RentAAA Pro Merchant Terms & Conditions and Privacy Policy

SaaS, payment facilitation and merchant administration terms

Starr Group Pty Ltd trading as RentAAA

RentAAA Pro Merchant Terms & Conditions and Privacy Policy

Effective date: 06 August 2026

Company: Starr Group Pty Ltd (ACN 637 444 798; ABN 98 637 444 798), trading as RentAAA.

Applies to: Merchants and authorised users of RentAAA Pro and related merchant portals.

Contact: [email protected]

These terms apply only to business users of RentAAA Pro. RentAAA Customer users and public website visitors are governed by separate documents.

Part A — RentAAA Pro Merchant Terms & Conditions

1. Agreement, Acceptance and Priority

1.1

These Terms constitute a legally binding agreement between RentAAA and the business entity or individual that creates a Merchant account, registers for, accesses, or uses the RentAAA Pro platform or any related services (Merchant). If these Terms are accepted by an individual on behalf of a Merchant, that individual confirms that they are at least 18 years old and have the authority to bind the Merchant.

1.2

The Merchant accepts these Terms by:

  • (a) creating a Merchant account;
  • (b) completing the merchant onboarding process;
  • (c) accepting these Terms electronically;
  • (d) accessing or using RentAAA Pro or any related services; or
  • (e) where the Merchant already uses RentAAA Pro, continuing to access or use the Services after RentAAA has provided reasonable notice that these Terms apply or have been updated.
1.3

The Merchant's agreement with RentAAA may include one or more of the following documents, as applicable:

  • these RentAAA Pro Merchant Terms;
  • any signed Merchant Software Services and Payment Facilitation Agreement;
  • the Merchant Payment Policy;
  • RentAAA Merchant Wallet Policy;
  • any transaction-specific Payment Provider terms expressly presented to and accepted by the Merchant; and
  • any other policies, guidelines or documents that these Terms expressly incorporate by reference.
1.4

Where a signed Merchant Software Services and Payment Facilitation Agreement or other written agreement exists between RentAAA and the Merchant, it prevails only to the extent that it expressly varies these Terms. The Merchant Payment Policy governs payment processing and settlement. RentAAA Merchant Wallet Policy governs the operation of the Merchant Wallet. These Terms govern all other matters relating to the Merchant's access to and use of RentAAA Pro and the Services.

1.5

A representative who accepts these Terms on behalf of a Merchant is not personally liable merely because they do so. Personal liability arises only where required by applicable law, results from that representative's own fraud, wilful misconduct or other unlawful conduct, or is expressly accepted under a separately executed personal guarantee or other written agreement.

2. Definitions

2.1

Customer means an individual or entity obtaining rental or other services from the Merchant.

2.2

Merchant Data means business information, Customer information and content uploaded to or generated through the Platform for the Merchant.

2.3

Merchant Services means the vehicles, properties, items, rentals, accommodation or other goods and services supplied by the Merchant.

2.4

Merchant Wallet means the Payment Provider’s settlement facility associated with the Merchant and administered through RentAAA.

2.5

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

2.6

Platform means RentAAA Pro, relevant merchant portals on RentAAA.com or Starr365.com, and associated software services supplied by RentAAA.

2.7

RentAAA means Starr Group Pty Ltd trading as RentAAA.

3. RentAAA’s role and services

3.1

RentAAA provides a cloud-based Software as a Service platform for rental and service businesses. Enabled modules may include inventory, bookings, Customers, agreements, inspections, invoicing, communications, recurring payment integrations, Customer Wallet profiles, Merchant Wallet administration, reporting and identity-verification workflows.

3.2

RentAAA is a non-exclusive technology and payment-administration provider. It does not own, lease, supply, rent, manage or control the Merchant’s inventory or Merchant Services and is not a party to rental or service agreements between the Merchant and its Customers. For clarity, Starr Group Pty Ltd and RentAAA provide technology, software, payment-administration and related support services only. All responsibility and liability for Merchant Services, inventory, rental items, pricing, availability, condition, safety, fulfilment, cancellation, refunds, deposits, bonds, damage, insurance, disputes and customer claims remains with the Merchant, subject to applicable law.

