Privacy Policy
Last updated: 7 May 2026
This Privacy Policy describes how Emphire Pty Ltd (ABN 59 649 866 384),
trading as Empire Trailer Hire ("we", "us", "our"), collects,
uses, stores, and protects your personal information across the
products and services we provide:
- Empire Trailer Hire — booking system at https://empiretrailerhire.com,
used by customers to book and manage trailer hires.
- ETHLOK — a mobile application used by our authorised employees,
contractors, and maintenance technicians to manage Igloohome smart
locks on our trailer fleet.
This policy applies to both products. Part A covers what's
specific to the Empire Trailer Hire booking system. Part B
covers what's specific to the ETHLOK app. The remaining sections
(your rights, retention, complaints, etc.) apply to both.
We comply with the Privacy Act 1988 (Cth) and the Australian
Privacy Principles.
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Part A — Empire Trailer Hire booking system
This section covers personal information collected when you use
(https://empiretrailerhire.com) to book or manage a trailer hire.
A.1 What we collect
When you create an account, book a trailer, or use the booking
system, we collect:
- Account details — your name, email address, mobile phone
number.
- Verification details (driver's licence) — see A.4 below for
the full list.
- Payment information — processed by Stripe, our payment
service provider. Empire Trailer Hire does not see or store your
full card number; Stripe handles it under PCI-DSS Level 1
certification. We see only what's needed to reconcile your
booking (last four digits, brand, expiry).
- Booking history — your past, current, and upcoming hires
(trailer type, dates, location, status, amounts paid or
refunded).
- Communications history — emails and SMS we've sent you
relating to your bookings (confirmations, PIN delivery,
reminders, receipts), and your replies if any.
- Technical information — IP address, device type, and basic
browser fingerprint, captured for fraud prevention and security
on sign-in.
A.2 How we use it
We use this information to:
- Set up and authenticate your account.
- Process your bookings and payments.
- Verify your identity and driver's licence (a regulatory and
insurance requirement for trailer hire).
- Issue access codes (PINs) for the lock on your hired trailer.
- Send you booking-related messages — confirmations, reminders,
PIN delivery, receipts.
- Resolve issues with bookings or trailers, including investigating
damage or late returns.
- Comply with legal, tax, and insurance obligations.
- Improve the service over time, using aggregated and de-identified
data.
We do not use your information for advertising or marketing
unless you have given separate, opt-in consent.
A.3 How we share it
We share information only as required to operate the service:
- Payments — Stripe. Card data is collected directly by Stripe
on our checkout pages and processed under their privacy policy.
See [stripe.com/privacy](https://stripe.com/privacy).
- Other service providers under contract — including
infrastructure, communications, and verification processors.
These parties act only on our instructions, only for the purpose
we've engaged them, and are bound by confidentiality and data-
protection terms. We do not authorise them to use, retain, share,
or sell your information for any other purpose.
- Where required by law — for example, in response to a valid
court order or law-enforcement request.
We do not sell, rent, or trade your personal information.
A.4 Driver's licence verification
To rent a trailer, we need to confirm you hold a valid Australian
driver's licence. This is required for our insurance and for legal
liability. When you submit your licence for verification, we record:
- Your full name as printed on the licence
- Your date of birth
- Your driver's licence number
- The licence's expiry date
- The state or territory that issued it (e.g. QLD, NSW)
- The address printed on the licence
What happens to the photo. The photo of your licence is
processed at the moment you submit it and then immediately
discarded. We do not retain a copy.
The only exception is when your submission needs to be checked by a
member of our team — for example, if the photo is blurry, partial,
or unusual in a way our automated checks can't resolve. In that
case we keep the photo securely until the review is complete, and
automatically delete it as soon as the review is resolved. We never
keep a review photo for longer than seven days.
How we keep your licence data safe. Your driver's licence
number, date of birth, and address are encrypted at rest and are
not visible by default to anyone — including our own team — until
a specific authorised person actively requests to view them. Every
such access is logged with the staff member's identity, the time,
and where they accessed it from. Other licence details (your name,
expiry date, and issuing state) are stored normally on our
encrypted infrastructure and are visible to authorised staff during
the ordinary course of running your booking.
