RentAAA Customer Terms & Conditions and Privacy Policy

Application means the RentAAA Customer mobile application and related customer-facing portal features.

Customer Wallet means the payment profile associated with your RentAAA Customer account. It may allow you to add supported payment methods, establish payment authorities and view payment records. It does not hold a customer balance and is not a bank account, deposit account or stored-value facility.

Merchant means the independent rental or service provider with whom you book, rent or obtain goods or services.

Merchant Wallet means the Payment Provider’s settlement facility associated with a Merchant and administered through RentAAA for settlement, holds, transfers and payouts.

Payment Provider means an appointed third-party payment gateway, processor, financial institution or payment service provider.

RentAAA, we, us or our means Starr Group Pty Ltd trading as RentAAA.

These Terms govern your use of RentAAA Customer. The RentAAA Customer Wallet Policy governs Customer Wallet functionality. A Direct Debit Request, Direct Debit Service Agreement, PayTo agreement or other payment authority governs that payment method. If there is an inconsistency about a particular payment authority, the transaction-specific authority applies to that issue, followed by the RentAAA Customer Wallet Policy and then these Terms. Nothing in this priority rule limits rights that cannot lawfully be excluded.

RentAAA Customer and customer-facing portal features on Starr365.com are digital software services that help you interact with a participating Merchant before, during and after a hired vehicle, rental item, inventory, property, accommodation or other service supplied by that Merchant. Depending on the features enabled by the Merchant, the Application may allow you to:

• accept a Merchant invitation or scan a QR code;
• create and maintain a customer profile;
• upload identity or driver-licence documents and review extracted information;
• complete identity-verification steps;
• view bookings, rental documents, invoices, notices and payment status;
• sign documents electronically;
• record inspections, photographs, location or damage information;
• communicate with the Merchant; and
• Add payment details and make authorised payments.

RentAAA supplies the technology platform and provides access to payment services delivered through Payment Providers. Unless expressly stated otherwise, RentAAA is not:

• the Merchant, owner or supplier of the rented vehicle, property, item, goods or services;
• a party to your rental or service agreement with the Merchant;
• the Merchant of Record for the Merchant’s goods or services;
• a bank, insurer or financial adviser; or
• the holder of a customer stored-value balance.

The Merchant remains responsible for its goods and services, including availability, condition, safety, roadworthiness, lawful supply, pricing, deposits or bonds, insurance, cancellation terms, damage decisions, refunds and performance of the rental or service agreement.

Features may depend on the Merchant, your device, your region and third-party services. We may add, change or remove features for legal, security, provider or service-improvement reasons. We will give reasonable notice where a material change is likely to disadvantage you, unless urgent action is reasonably required.

RentAAA provides technology, software and related support services only. RentAAA does not own, supply, rent, lease, manage or control any vehicle, property, equipment, inventory, accommodation, goods or rental service offered by a Merchant, service provider or third party. All responsibility, liability and obligations relating to the rental item, inventory, product, service, pricing, availability, condition, safety, fulfilment, cancellation, refund, bond, deposit, damage, insurance, dispute or customer claim remain with the relevant Merchant, service provider or third party, subject to applicable law.

RentAAA is not a marketplace, rental agency or reseller. It provides software tools only. The Merchant remains responsible for its own rentals, services, customers, pricing, refunds, claims and disputes.

You must be at least 18 years old and legally capable of entering the relevant rental, service and payment arrangements. A Merchant may impose a higher age, licence, identity, deposit, insurance or eligibility requirement.

You must provide accurate, current information and must not impersonate another person. You must promptly update information that changes.

Keep your device, login credentials and one-time passcodes secure. Tell us promptly if you suspect unauthorised access. You are responsible for activity you authorise, but nothing in these Terms makes you responsible for an unauthorised transaction where Australian law or applicable payment rules give you a right to dispute it.

Your account is personal to you. You must not sell, transfer or allow another person to use it as their own.

Your rental or service agreement is with the Merchant. The Merchant determines amounts payable and the commercial terms applying to what it supplies. Read the Merchant’s agreement and policies before signing, collecting an item or making a payment.

Questions or disputes about the Merchant’s vehicle, property, goods, services, damage, bond, cancellation, refund or performance should be raised with the Merchant.