3.3

Payment processing, settlement-account services and related regulated services are supplied by independent Payment Providers. The Payment Provider maintains the underlying payment, settlement and payout accounts. RentAAA does not hold Customer or Merchant funds in its own bank account. RentAAA may, where authorised, send operational instructions to the Payment Provider through the Merchant Wallet, including instructions for holds, releases, transfers, payouts, refunds, reversals and authorised deductions. RentAAA’s administration of the Merchant Wallet does not mean RentAAA beneficially owns or physically holds the underlying funds.

3.4

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.

4. Licence and authorised users

4.1

During the subscription term, RentAAA grants the Merchant a limited, non-exclusive, non-transferable licence to access and use the Platform for its internal business operations in accordance with the agreement.

4.2

The Merchant may permit its employees and contractors to use the Platform as authorised users. The Merchant must assign appropriate access permissions, remove access promptly when no longer required and remain responsible for use under its account.

4.3

Login credentials must not be shared except through an approved multi-user function. The Merchant must notify RentAAA promptly of suspected unauthorised access or compromised credentials.

5. Order Forms, implementation and support

5.1

The applicable Order Form identifies the subscribed plan, modules, implementation work, minimum term, fees, usage limits and agreed special conditions.

5.2

The Merchant must provide timely information, decisions, system access and personnel reasonably needed for implementation. Dates dependent on the Merchant or a third party may be adjusted for delay outside RentAAA’s reasonable control.

5.3

RentAAA will provide support through its published or agreed channels. Unless expressly included in an Order Form, support does not include legal, tax, accounting, insurance, regulatory or business advice.

6. Merchant responsibilities

6.1

The Merchant is solely responsible for:

  • its Merchant Services and rental operations;
  • inventory ownership or authority, condition, safety, roadworthiness, maintenance and lawful supply;
  • pricing, deposits, bonds, insurance, refunds, cancellation terms, fines, tolls and damage decisions;
  • accurate descriptions, invoices, receipts and communications;
  • licences, registrations, permits, insurance, taxes and industry obligations;
  • its rental agreements, consumer disclosures and compliance with Australian Consumer Law; and
  • decisions made using Platform information, including rental eligibility and Identity Opinions.
6.2

The Merchant must provide accurate information, maintain appropriate records and use the Platform only for lawful business purposes.

6.3

The Merchant must not collect complete card numbers, card verification values, internet-banking credentials or other sensitive authentication data through email, ordinary messaging or unapproved Platform fields.

6.4

The Merchant must obtain the lawful notices, consents and payment authorities required for information and transactions it initiates. Where RentAAA presents a Customer notice, payment authority or DVS consent directly, the Merchant must not bypass, alter or misrepresent that process.

6.5

RentAAA provides toll, fine, infringement and nomination support as an optional add-on service where requested by the Merchant. The Merchant is responsible for checking and confirming all details before any request is submitted, including the notice, due date, vehicle, booking, driver, customer, rental agreement and supporting documents. The Merchant confirms that all information provided to RentAAA is true, complete, accurate, lawful and authorised.

6.6

The Merchant must provide the complete request to RentAAA at least 5 business days before the due date. Requests received after 2:00 PM AEST/AEDT, or on a weekend or public holiday, may be treated as received on the next business day. If the Merchant provides the request late, or provides incorrect, incomplete or unauthorised information, RentAAA will process it on a best-efforts basis only and does not guarantee completion before the due date.

6.7

The Merchant is responsible for any late fee, penalty, rejected nomination, overdue amount, customer dispute, driver claim or legal consequence caused by late, incorrect, incomplete or unauthorised information, unless the delay or error is directly caused by RentAAA’s own negligence, fraud, wilful misconduct or unreasonable processing delay after receiving a complete request on time. RentAAA does not decide who was driving, who is liable, whether an offence occurred, or whether a toll, fine or infringement should be disputed.

7. Customer relationships

7.1

Every rental or service contract is between the Merchant and its Customer. The Merchant is the supplier and ordinarily the Merchant of Record for Merchant Services.

7.2

The Merchant must resolve Customer issues about Merchant Services, including delivery, quality, cancellation, damage, bonds and refunds. RentAAA may assist with Platform records or technical processing but does not adjudicate the underlying commercial dispute.

7.3

If the Merchant ceases trading, becomes insolvent or cannot provide Merchant Services, the Merchant remains responsible for unfulfilled services, Customer claims and refunds, subject to applicable law.

