with applicable guidelines specified under relevant Australian Standards (AS ISO 15489);
5.3. Electronic data which includes personal information and is held by Ajen is encrypted and protected by secure methods utilising proprietary software known as ‘Smartrac’ (Electronic Data).
5.4. Electronic Data is stored on computer servers located in Sydney, Australia and backed up securely at an alternate location within Australia.
5.5. In addition, Electronic Data is protected by commercially prudent means including password access, firewalls and other protection measures such as:
5.5.1. administrative processes;
5.5.2. technical safeguards; and
5.5.3. physical infrastructure and site security.
6. DISCLOSURE OF PERSONAL INFORMATION
6.1. Access to your personal information which is collected and held by Ajen is only accessible to personnel of Ajen’s representatives and other personnel who reasonably require such access in connection with performance of their duties and in connection with provision of our services or other lawful obligations contemplated under this Privacy Policy, the relevant State Program or Applicable Law.
6.2. Ajen may make disclosure of your personal information to:
6.2.1. a Regulatory Authority, alcohol education assessors in accordance with the requirements of an applicable State Program, including for the purposes of administration, monitoring, assessment and evaluation of your participation in the applicable State Program, or as otherwise required or permitted under Applicable Law; and
6.2.2. to courts and other relevant law enforcement bodies in accordance with the requirements of an applicable State Program or as otherwise required or permitted under Applicable Law.
6.3. Ajen may also make disclosure of your personal information to third parties where the disclosure is:
6.3.1. to a third party collection agency for the purposes of recovering a debt you owe us;
6.3.2. to a third party service provider in connection with the provision of services and conduct of our business (including performing any requirement under a State Program), which may include service providers engaged in data hosting, application development, web analytics, survey administration, customer communications, marketing, sales support and customer support;
6.3.3. to a third party advertising platform (including Google) for the purposes of audience management in a hashed or pseudonymised format and which is processed using industry-standard encryption techniques; however, it may be matched by the recipient advertising platform against its own user database; or
6.3.4. made to a third party with your express consent, and where that disclosure is permitted under Applicable Law.
6.4. If Ajen does make disclosure of your personal information to a third party as contemplated under section 3, it will do so only on the basis that the relevant third party:
6.4.1. is obligated to implement and maintain sufficient security measures to securely store and protect the personal information disclosed to it from misuse, loss, theft as well as against unauthorised access, modification or disclosure, alteration and destruction;
6.4.2. is prohibited from using your personal information for any purpose other than which we are authorised to use your personal information and in any event is necessary to perform the function or provide the service the third party is required to perform or provide (as the case may be); and
6.4.3. has agreed to comply with the requirements of this Privacy Policy as may be applicable in the relevant circumstances.
7. TRANS BORDER DATA FLOWS
7.1. Unless Ajen is prohibited pursuant to Applicable Law or contractual terms which are binding upon it (including the requirements of a State Program), Ajen may disclose your personal information to our Associated Entities, third party service providers or other third parties located outside of Australia where:
7.1.1. we reasonably believe that the recipient of the personal information is subject to a law, binding scheme or contract which effectively upholds the principles for fair handling of the personal information that are substantially equivalent to the Australian Privacy Principles;
7.1.2. it is reasonably necessary for the performance of an obligation or the exercise of a right arising under a contractual arrangement between us, or any pre-contractual steps taken in response to an interaction between you and Ajen; or
7.1.3. the transfer is for your benefit, it is impracticable to obtain your express consent prior to the transfer occurring and if it were practicable, you would likely give such consent,
and we have taken reasonable steps to ensure the information which it has transferred will not be held, used or disclosed by the recipient of the information inconsistently with the Australian Privacy Principles.
7.2. As at the date of this Privacy Policy, Ajen may disclose personal information to overseas recipients located in the United States of America and Canada and will update this Privacy Policy from time to time to reflect any changes to the countries in which overseas recipients are likely to be located.
8. ACCESS TO YOUR PERSONAL INFORMATION AND ACCURACY
8.1. Ajen shall take all reasonable steps to make sure that the personal information that it collects, holds, uses, and discloses is accurate, complete, and up to date.
8.2. You have a right to access personal information held by us about you and to correct any information about you that is not correct at that time.
8.3. In the case where Ajen holds information about an individual, the individual may request access to this information by contacting our Support Centre using the details set out in section 14 of this Privacy Policy.
