Effective date: 20 May 2026 Last reviewed: 20 May 2026 Version: 2.0

Ready Track Pty Ltd (ABN 64 166 623 981) trading as Linxio (“Linxio”, “we”, “us”, “our”) takes privacy seriously. This Privacy Policy explains how we collect, use, store, disclose and otherwise handle personal information in connection with our GPS tracking, fleet management, AI dash camera and related products (the “Service”), our website at linxio.com, and our other interactions with you.

This policy is designed to comply with the Privacy Act 1988 (Cth), the Australian Privacy Principles (the APPs), and applicable state and territory surveillance devices legislation. Where we deal with individuals located outside Australia, we also take account of the laws of those jurisdictions where they apply to us.

By using the Service, our website or our other products, you confirm that you have read this policy. If you are a driver, passenger or other individual whose data is collected through the Service operated by one of our customers, please also see the section titled “Drivers and other individuals whose data is captured through the Service” below.

If you do not agree with this policy, please stop using the Service and our website, and contact your fleet operator or contact us using the details at the end of this policy.

1. Who this policy applies to

The Service is sold to businesses (“Customers”) who deploy our hardware and software in their fleets to monitor vehicles, assets, drivers, and field operations. As a result, several groups of people are affected by how we handle data:

Customers are the businesses that hold contracts with us and operate the Service.
End Users are the individuals who log into the Service on behalf of a Customer, such as fleet managers, dispatchers, administrators and support staff.
Drivers and other individuals are the people whose location, behaviour, video, audio or other data is captured through devices installed in vehicles or assets that are managed by a Customer. These individuals usually do not have a direct relationship with us, and their relationship is with the Customer who operates the Service.
Website visitors are people who browse linxio.com, request a demo, sign up to the blog or otherwise interact with us through the website.

The way each group’s information is handled differs, and we explain this throughout the policy.

2. The information we collect

We collect several categories of information. Not all categories apply to every individual, and the data collected depends on the configuration of the Service and the products in use.

2.1 Customer and account information

When a Customer signs up, places an order, or sets up End Users, we collect:

Full name
Business name and ABN
Email address
Phone number
Job title or role
Billing and shipping address
Payment information (handled by our payment processor; we do not store full card numbers on our systems)
Account credentials such as usernames

2.2 Vehicle, asset and operational data

Through hardware installed in or attached to vehicles, machinery, trailers or other assets, the Service captures:

Vehicle make, model, registration, VIN and other identifying details
Odometer readings and engine hours
Fault codes, diagnostic data, battery voltage and other telematics
Fuel consumption and fuel transaction matching data (where fuel card integrations are enabled)
Sensor readings (for example, temperature, humidity, tyre pressure, door open or closed)
Geofence, route and trip information

2.3 Location and movement data

The Service continuously records GPS-based location data and derived information including:

Real-time coordinates, speed, heading and altitude
Trip start and end locations and times
Stop and idle events
Routes taken
Time spent at customer locations or sites
Entry to and exit from geofenced areas

2.4 Driver behaviour and identification data

Where the Service is configured to monitor driver behaviour, we capture:

Harsh braking, harsh acceleration, harsh cornering, speeding events and idling
Driver scorecard data derived from these events
Driver identification through driver ID fobs, NFC tags or login credentials
Where digital tachograph integrations are used: driver licence number, name, work and rest patterns, tachograph card information, calibration data, and other tachograph activity data
Driver allocations to vehicles and trips

2.5 Video and audio data (where dash camera Hardware is fitted)

Where a Customer has deployed Linxio Vision dash cameras or other camera Hardware, the Service captures and may transmit to the Linxio cloud:

Continuous or event-triggered video footage from road-facing and (where fitted) driver-facing cameras
Where the in-cabin camera is enabled, video footage of drivers, passengers and occupants
Where audio recording is enabled in compliance with applicable law, audio recordings from inside or near the vehicle
AI-derived events such as distracted driving, drowsiness, mobile phone use, seatbelt status, smoking detection, lane departure, forward collision warnings, headway monitoring and pedestrian detection
Still images extracted from video for safety reports, evidence and AI training

Audio recording inside vehicles is subject to state and territory surveillance devices legislation. Customers are responsible for ensuring that all required notifications and consents are in place before audio recording is enabled.