If an accident, damage or insurance matter arises, the Customer must deal directly with the Merchant, service provider or relevant insurer. RentAAA is a software provider only and does not assess insurance claims, decide fault, or provide vehicle, rental, accident, damage or claim records directly to an insurer at the Customer’s request. Any insurer request should be directed to the Merchant or service provider. RentAAA may disclose information only where required by law.

If a Merchant ceases trading, closes its business, becomes insolvent, sells its business, or is unable to provide the rental, goods, property, item, or service booked by you, the Merchant remains responsible for any unfulfilled services, refunds, claims, deposits, bonds, cancellations, and other obligations owed to you under your agreement with that Merchant and applicable Law. RentAAA is not responsible for supplying the Merchant’s services or paying the Merchant’s refund obligations, except to the extent required by applicable Law or caused by RentAAA’s own breach, processing error, negligence, fraud, or wilful misconduct.

The Merchant may use the RentAAA Platform to record, manage, nominate, recover or respond to tolls, fines, infringement notices, traffic notices, parking notices, road-user charges and related administration fees.

The Merchant is responsible for checking the relevant notice, booking, vehicle, driver and rental agreement before making any charge, nomination, declaration or recovery action. RentAAA provides platform and administrative support only. RentAAA does not decide who was driving, who is legally liable, whether an offence occurred, or whether a toll, fine or infringement should be disputed.

Any dispute about a toll, fine, infringement, nomination or charge must be raised with the Merchant or the relevant authority.

RentAAA remains responsible for its own obligations under these Terms and applicable law. Nothing in these Terms excludes responsibility that cannot lawfully be excluded.

A Customer Wallet may be established with your RentAAA Customer account. It is a payment profile and recordkeeping interface only. It does not contain money that you can hold, load, deposit, spend, transfer or withdraw. RentAAA integrates with appointed Payment Providers, which may include Zai, Stripe, Pay Advantage or other approved payment gateways. Customer funds are not held in, transferred to, or maintained in any bank account owned or controlled by RentAAA. It is created only to support payment methods, payment authorities, transaction records and payment status information connected with your Merchant transactions.

The Customer Wallet may display supported payment methods, payment mandates, transaction references, payment status, refunds or reversals. An amount displayed is a transaction record and is not a stored customer balance.

Payment details may be collected directly by a Payment Provider through an embedded or redirected payment interface. RentAAA may receive and retain limited payment-related information, such as tokens, masked details, mandate references, account identifiers, BSB or account number details where required, and transaction status information, only to the extent reasonably necessary to operate the Application, support payment records and comply with legal or provider requirements.

Customer Wallet functionality is governed by the RentAAA Customer Wallet Policy. Removing a payment method or closing a Customer Wallet does not cancel a completed payment, an amount already validly initiated, a rental agreement or an outstanding obligation to the Merchant.

A Customer may add more than one supported payment method to the Customer Wallet, such as Direct Debit, PayTo, PayID, debit card, credit card or any other method shown in the Application. Each payment method is separate and may be used as the Customer has given valid consent and authority for that method.

Payments: The Application allows you to make authorised payments to participating Merchants using supported methods, which may include Direct Debit, PayTo, PayID, debit cards, credit cards and other options presented in the Application. The Merchant determines amounts payable under your rental or service agreement.

Payment authorisation: By selecting a payment method and confirming a payment or mandate, you authorise RentAAA and the appointed Payment Provider to process the instruction, debit or charge the nominated method where applicable, receive settlement information and apply the payment to the relevant Merchant transaction. You confirm that you are authorised to use the selected method and that the information supplied is accurate and current. An authority applies only within its disclosed scope. A valid recurring authority may permit retries or subsequent payments in accordance with the authority and applicable payment rules.

If a payment fails, is declined or is dishonoured, the Customer may update the payment method or use another supported payment method. RentAAA or the Payment Provider may retry the failed payment or process payment through an available authorised payment method, in accordance with the Customer’s payment authority, Payment Provider rules and applicable law.

Merchant Wallet and settlement: Once a customer payment successfully settles, the underlying funds are maintained by the Payment Provider in its settlement account pending payout to the relevant Merchant. The corresponding amount is recorded in the Merchant Wallet supplied by the Payment Provider.