8. Payment facilitation

8.1

Payment services are governed by the Merchant Payment Policy, RentAAA Merchant Wallet Policy, applicable Payment Provider terms and Customer payment authorities.

8.2

Customers may make one-time or recurring payments using Direct Debit, PayTo, PayID, cards or other supported methods. The Merchant must submit only legitimate amounts due under an identified rental or service agreement and within the Customer’s authority.

8.3

The Payment Provider maintains the underlying settlement account. The Merchant authorises RentAAA to administer the Merchant Wallet and exercise operational control over settlement funds, including holding funds by restricting their availability, releasing them, directing transfers and payouts, processing refunds, and deducting authorised fees, reversals, chargebacks and negative balances. For clarity, RentAAA’s administration of the Merchant Wallet means software-based and provider-approved operational control. It does not mean RentAAA beneficially owns or physically holds the underlying funds.

8.4

RentAAA does not guarantee successful collection, Customer solvency, uninterrupted processing, and protection from fraud or the outcome of a chargeback.

8.5

The Merchant must not represent that the Customer Wallet contains a customer balance. It is a payment profile and authorisation interface only.

9. Fees, invoicing and taxes

9.1

The Merchant must pay the subscription, implementation, transaction, processing, chargeback and other fees, the Platform or an applicable fee schedule. Unless stated otherwise, fees are exclusive of GST.

9.2

RentAAA may invoice fees or deduct them from the Merchant Wallet, settlement payouts or an authorised Merchant payment method as disclosed in the applicable policy or authority.

9.3

Subscription fees are non-refundable except required by law, or where RentAAA agrees to a pro-rata refund because it terminates for convenience or fails to provide a prepaid service for reasons within its reasonable control.

9.4

RentAAA may change recurring fees by giving at least 30 days’ notice. If a material increase takes effect during a fixed minimum term and is not caused by tax, law or a third-party provider cost expressly passed through, the Merchant may terminate the affected service before the increase takes effect without an early termination fee.

9.5

Overdue amounts are a debt due by the Merchant. RentAAA may use lawful recovery methods and recover reasonable external recovery costs to the extent permitted by law. Access may be suspended after reasonable notice where an undisputed amount remains overdue.

10. Privacy and Customer Data responsibilities

10.1

Each party must comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles where applicable, and other privacy laws applying to its activities.

10.2

The Merchant determines the purposes of its rental operations and remains responsible for the lawfulness, accuracy and necessity of Customer information it collects or instructs RentAAA to process.

10.3

RentAAA processes Merchant Data to provide, secure and support the Platform and also handles information for its own account administration, security, compliance, identity and payment-facilitation purposes as described in Part B.

10.4

The Merchant must provide appropriate privacy notices and must not instruct RentAAA to collect, use or disclose information unlawfully. Where the Merchant collects information for RentAAA, it must give any notice supplied by RentAAA without material alteration.

11. DVS and identity services

11.1

The Merchant may use identity-verification features only for its own permitted rental, fraud-prevention or identity-verification purpose and not as an agent for another business or as a standalone verification service for third parties.

11.2

A DVS check must not be initiated until the Customer has provided the express consent presented through the approved RentAAA journey. The Merchant must not attempt to bypass or pre-select consent.

11.3

The Merchant will not receive direct DVS access or the underlying information-match result. It may receive only an overall Identity Opinion based on DVS and other identity checks. The Merchant must not attempt to infer, reverse engineer or require disclosure of the DVS result.

11.4

An Identity Opinion is not a guarantee. The Merchant remains responsible for its rental decision and must provide a reasonable alternative process where automated verification is unavailable or cannot be completed.

11.5

The Merchant must cooperate with lawful Customer correction, review and complaint requests and with RentAAA audits or information requests relating to DVS compliance. It must restrict Identity Opinions and related information to authorised personnel with a genuine business need.

12. Security and incidents

12.1

Each party must maintain reasonable administrative, technical and organisational safeguards appropriate to the information and systems it controls.

12.2

The Merchant must promptly notify RentAAA of suspected unauthorised access, fraud, malware or a privacy incident affecting the Platform or Merchant Data. Where an incident may require coordinated action, each party will notify the other without undue delay and, where reasonably practicable, within 72 hours. This contractual notice does not determine whether notification to individuals or a regulator is legally required.