2.6 Communication and support data

When you contact us by email, phone, chat, support ticket or otherwise, we collect:

The content of your communications
Call recordings (where calls are recorded for quality or training purposes, in line with applicable law and with notification to the caller)
Support tickets, replies and any information you provide to us during a support interaction
Survey responses and feedback

2.7 Website and product usage data

When you visit linxio.com, log into the Service, or use our mobile applications, we collect:

IP address and approximate location derived from it
Device type, operating system, browser type and version
Pages viewed, time on page, click activity and referring URL
Search terms used on our website
Performance and error data
Information collected through cookies and similar technologies (see section 9)

2.8 Information from third parties

We also receive information about you from third parties, including:

Fuel card providers (where you have linked a fuel card to the Service)
Insurance brokers and providers (where we are working with them on your behalf)
Public sources such as ABN lookup, government registries and publicly available business data
Marketing partners and lead generation services
Our parent company Banyan Software and its affiliates for legitimate business purposes

3. How we use information

We use the information described above for the following purposes.

3.1 Providing and operating the Service

We use information to:

Set up and manage Customer accounts and End User access
Deliver the Service in accordance with our agreement with the Customer
Process orders, invoices and payments
Provide customer support, troubleshoot issues and respond to enquiries
Deliver hardware, schedule installations and arrange professional services
Send service-related communications such as outage notifications, hardware shipping updates and account notices

3.2 Improving the Service and developing new products

We use information to:

Monitor and improve the performance, reliability and security of the Service
Diagnose and resolve technical issues
Develop new features, modules and integrations
Carry out usability research, A/B testing and product analytics
Test, validate and quality-assure new releases

3.3 Training, developing and operating AI systems

We use information, including raw location data, driver behaviour data, telematics, sensor data, and video and audio footage from dash cameras, to train, validate, evaluate, fine-tune, operate and improve artificial intelligence and machine learning systems. These systems include:

AI features built into the Service such as driver risk scoring, predictive maintenance, route optimisation, automated incident detection, compliance monitoring and natural language reporting tools
AI models that power our Vision dash camera product, including models for distracted driving, drowsiness, lane departure, forward collision warning and other safety events
New AI products and capabilities that may or may not become part of the Service in the future
AI features developed for use within Linxio and within other businesses owned by our parent company, Banyan Software

Where we use video footage to train AI systems, we apply techniques to reduce the risk that individuals are identifiable in training datasets, including blurring of faces and licence plates where appropriate, and aggregation across many customers.

3.4 Creating and using Aggregated Data

We combine and de-identify data collected from many Customers to create “Aggregated Data”. Aggregated Data is data that has been combined, statistically processed or otherwise transformed so that it does not identify, and could not reasonably be used to identify, any individual, Customer, vehicle or specific business operation.

We use Aggregated Data to:

Generate industry benchmarks and reports (for example, average fleet fuel efficiency by region)
Identify trends in driver behaviour, road safety, vehicle reliability and operational efficiency
Develop and improve our products and our pricing
Share or license to research institutions, insurance providers, transport authorities, road safety bodies, industry associations, commercial partners and other third parties for their own purposes
Publish public research, white papers and marketing content

Aggregated Data does not identify you, the Customer, or any specific vehicle, and is not personal information once de-identified. We own all rights in Aggregated Data and may commercialise it without restriction.

3.5 Security and fraud prevention

We use information to:

Detect, investigate and prevent fraud, abuse, security incidents and breaches of our contracts and policies
Protect the safety and security of our systems, our staff, our Customers and the public
Verify identity and authenticate users
Investigate complaints, disputes and incidents

3.6 Marketing and communications

Where permitted by law, and subject to your right to opt out at any time, we use contact information to:

Send you marketing communications about Linxio products, features, offers and events
Personalise the marketing content you see on our website and on third-party platforms
Conduct market research and customer satisfaction surveys
Invite you to webinars, training sessions and partner events

You can opt out of marketing at any time by clicking the unsubscribe link in any email we send, or by contacting us using the details at the end of this policy. Opting out of marketing does not stop service-related communications such as billing notices, support replies and outage notifications.