8.4. However, Ajen and its representatives may exercise the right to refuse or restrict access to personal information, under Applicable Law, including in the circumstances:
8.4.1. where providing access would pose a serious threat to the life or health of any individual;
8.4.2. where providing access would have an unreasonable impact on the privacy of other individuals;
8.4.3. the request for access is frivolous or vexatious;
8.4.4. where information relates to anticipated or current legal proceedings and such information would not be accessible through the process of discovery in those proceedings;
8.4.5. providing access would be unlawful;
8.4.6. denying access is required or permitted by Applicable Law; or
8.4.7. where providing access would be likely to prejudice an investigation by a Regulatory Authority or law enforcement agencies.
8.5. If access to this personal information is denied, Ajen will notify the individual of the reason for this restricted access.
8.6. If information is held about an individual that they believe is inaccurate, incorrect or incomplete, Ajen will take reasonable steps to correct the information as required under Applicable Law, and to the extent that Ajen refuses to correct such information, we will provide reasons for this refusal.
9. ANONYMITY
Wherever it is lawful and practical, individuals have the option of not identifying themselves through provision of personal information when interacting with Ajen. However, it is generally required that an individual makes disclosure of their personal information to enable us to provide our services to them.
10. EMPLOYEES
10.1. Ajen will hold and retain any information provided by potential employees, including personal information outlined in CVs, cover letters and other documents. Ajen will not intentionally collect or store sensitive information regarding potential employees.
10.2. Ajen holds personal information of its employees where required for the operation of the business and when required by law.
10.3. Ajen may collect, hold, use and disclose employee’s personal information for all purposes connected with its employment relationship. This employment relationship includes hiring, training, administration of personnel records (including remuneration and leave records) and managing performance.
10.4. Personal information collected and held in relation to employees includes, but is not limited to their:
10.4.1. name;
10.4.2. date of birth;
10.4.3. pay and tax information;
10.4.4. leave information;
10.4.5. criminal record checks;
10.4.6. bank and superannuation information;
10.4.7. third party reference checks;
10.4.8. sensitive information obtained in connection with employee drug and alcohol tests as specified in our workplace policies from time to time; and
10.4.9. all information provided in cover letters and CVs provided to Ajen at the time of employment or otherwise provided during the recruitment process.
11. INTERNET
Our Websites
11.1. The Ajen website can be found at: ajen.com.au. Other associated websites, include:
11.1.1 the Smart Start website which can be found at smartstartinterlocks.com.au; and
11.1.2. our Agent Support website, which can be found at agentsupport.com.au.
11.2. Visits to websites listed in section 1 above, may be logged and collect information (Web Data), including but not limited to:
11.2.1. the type of operating system you are using;
11.2.2. domain name you are accessing;
11.2.3. the address of any linked website which referred you access the relevant website;
11.2.4. your servers IP address;
11.2.5. the date and time of the visit; and
11.2.6. internal traffic in different areas of the website, including files downloaded.
Third Party Online Tools
11.3. Ajen makes use of social media and online tools. This includes, but is not limited to: Facebook, X, Instagram, Google Plus, YouTube, SurveyMonkey and LinkedIn. When contacting Ajen via these services, it is important to review and acknowledge the privacy policies of the respective websites, applications and platforms.
11.4. Additionally, a Facebook plugin may be used by our Websites. Facebook functions are offered by Meta Platforms., 1 Metra Way, Menlo Park, California, 94025, USA. By using these functions, an individual can share a contribution on Facebook and follow Ajen on Facebook, if they have their own Facebook account. This involves transmitting data to Facebook pursuant to its terms and conditions of use.
11.5. As a provider of websites that host these functions, Ajen have no knowledge of the content of the data transferred to and used by Facebook. Individuals should visit https://www.facebook.com/privacy/policy/ for further information about Meta data protection and privacy declaration. Privacy preferences can be changed at Facebook in account settings and privacy.
11.6. Occasionally, Ajen will link to third party websites and we will make all reasonable efforts to ensure safety and accuracy, we do not accept any responsibility or liability for these third-party websites and you use these links at your own risk.
12. PRIVACY BREACH AND NOTIFICATION
Complaints
12.1. If you have a complaint related to how Ajen has managed your personal information, please contact Ajen using the contact information set out in section 13 Ajen may ask you to place details of your complaint in writing in order for it to fully understand and investigate the issues you have raised. All such complaints will be handled with the appropriate discretion.
12.2. If a complaint remains unresolved, you may access an external dispute resolution service or apply to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au to have the complaint heard and determined.