12.3

The parties will reasonably cooperate to contain, investigate, remediate and meet applicable notification obligations. Neither party may notify on behalf of the other without authority, except where required by law.

13. Merchant Data and intellectual property

13.1

As between the parties, the Merchant retains rights in Merchant Data and RentAAA retains all intellectual property rights in the Platform, documentation, configurations, templates and underlying technology.

13.2

The Merchant grants RentAAA a non-exclusive, worldwide, royalty-free licence to host, copy, process, transmit, back up and otherwise use Merchant Data only as reasonably necessary to provide, secure and improve the Platform, facilitate authorised payments and identity services, comply with law and provider requirements, prevent fraud, resolve disputes and enforce the agreement.

13.3

RentAAA may use aggregated or de-identified data for analytics, security, reporting and service improvement where neither the Merchant nor an individual is reasonably identifiable.

13.4

Feedback may be used by RentAAA without restriction provided it does not disclose the Merchant’s Confidential Information or personal information unlawfully.

14. Acceptable use

14.1

The Merchant and its users must not:

  • use the Platform unlawfully, deceptively or for fraudulent transactions;
  • access another customer’s systems or data without authority;
  • introduce malicious code or interfere with security or performance;
  • reverse engineer, decompile or copy the Platform except where law prohibits restriction;
  • scrape, resell or provide the Platform as a service bureau without written approval;
  • upload infringing, unlawful or misleading content; or
  • use payment or identity services outside their approved purpose.

15. Third-party services

15.1

The Platform may depend on Payment Providers, banks, hosting services, communications tools, app stores, identity providers and other third parties. Their services may be subject to separate terms and operational limits.

15.2

RentAAA will use reasonable care in selecting and managing providers but is not responsible for a third party to the extent the issue is outside RentAAA’s reasonable control. RentAAA remains responsible for its own selection, instructions and conduct as required by law and contract.

16. Availability and changes

16.1

RentAAA does not guarantee uninterrupted or error-free availability. Maintenance, provider failures, banking networks, internet outages, cyber incidents and events outside reasonable control may affect the Platform.

16.2

RentAAA will use reasonable efforts to restore material outages and will provide notices available from relevant providers where appropriate.

16.3

If a change materially reduces an included paid feature during a fixed term, the parties will work in good faith on a reasonable alternative. If none is available, the Merchant may terminate the materially affected feature and receive any refund required by the Order Form or law.

17. Confidentiality

17.1

Each party must protect the other’s non-public commercial, financial and technical information using reasonable care and use it only for the agreement.

17.2

Confidential Information may be disclosed to personnel, advisers and service providers who need it and are bound by confidentiality, or where required by law. This section does not restrict information that is public without breach, independently developed, or lawfully received without restriction.

18. Warranties and Australian Consumer Law

18.1

Each party warrants it has authority to enter the agreement. The Merchant warrants it has authority to provide Merchant Data and operate its business as contemplated.

18.2

Except for express commitments and rights that cannot be excluded, the Platform is provided on an “as available” basis. Nothing excludes, restricts or modifies a guarantee, right or remedy that cannot lawfully be excluded, including protections that may apply to eligible small businesses under Australian law.

19. Indemnity

19.1

The Merchant indemnifies RentAAA against direct loss, liability, penalty and reasonable external cost arising from the Merchant’s unlawful Merchant Services, breach of section 6, unauthorised transaction instructions, infringement by Merchant Data, or material breach of the agreement.

19.2

The indemnity is reduced to the extent loss is caused by RentAAA’s breach, negligence, fraud or wilful misconduct. RentAAA must take reasonable steps to mitigate loss and must allow the Merchant reasonable participation in the defence of a third-party claim.

20. Limitation of liability

20.1

Neither party is liable for indirect or consequential loss, loss of profit, revenue, goodwill or opportunity, except to the extent such exclusion is not permitted by law nor the loss arises from fraud or wilful misconduct.

20.2

To the extent permitted by law, RentAAA’s aggregate liability arising from the agreement is limited to the greater of AUD 10,000 and the fees paid or payable by the Merchant to RentAAA for the affected services in the 12 months preceding the event giving rise to the claim.

20.3

The limitation does not apply to fraud, wilful misconduct, breach of confidentiality, infringement of the other party’s intellectual property, or liability that cannot lawfully be limited. Where a statutory guarantee permits limitation, liability may be limited to resupply of the services or the reasonable cost of resupply.