3.7 Legal, regulatory and compliance purposes

We use information to:

Comply with our obligations under Australian law, including the Privacy Act, tax laws and the Notifiable Data Breaches scheme
Respond to lawful requests from courts, regulators, law enforcement and other public authorities
Establish, exercise or defend legal claims
Enforce our contracts, terms and policies
Cooperate with insurers, auditors and professional advisers

4. Legal grounds for processing

Where Australian law applies, we collect, hold, use and disclose personal information in accordance with the Privacy Act 1988 (Cth) and the APPs. Where laws of other jurisdictions apply to a specific individual or processing activity, we may also rely on the following grounds:

Performance of a contract: where processing is needed to deliver the Service to a Customer, manage End User access, or fulfil our obligations
Legitimate interests: where we have a genuine business reason, such as improving the Service, training AI systems, creating Aggregated Data, securing our systems, conducting marketing, and pursuing other business objectives, balanced against your rights
Legal obligation: where we are required by law to collect or share information
Consent: where required by law, such as for certain direct marketing activities or for sensitive information

If you wish to know which ground applies to a specific use of your information, please contact us using the details at the end of this policy.

5. Drivers and other individuals whose data is captured through the Service

If you are a driver, passenger or other individual whose data is being captured by the Service installed in a vehicle or asset, your direct relationship is with the business that operates that vehicle or asset (our Customer), not with Linxio.

The Customer is responsible for:

Telling you that the Service is installed
Explaining what data is captured, including any video or audio recording
Obtaining any consents required by law before capturing your data
Telling you who the data is shared with, including Linxio
Telling you how to exercise your privacy rights in relation to the Customer

This obligation is reflected in our contract with the Customer. We rely on the Customer to comply with it.

In most cases, you should raise privacy questions about the Service with your employer or with the business that operates the relevant vehicle. We are usually only able to act on instructions from the Customer in relation to data captured through their account. Where we are required to give you direct access to or correction of your information under Australian law, we will work with you and the Customer to do so.

For audio and video recording in vehicles, state and territory surveillance laws impose specific obligations, and the Customer is responsible for ensuring those obligations are met before the relevant feature is enabled.

6. Sharing your information with third parties

We share information with third parties in the categories below. We require these parties to handle personal information in accordance with applicable privacy laws and under appropriate contractual protections.

6.1 Service providers

We use third party service providers to help us deliver the Service. They have access to personal information only to the extent needed to perform their role, and are bound by confidentiality and data protection obligations. Categories include:

Cloud hosting and infrastructure providers, including Amazon Web Services
Database, storage and content delivery providers
IoT SIM card and telecommunications providers
AI and machine learning platform providers
Analytics and product usage tracking providers
Email, SMS and other communication providers
Customer support and helpdesk platforms
Payment processors and billing platforms
Identity, single sign-on and security providers
Endpoint protection and security operations providers
Backup and disaster recovery providers
Marketing automation, advertising and lead management platforms
Professional advisers such as lawyers, accountants and auditors

6.2 Integration partners

Where a Customer has enabled an integration with a third party product, we may exchange information with that third party as required to operate the integration. Examples include fuel card providers (such as WEX Motorpass and similar), accounting systems, electronic work diary providers, dispatch and route optimisation systems, and other telematics or logistics partners. The third party will handle the information under its own terms and privacy policy.

6.3 Banyan Software and its affiliates

Linxio is part of the Banyan Software group. We may share information with Banyan Software and its affiliated companies for legitimate business purposes, including shared infrastructure, security operations, AI development, group reporting, financial consolidation, and cross-company product development.

6.4 Research, insurance, government and commercial partners (Aggregated Data)

We may share or license Aggregated Data, in the form described in section 3.4, with research institutions, insurance providers, transport authorities, road safety bodies, industry associations and commercial partners. Aggregated Data is not personal information.

6.5 Legal, regulatory and law enforcement disclosures

We may disclose information where required or permitted by law, including in response to subpoenas, search warrants, court orders, regulatory requests and other lawful demands. We may also disclose information to investigate and respond to suspected breaches of law, our contracts or our policies.

6.6 Business transactions

If we, or any part of the Linxio business, is sold, merged, restructured, financed or transferred, your information may be transferred to the acquiring party as part of that transaction. Any acquiring party will be required to handle your information in accordance with applicable privacy laws.