The Payment Provider, not RentAAA, maintains the underlying payment, settlement and payout accounts. RentAAA does not hold Customer or Merchant funds in its own bank account. RentAAA’s role is to provide the software interface and send operational instructions or requests to the Payment Provider, including payment submission, settlement status requests, holds, releases, refunds, reversals, deductions, transfers and payouts.

Payment status: The Application may display statuses such as In Queue, Sent to Bank, In Progress, Waiting Settlement, On Hold, Completed, Dishonoured, Reversed or Refunded. A pending or processing status does not mean that payment has completed. Status and banking timeframes may change while processing continues.

Direct Debit: Where offered, you may establish a Direct Debit authority through the Application. The arrangement is governed by a separate Direct Debit Request and Direct Debit Service Agreement presented during setup. Cancelling the authority stops future debits in accordance with the applicable process but does not cancel obligations owed to the Merchant.

Payment method setup fee: A Payment method setup fee may apply. The amount will be disclosed before setup is started. The setup fee is non-refundable.

PayTo, PayID and other methods: A PayTo agreement may require approval and may be managed through your banking channel. For PayID, use the destination and payment reference displayed in the Application. Incorrect references, amounts or destination details may delay matching or require assistance from your financial institution. Additional method-specific terms will be presented when applicable.

Card and bank-account information: Card payments are processed through appointed Payment Providers by the service provider. RentAAA does not store your complete debit or credit card number, card verification value or internet-banking credentials. Payment Providers may give RentAAA payment tokens, masked details, card type, expiry information, mandate status and transaction information.

Bank-account information entered for Direct Debit or another bank payment method is used for the relevant payment setup and processing. The collection interface will identify the Payment Provider and any information retained by RentAAA. Where bank-account information is retained by RentAAA, it will be protected using reasonable security measures.

Do not send complete card details or internet-banking credentials to RentAAA or a Merchant by email or ordinary messaging.

Fees and failed payments: Any RentAAA or Payment Provider fee payable by you, including a setup, processing or dishonour fee, will be disclosed before authorisation or in an accessible fee schedule. Your financial institution may charge separate fees outside RentAAA’s control.

If a payment is declined, dishonoured or returned, you may need to update your details or provide a separately authorised alternative method. RentAAA may retry a payment only within the scope of an existing valid authority and applicable payment rules.

Refunds, reversals and disputes: The Merchant generally determines refunds for its goods or services in accordance with the rental or service agreement and Australian Consumer Law. Where approved, a refund is ordinarily returned through the payment system to the original method, subject to provider and banking timeframes.

If you believe a payment was processed incorrectly or without your authority, notify the Merchant and contact your financial institution where appropriate. No reporting period in these Terms removes a right available under Australian law or applicable payment rules.

Payment records and security: RentAAA uses appointed Payment Providers and reasonable security measures to support payment transactions. Protect access to your device and financial accounts. RentAAA may retain transaction references, settlement information and related records where reasonably necessary for reconciliation, fraud prevention, support, audit, dispute resolution and legal compliance. The Payment Provider may provide RentAAA with transaction status, settlement amount, payout information, fee, refund, reversal, chargeback and related payment records through approved systems or reports so RentAAA can operate and support the Application.

For a permitted rental, identity-verification or fraud-prevention purpose, RentAAA may use an approved identity service provider or gateway to compare information from an identity document with information held by an official record holder or document issuer.

RentAAA will not initiate a Document Verification Service (DVS) check until you provide express consent through a separate consent statement presented during the verification process. We may record the wording accepted, account identifier, date and time, document version and verification reference as evidence of consent.

RentAAA will not provide the Merchant with direct DVS access or disclose the underlying DVS information-match result. The Merchant may receive an overall Identity Opinion based on DVS and other identity checks. The Identity Opinion is not a guarantee of identity, eligibility, creditworthiness or suitability. The Merchant remains responsible for its rental decision.

If DVS is unavailable, you decline consent or automated verification cannot be completed, RentAAA or the Merchant may offer manual document review or another lawful verification process. A booking or feature may be delayed or unavailable until an alternative process is completed.

You may request correction of inaccurate identity information or review of an Identity Opinion. RentAAA may conduct a manual review or request additional information. Restricted DVS results will not be disclosed where disclosure is prohibited.

The Application may request camera, photo-library, notification, precise-location or similar permissions when needed for a stated feature. We do not continuously monitor location or collect background location unless a separate notice is presented and the permission is enabled. You may withdraw device permission, although the related feature may stop working.