21. Suspension and termination

21.1

RentAAA may suspend affected services where reasonably necessary to address security, fraud, unlawful conduct, excessive chargebacks, provider or regulator requirements, material breach or overdue undisputed amounts. Except where urgent action is required, RentAAA will give notice and a reasonable opportunity to respond or remedy.

21.2

Either party may terminate for material breach not remedied within 14 days after written notice, or immediately for an irremediable material breach, insolvency or unlawful use.

21.3

Either party may terminate this agreement for convenience in accordance with any notice period or minimum term expressly set out in a signed Merchant Software Services and Payment Facilitation Agreement. If no such signed agreement exists, or if it does not specify a notice period for termination, the Merchant may terminate these Terms and cease using the Services by giving at least 30 days' written notice to RentAAA, and RentAAA may terminate these Terms by giving the Merchant at least 60 days' written notice.

21.4

On termination, accrued fees, payment adjustments, confidentiality, privacy, intellectual property, indemnity and liability provisions survive as required. RentAAA will provide a reasonable opportunity to export Merchant Data, subject to security, lawful retention and payment of undisputed fees.

22. Changes to the agreement

22.1

RentAAA may update incorporated policies for legal, security, provider or operational reasons. It will give at least 30 days’ notice of a material change unless urgent legal, security or provider action requires a shorter period.

22.2

If a non-urgent change materially disadvantages the Merchant or increases its obligations, the Merchant may terminate the affected service before the change takes effect without an early termination fee. A change does not retrospectively alter completed transactions without a lawful basis.

23. Disputes, governing law and notices

23.1

A party raising a dispute must give reasonable details. Senior representatives will first attempt good-faith resolution. If unresolved after 14 days, either party may propose non-binding mediation in New South Wales before commencing proceedings, except for urgent relief or debt recovery for an undisputed amount.

23.2

The agreement is governed by New South Wales law. The parties submit to the non-exclusive jurisdiction of courts of New South Wales and competent appellate courts.

23.3

Notices may be given to the account contact or email provided. Legal notices to RentAAA may be sent to [email protected] and its address shown above.

24. General

24.1

The agreement does not create a partnership, employment, fiduciary or general agency relationship. The Merchant’s limited authorisation for RentAAA to administer payment instructions is governed by the Merchant Payment Policy and does not create a broader agency.

24.2

Neither party may assign the agreement without the other’s consent, not to be unreasonably withheld, except to an affiliate or as part of a genuine business reorganisation or sale where the assignee can perform the obligations. The Merchant must complete any provider re-onboarding required for a transfer.

24.3

If a provision is unenforceable, it is read down where possible and otherwise severed. Failure to enforce a right is not a waiver. Electronic counterparts and acceptance are permitted.

25. Trade mark and intellectual property

25.1

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.

Part B — RentAAA Pro Merchant Privacy Policy

26. Scope

26.1

This Part explains how RentAAA handles personal information about sole traders, directors, beneficial owners, employees, contractors, authorised users and contacts of Merchants through RentAAA Pro, merchant onboarding, support, payment facilitation and related services.

26.2

It also explains RentAAA’s role when processing Customer information through the Platform. The Merchant remains responsible for its independent privacy obligations and should maintain its own Customer-facing privacy policy.

27. Information we Manage

27.1

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

  • names, contact details, job titles, signatures and account credentials;
  • business name, ABN, ACN, addresses, registrations, ownership and controller information;
  • identity documents, director or beneficial-owner verification and compliance information;
  • Order Forms, subscriptions, invoices, billing and support records;
  • bank-account, payout, Payment Provider onboarding and Merchant Wallet information;
  • inventory, booking, rental, Customer, agreement, inspection, maintenance and communication records processed through the Platform;
  • device, browser, IP address, login, cookie, security and diagnostic information; and
  • Complaints, disputes, fraud, chargeback, audit and incident information.
27.2

We collect information from Merchant representatives, the Merchant, public business registers, authorised verification services, Payment Providers, financial institutions, professional advisers and other persons authorised by the Merchant.

27.3

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, 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.