12.3. Further information on the Privacy Act and the Australian Privacy Principles can be found at privacy.gov.au.
Mandatory Breach Notices
12.4. Where required by Applicable Law or requirements of a relevant State Program, Ajen will immediately notify the applicable Regulatory Authority if we become aware of any:
12.4.1. breach or possible breach of Applicable Law, by any of our Associated Entities, employees or other representatives; or
12.4.2. complaint concerning the collection, use, handling of disclosure of any personal information,(Mandatory Breach Notification).
12.5. Any Mandatory Breach Notification will include the particulars of the breach and/or complaint (as the case may require) and the proposed response, including any investigation, timeframe, and the steps that will be taken to remedy any breach and prevent further breaches of the same or similar nature from occurring.
13. CONTACT DETAILS
If an individual has any questions or concerns in connection with this Privacy Policy, or a complaint regarding the treatment of their personal information or a possible breach of their privacy, they can contact Ajen using the following methods:
Ajen Monitoring Systems Pty Ltd
31 Korong Road
Heidelberg West, VIC 3081
Phone: +61 (03) 8339 2062
Email: info@ajen.com.au; info@smartstartinterlocks.com.au
14. CHANGES TO OUR PRIVACY POLICY
This Privacy Policy is subject to change at any time. If Ajen changes this Privacy Policy, an updated version will be posted on our website to notify you of this change. By continuing to access our website or our services you will be deemed to have irrevocably accepted any changes to this Privacy Policy.
15. INTERPRETATION AND DEFINED TERMS
In this Privacy Policy, unless the context otherwise requires:
15.1. a term defined by Applicable Law has the same meaning when used in this Privacy Policy;
15.2. a reference to Ajen, we, our or us includes our Associated Entities.
15.3. the following words have the correspondence meaning:
15.3.1. Applicable Law means the Privacy Act, an approved privacy code (as defined in the Privacy Act) and any other State Law, statute, regulation or law in Australia relating to the protection of personally identifiable information, including health information, personal information and sensitive information that we must comply with;
15.3.2. Associated Entity means, collectively, our Related Bodies Corporate, authorised service agents and appointed contractors;
15.3.3. collect or collection includes, but is not limited to:
(a) recording what a person says, or recording an opinion about what a person has said;
(b) requiring a person to complete a form requesting details such as name, address, date of birth and health information; and
(c) keeping emails or other correspondence containing personal information about a person;
15.3.4. Privacy Act means the Privacy Act 1988 (Cth);
15.3.5. Regulatory Authority means a government or governmental, administrative, department, commission, authority, agency or entity whether state or territorial, in Australia which is responsible for the implementation, management or supervision of a State Program and includes:
(a) Transport for NSW (ABN 18 804 239 602) (Trading as Roads and Maritime Services);
(b) Roads Corporation (ABN 61 760 960 480) (Trading as VicRoads);
(c) Department of Transport and Main Roads (ABN 39 407 690 291) (Trading as TMR);
(d) Department of Infrastructure and Transport (ABN 92 366 288 135) (Trading as Department of Planning, Transport and Infrastructure);
(e) Department of Transport and Major Infrastructure (ABN 27 285 643 255) (Trading as Department of Transport);
(f) Northern Territory of Australia (ABN 84 085 734 992) (Trading as Department of Planning, Infrastructure and Logistics); and
(g) Access Canberra Territorial (ABN 16 479 763 216) (Trading as Access Canberra);
15.3.6. Related Bodies Corporate has the meaning given by the Corporations Act 2001 (Cth);
15.3.7. State Law means each statute applicable in a State or Territory of Australia relating to the protection of personally identifiable information, including health information, personal information and sensitive information that Ajen must comply with in connection with a State Program or otherwise, to the extent applicable includes the:
(a) Privacy and Personal Information Protection Act 1998 (NSW);
(b) Privacy and Data Protection Act 2014 (VIC);
(c) Information Privacy Act 2009 (QLD);
(d) Information Privacy Act 2014 (ACT);
(e) Information Act 2002 (NT); and
(f) Personal Information Protection Act 2004 (TAS);
15.3.8. State Program means an alcohol interlock program administrated by a Regulatory Authority in a state or territory of Australia in respect of which we provide related services to participants of, from time to time and includes the contractual arrangements entered into between a Regulatory Authority and Ajen in connection with that program.
16. FURTHER INFORMATION
Further information relating to privacy can be found at the Australian Federal Privacy Commissioner’s web-site: www.privacy.gov.au and through further resources provided by each Regulatory Authority. For information about how a Regulatory Authority collects, holds, uses and discloses personal information in connection with the applicable State Program, individuals should refer to the privacy policy published by the relevant Regulatory Authority.
Current version effective 5th August 2026.