Optical character recognition may extract text from identity or rental documents. Check extracted information before confirming it. RentAAA does not create a facial-recognition or biometric identification template from uploaded images unless a separate notice is provided and any required consent is obtained. RentAAA may use OCR, document-reading technology and AI-assisted tools to read uploaded documents, extract information, structure data and prepare platform records. The Customer must check and correct extracted information before confirming it. RentAAA does not use AI-assisted tools to make final rental, payment, damage, insurance, approval, rejection or legal decisions.

You agree to receive agreements, notices, receipts and records electronically. Selecting an acceptance control, entering a one-time passcode or applying an electronic signature may evidence agreement. You may download or request a copy and may contact us about a reasonable alternative format.

You retain ownership of content you upload. You give RentAAA a limited, non-exclusive licence to host, copy, process, transmit and disclose that content only as reasonably necessary to provide and secure the service, support the rental workflow, comply with law, maintain records and resolve disputes. RentAAA will not use uploaded content for unrelated advertising or model training without a separate lawful basis and any consent required by law.

You must not use the Application unlawfully or fraudulently; bypass security; introduce malicious code; scrape data; interfere with another account; impersonate another person; upload unlawful, infringing or misleading material; or attempt unauthorised access.

You must have the right to provide any document, photograph, personal information or other content you upload.

We aim to provide reliable access but do not guarantee uninterrupted or error-free operation. We may suspend access where reasonably necessary for maintenance, security, suspected fraud, provider requirements, legal compliance or a material breach. Where practicable, we will provide notice and a reasonable opportunity to respond.

You may request closure of your account with your service provider and not with RentAAA. As such you have the rental or service relationship with merchant. RentAAA cannot independently accept or approve a request to close the Merchant’s customer account, cancel the Merchant’s records or end your rental relationship with the Merchant. If you contact RentAAA, we may direct or forward your request to the relevant Merchant where appropriate. Closure does not cancel a rental agreement, payment obligation, pending transaction, complaint or record that must lawfully be retained. We will handle personal information as described in Part B.

Nothing in these Terms excludes, restricts or modifies a guarantee, right or remedy that cannot lawfully be excluded, including under the Australian Consumer Law.

To the extent permitted by law, RentAAA is not responsible to the extent loss is caused by the Merchant’s goods, services, acts, omissions, representations, charges or performance; your bank or telecommunications provider; misuse of your account or device; or inaccurate information supplied by you or the Merchant.

Clause 11.2 does not limit RentAAA’s responsibility for its own breach, negligence, fraud or wilful misconduct, or liability that cannot lawfully be excluded or limited.

Contact the Merchant first about its goods or services. Contact RentAAA about the Application, Customer Wallet, identity verification or payment processing using section 28.

We will acknowledge complaints promptly, investigate fairly and aim to provide a substantive response within 30 days. If more time is reasonably required, we will explain why and provide an updated timeframe. Privacy complaints follow section 27.

These Terms are governed by the laws of New South Wales, Australia. Courts with jurisdiction may hear disputes, but this does not prevent you from relying on a right to bring proceedings elsewhere. The parties should first attempt to resolve a dispute in good faith.

A Customer may question or dispute a payment if they believe it is incorrect or unauthorised. However, if the payment was validly authorised, correctly processed and genuinely owed, and the Customer’s failed payment, dishonour, chargeback or unsupported dispute causes RentAAA, the Merchant or the Payment Provider to incur a bank, provider or dispute fee, the Customer may be required to reimburse that reasonable fee where permitted by applicable law.

We may update these Terms for legal, security, provider, product or operational reasons. We will publish the effective date and give reasonable advance notice by email, in-app message or another prominent method where a material change is likely to disadvantage you. We may ask you to accept a material change before further use.

An update does not retrospectively change a completed rental or payment without a lawful basis.

The RENTAAA name is an Australian registered trade mark of Starr Group Pty Ltd. All RentAAA software, websites, applications, platform content, designs, branding and related materials are owned by Starr Group Pty Ltd or its licensors and may be used only as permitted under these Terms.

This Part explains how RentAAA handles personal information through RentAAA Customer, Customer Wallet, customer-facing portal features and related support services in accordance with the Privacy Act 1988 (Cth), the Australian Privacy Principles and applicable law.