28. How we use information

28.1

We use information to:

  • establish and administer Merchant accounts, subscriptions and authorised users;
  • verify the Merchant, controllers and representatives;
  • provide, configure, secure, support and improve the Platform;
  • facilitate Customer workflows, payments, Merchant Wallet administration and payouts;
  • provide identity services and Identity Opinions;
  • invoice, reconcile and recover properly payable amounts;
  • communicate service, security, legal and marketing information;
  • prevent fraud, manage risk and investigate incidents;
  • resolve disputes and maintain audit records; and
  • Comply with legal, tax, accounting, provider and regulatory requirements.

29. Customer information processed for Merchants

29.1

RentAAA processes Customer information on the Merchant’s instructions to provide rental-management workflows. RentAAA may also handle limited Customer information for its own security, account, identity, payment, compliance and support purposes, as disclosed in the RentAAA Customer Privacy Policy.

29.2

The Merchant must ensure its instructions are lawful, provide required notices and respond to Customer requests concerning information it controls. RentAAA will reasonably assist with access, correction, deletion, complaints and incidents where relevant to the Platform.

30. Payment and wallet information

30.1

Payment Providers process bank, card, settlement and payout information under their own terms and privacy practices. RentAAA does not store complete card numbers, card verification values or internet-banking credentials.

30.2

RentAAA may retain Payment Provider identifiers, masked details, payout-account information, mandates, transaction references, Merchant Wallet balances and statuses, fees, holds, reserves, refunds, reversals, chargebacks and reconciliation records. Some of this information may be received from Payment Providers through API integrations, dashboards, reports or other approved access channels.

31. Identity and DVS information

31.1

RentAAA may verify Merchant representatives and may provide approved Customer identity services. DVS information is handled only for permitted purposes, with required consent, access controls, logging and retention restrictions.

31.2

Merchants receive an Identity Opinion—not the underlying DVS match result. Credential details used solely for a DVS transaction are deleted after permitted use, while consent, permitted results, Identity Opinions, manual-review actions and audit records may be retained.

31.3

DVS environments and restricted match information are accessible only to authorised personnel in approved locations. Overseas personnel must not access them without required DVS or identity-service approval.

32. Disclosure

32.1

We may disclose relevant information to authorised Merchant users; Customers where necessary for their transactions; Payment Providers, banks and identity providers; hosting, cloud, communications, analytics and support providers; professional advisers, auditors and insurers; regulators, courts and law enforcement; a business successor under confidentiality; and other persons authorised by the Merchant or individual.

32.2

We do not sell personal information for monetary payment.

33. Overseas access and storage

33.1

Some support and technology providers may access or store personal information outside Australia, including in India. Other likely countries will be identified in a collection notice or updated country list where practicable.

33.2

We take reasonable steps required by Australian privacy law before disclosing personal information overseas. Restricted DVS information remains subject to section 31.3.

34. Cookies and marketing

34.1

RentAAA Pro and related sites may use essential cookies, local storage, analytics and diagnostic technologies for authentication, preferences, performance, security and service improvement. Choices for non-essential technologies will be provided where required.

34.2

We may send service, billing, security and legal communications. Marketing is sent only where permitted by law and may be opted out of through the message or by contacting us.

35. Security and data incidents

35.1

We use reasonable administrative, technical and physical safeguards, including role-based access, encryption where appropriate, logging, backups, provider due diligence, staff confidentiality and incident-response procedures.

35.2

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.

36. Retention

36.1

We retain information only while reasonably needed for the purposes described, to follow lawful Merchant instructions, resolve disputes, prevent fraud or meet legal, tax, accounting, provider and audit obligations.

36.2

Financial, transaction, payment-authority and audit records may be retained for up to seven years where required or reasonably necessary. Other information is deleted or de-identified when no longer required, subject to protected backup cycles and lawful holds.

37. Access, correction and account administration

37.1

Individuals may request access to or correction of personal information RentAAA holds about them. We may verify identity and may refuse only on a lawful ground, in which case we will generally explain the reason and complaint process.

37.2

The Merchant account administrator controls ordinary authorised-user access. Requests concerning Customer information controlled independently by the Merchant should be directed to the Merchant.

38. Privacy complaints & Contact

38.1

Send privacy questions or complaints to the Privacy Officer at [email protected]. We will acknowledge a complaint 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], [email protected], Website: https://RentAAA.com

39. Changes to this Privacy Policy

39.1

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