A.5 How long we keep it
We keep your account, booking, and verification records while your
account is active, plus the period required by Australian law for
tax and business records (currently seven years). After that period
your records are deleted unless we have a specific legal reason to
retain them longer.
You can ask us to delete your records sooner — see "Your rights"
in section 4 below.
---
Part B — ETHLOK mobile application
This section covers personal information collected when you use the
ETHLOK mobile application. ETHLOK is provided to authorised users
(employees, contractors, and maintenance technicians) for the
purpose of managing Igloohome smart locks deployed across our
trailer hire fleet. ETHLOK is not a customer-facing product.
B.1 What we collect
- Account information — your name, email address, and assigned
user role. Login credentials are stored in encrypted form only.
- Device information — device type, operating system version,
unique device identifier, and the Bluetooth identifiers required
to connect to Igloohome locks.
- Lock and usage data — lock identifiers and location
associations, sync logs, unlock events, timestamps, and activity
logs from paired Igloohome locks (e.g. access events, battery
status, firmware version).
- Diagnostic data — crash reports and basic usage analytics so
we can fix bugs and improve the App.
We do not collect payment information, contacts, photos, or
location data beyond what's needed to pair with a lock.
B.2 How we use it
- Authenticate authorised users.
- Enable Bluetooth communication with Igloohome smart locks.
- Maintain audit logs of lock access for security and compliance.
- Diagnose technical issues and improve the App.
- Comply with our legal and contractual obligations.
B.3 How we share it
- Igloohome — the lock hardware manufacturer. Lock activity is
necessarily synchronised with their servers because Igloohome's
hardware is the device the App talks to. Igloohome's privacy
practices are governed by their own privacy policy at
[igloohome.co](https://www.igloohome.co).
- Service providers under contract — including infrastructure
and crash-reporting providers, bound by confidentiality and
data-protection terms.
- Where required by law.
We do not sell, rent, or trade your information.
B.4 How long we keep it
We keep account and lock-activity data while you remain an
authorised user, plus up to seven years thereafter to meet
record-keeping obligations. Crash and diagnostic data is kept for
up to 90 days.
---
3. Data security (applies to both)
Your information is stored on secure servers with encryption in
transit (HTTPS / TLS) and at rest. Access is restricted to
authorised personnel on a need-to-know basis. Sensitive fields
(licence number, date of birth, address) carry an additional layer
of encryption-at-rest and are visible only when an authorised
person actively requests them, with each access logged.
While we take reasonable steps to protect your information, no
system is completely secure. You agree that you use our services at
your own risk subject to the rights and protections set out in
this policy and Australian law.
---
4. Your rights (applies to both)
Under the Privacy Act 1988 (Cth), you have the right to:
- Access the personal information we hold about you.
- Correct any inaccurate or out-of-date information.
- Request deletion of your information, subject to our legal
retention obligations described above.
- Make a complaint about how we've handled your information —
to us first, and then to the Office of the Australian Information
Commissioner (OAIC) at [oaic.gov.au](https://www.oaic.gov.au) if
you're not satisfied with our response.
To exercise any of these rights, email
[privacy@empiretrailerhire.com](mailto:privacy@empiretrailerhire.com).
We'll acknowledge your request within a reasonable time and
respond fully within 30 days.
---
5. Children's privacy
Neither the Empire Trailer Hire booking system nor the ETHLOK app
is directed at, or intended for use by, anyone under 18. We do not
knowingly collect information from minors. If you believe we hold
information about a minor, please contact us and we'll delete it.
---
6. Changes to this policy
We may update this Privacy Policy from time to time. The "Last
updated" date at the top reflects the current version. Material
changes — for example, a change in the kinds of data we collect or
who we share it with — will be communicated by email to active
account holders.
Continued use of our services after a change is published
constitutes acceptance of the revised policy.
---
7. Contact us
For privacy questions, complaints, or to exercise your rights:
Empire Trailer Hire (Emphire Pty Ltd)
Email: admin@empiretrailerhire.com)
Website: https://empiretrailerhire.com
If you are not satisfied with our response, you may contact the
Office of the Australian Information Commissioner (OAIC) at
[oaic.gov.au](https://www.oaic.gov.au).