The Merchant separately handles personal information for its rental or service business and may have its own privacy policy. RentAAA handles information for its account, platform, security, support, identity and payment-facilitation purposes and may also process information for the Merchant through the Application.

Direct questions about the Merchant’s rental decisions, independent use of information or rental-record obligations to the Merchant. RentAAA remains responsible for information it handles for its own purposes and for complying with applicable obligations when providing the platform.

Depending on the features used, we may manage or view:

• name, contact details, email address, Physical address, phone number, date of birth and account details;
• Documents as per merchant requirements such as driver-licence, passport and other government-identifier information;
• booking, rental, vehicle, inventory, property, item, invoice and agreement information;
• electronic signatures, inspections, damage reports, photographs and precise location when enabled;
• communications with the Merchant and RentAAA, support records and complaints;
• payment-method type, payment tokens, masked payment details, mandates, transaction information, Customer Wallet and Merchant Wallet status relevant to your payment;
• consent, acceptance and audit records; and
• Device, browser, cookie, IP address, login, security and Application diagnostic information.
• Account holder name, BSB, account number, PayID details, payment references and other bank-payment details where required for Direct Debit, PayTo, PayID or other supported payment methods.

If a Customer provides payment details belonging to another person, such as a family member, friend or authorised account holder, the Customer must have that person’s permission to provide and use those details. RentAAA may process limited payment-related information about that payment method as required to operate the service, support payment records and comply with provider or legal requirements.

We collect information from you, your device, the Merchant, Payment Providers, identity and document-processing providers, your financial institution where the payment process permits, and other persons you authorise.

Information received from a financial institution is generally limited to mandate, payment, matching and settlement information—not your general banking history. If required information is not provided, the relevant account, rental, identity or payment feature may be unavailable.

RentAAA does not ordinarily collect sensitive information. If a feature requires sensitive information, we will explain the purpose and obtain consent where required by law.

We use or disclose government-related identifiers only where reasonably necessary for identity, eligibility, fraud prevention or rental-related purposes and as permitted by law. We do not use a government-related identifier as your RentAAA account identifier.

RentAAA may collect, use, store and disclose information required to support toll, fine, infringement, nomination, payment, recovery, dispute and audit workflows. This may include customer details, driver details, licence details, vehicle details, and registration number, booking dates, rental agreement details, toll records, infringement notices, payment records, documents, communications and audit logs.

This information may be shared with the Merchant, customer, driver, toll provider, infringement authority, payment provider, legal adviser, insurer, regulator or other relevant party where required or permitted by law, authorised by the Merchant, required for platform operation, or needed to protect legal rights.

We use personal information to:

• create, verify and secure accounts; connect you with the Merchant and support the rental workflow;
• support bookings, identity, licence, agreements, signatures, inspections and communications;
• establish payment profiles and authorities and process, match and reconcile payments;
• provide transaction status, receipts, refunds and support;
• detect fraud, misuse and security incidents; troubleshoot, analyse and improve the service;
• maintain records, enforce applicable terms and resolve disputes;
• comply with legal and provider requirements; and
• protect Customers, Merchants, RentAAA and other persons.

Where documents or images are uploaded, RentAAA may use OCR and AI-assisted tools to read, extract, structure and process information for platform use. This may include identity, licence, rental, agreement, inspection, damage and payment-related information. We use this to operate the Platform, reduce manual entry, support verification, maintain records, prevent fraud and provide support. Users should check extracted information before confirming it.

We may use aggregated or de-identified information for analytics, security, reporting and service improvement where individuals are not reasonably identifiable.

Payment Providers collect and process card, bank-account and payment-mandate information under their terms and privacy practices. RentAAA does not store complete card numbers, card verification values or internet-banking credentials.

RentAAA may retain payment tokens, Bank account details, masked identifiers, mandate status, payment type, amounts, dates, references, fees, refunds, reversals, chargebacks and reconciliation records.

The Customer Wallet does not contain a customer balance. Merchant settlement information may be displayed to you only to the extent needed to show the status of your payment.

With your express consent, RentAAA may provide your name, date of birth, and driver licence, passport or other identity document details to an approved DVS gateway or official record holder for the purpose of identity verification and fraud prevention in accordance with applicable law.

The Merchant receives only an overall Identity Opinion and not the underlying DVS information-match result. Credential details used solely for the DVS transaction are deleted after the permitted verification use. RentAAA may retain the consent record, transaction reference, permitted result, Identity Opinion, manual-review actions and audit records.

Licence or identity information separately required for a lawful rental record is handled for that separate purpose and is not treated as DVS information merely because it is the same type of information.

Declining DVS consent will not by itself close your RentAAA Customer account, but the relevant rental or identity feature may require manual verification or remain unavailable.

Access to the DVS environment and restricted match data is limited to authorised personnel in approved locations. Personnel outside approved locations, including overseas support personnel, must not access that environment or data unless expressly approved by the relevant DVS or identity-service manager.

We may disclose relevant information to:

• the Merchant and its authorised staff; Payment Providers, payment gateways and financial institutions;
• DVS gateways, official record holders, identity, optical-character-recognition and electronic-signature providers;
• hosting, cloud, communications, analytics, fraud-prevention and support providers;
• professional advisers, auditors, our insurers and legal representatives;
• regulators, courts and law-enforcement bodies where required or permitted by law;
• a prospective purchaser or successor to our business under appropriate confidentiality arrangements; and other persons you authorise.

RentAAA does not normally provide vehicle, rental, booking, damage, accident, location, payment or Merchant records directly to an insurer or third party at a Customer’s request. Any insurance or claim-related request should be directed to the relevant Merchant or service provider. RentAAA may disclose information only where required by law.

We disclose only information reasonably needed for the relevant purpose and use reasonable contractual, technical and organisational measures with service providers. RentAAA does not sell personal information for monetary payment.

Some support and technology providers may access or store personal information outside Australia.

We take reasonable steps required by Australian privacy law before disclosing personal information overseas. Overseas privacy laws may differ from Australian law.

Restricted DVS information is subject to the stricter access limitation in section 19.5.

Our websites and Application may use essential cookies, local storage, analytics and diagnostic tools to maintain sessions, remember settings, measure performance, detect abuse and improve the service. Where required, we provide choices for non-essential technologies.

A device-permission request will identify the relevant feature. Precise location is collected only when enabled and needed for a disclosed function. We do not collect background location without a separate notice and enabled permission.

We send operational messages needed for an account, payment, identity check or rental. We send direct marketing only where permitted by law. You may opt out using the message link or by contacting us, but essential operational and legal messages will continue.

We use reasonable administrative, technical and physical safeguards, which may include access controls, encryption, logging, backups, provider due diligence, staff confidentiality and incident-response procedures.

No internet service is completely secure. Protect your device and promptly report suspected account, payment or information-security incidents using section 28.

We retain personal information only while reasonably needed for the purposes described in this Policy, to follow lawful Merchant instructions, manage security and disputes, or comply with legal, tax, accounting, payment and audit obligations.

Financial, transaction and audit records may be retained for up to seven years where required or reasonably necessary. Identity images, driver-licence information and precise-location information are deleted or de-identified when no longer reasonably necessary, subject to lawful retention, fraud and dispute requirements. DVS information is subject to section 19.

You may request account deletion with your merchant only. We may delete or de-identify information where reasonably practicable but may retain limited records where required or permitted for fraud prevention, legal claims, payment reconciliation, audit or a Merchant’s lawful rental-record obligations. Protected backups are removed or overwritten through normal backup cycles.

You may request access to or correction of personal information held by RentAAA. We may need to verify your identity. If we refuse a request on a lawful ground, we will generally explain the reason and available complaint process.

Contact the Merchant for information it controls independently. You may ask RentAAA to review or correct an Identity Opinion as described in section 7.5.

We assess suspected privacy incidents and take containment, assessment and remediation steps. Where the Notifiable Data Breaches scheme applies, we will notify affected individuals and the Office of the Australian Information Commissioner as required by law.

Send a privacy request or complaint to the Privacy Officer. Include enough information for us to investigate. We will acknowledge it promptly and aim to provide a substantive response within 30 days. If more time is reasonably required, we will explain why and provide an updated timeframe.

Privacy Officer and Customer Support: Starr Group Pty Ltd trading as RentAAA, Email: [email protected], Website: https://rentaaa.com

We may update this Privacy Policy as our practices, providers or legal obligations change. We will publish the effective date and give prominent notice of material changes. Where a new use requires consent, we will request consent rather than relying only on an updated policy.