7. Where your information is stored and processed

We host the core Linxio Service infrastructure in Amazon Web Services data centres located in Australia where reasonably possible. However, some service providers and integrations process personal information outside Australia, including in the United States, Europe and Asia. Examples include:

Email, SMS and customer support platforms
AI and machine learning service providers
Analytics platforms
Backup and disaster recovery infrastructure
Marketing automation and advertising platforms

Where personal information is transferred outside Australia, we take reasonable steps to ensure that recipients handle the information in accordance with the APPs or substantially similar protections, including through contractual safeguards.

8. Data retention

We hold personal information for as long as we need it to deliver the Service, run our business, and meet our legal and regulatory obligations. Specific retention periods depend on the data category:

Account and Customer records: for the term of the contract and for at least 7 years afterwards to meet financial, tax and other legal obligations
Telematics and location data: for as long as the Customer’s account is active, with historical access depending on the Customer’s subscription plan. After the account ends, retention follows our standard backup and archival cycles
Video and audio footage from dash cameras: typically for between 30 and 180 days in the active system, depending on the Customer’s configuration and storage plan. Specific safety events, incidents flagged by AI, or footage tagged by the Customer may be retained for longer
AI training data: data used to train, validate or evaluate AI systems may be retained in de-identified or aggregated form indefinitely for ongoing model development
Aggregated Data: retained indefinitely as it does not identify any individual
Marketing data: retained until you unsubscribe or for a period afterwards to honour your opt-out
Support communications: retained for a reasonable period to allow us to manage ongoing support and quality assurance

Where we no longer have a need to retain personal information, we will take reasonable steps to destroy it or to de-identify it.

9. Cookies and similar tracking technologies

Our website and the Service use cookies, pixels, tags and similar technologies to:

Operate the website and Service (essential cookies)
Remember preferences and login states
Measure how the website and Service are used (analytics)
Deliver and measure marketing campaigns

We use several third party platforms for these purposes, including Google Analytics 4, Google Tag Manager, Google Ads, Meta Pixel, Microsoft UET, LinkedIn Insight Tag and HubSpot. These platforms may set their own cookies and process information about your interactions with our website and ads.

You can control cookies through your browser settings. Blocking some cookies may affect website functionality.

10. How we protect information

We apply a range of technical and organisational measures to protect personal information from unauthorised access, loss, misuse, alteration and disclosure. These include:

Encryption of data in transit and at rest where reasonably practicable
Role-based access control across the Service and supporting systems
Multi-factor authentication for administrative access
Endpoint protection and identity management across our workforce
Secure software development practices and code review
Regular vulnerability scanning and security testing
Vendor risk management for service providers handling personal information
Staff training and policy controls
Incident response and breach notification procedures

We maintain an internal trust and security program covering policies, training and ongoing compliance. Customers may request information about our security posture through their account manager.

No security control is perfect. If you suspect that your information has been compromised, please contact us at [email protected] immediately.

11. Data breaches

If a data breach occurs that is likely to result in serious harm to affected individuals, we will notify the Office of the Australian Information Commissioner and affected individuals in accordance with the Notifiable Data Breaches scheme under the Privacy Act 1988 (Cth).

Where the breach affects data held on behalf of a Customer, we will also notify the Customer in accordance with our contractual obligations to assist the Customer in meeting any notification obligations they may have.

12. Your rights

Subject to applicable law, you may have the following rights in relation to your personal information.

12.1 Access

You can ask for a copy of the personal information we hold about you. We may charge a reasonable fee where allowed by law, and we may need to verify your identity before responding.

12.2 Correction

You can ask us to correct personal information that is inaccurate, out of date or incomplete.

12.3 Deletion

You can ask us to delete personal information about you. We may not be able to delete information that we are required to retain for legal, regulatory, contractual or security reasons. Where deletion is requested by an individual whose data is captured through a Customer’s account, we will usually direct the request through the Customer.

12.4 Withdrawing consent

Where we rely on your consent, you can withdraw it at any time. Withdrawal does not affect processing that has already taken place.

12.5 Opting out of marketing

You can opt out of marketing at any time by clicking the unsubscribe link in any marketing email, or by contacting us. Opting out of marketing does not stop service-related communications.

12.6 Making a complaint

If you believe we have handled your personal information in a way that breaches the Privacy Act or this policy, you can contact us using the details below. We will investigate and respond within a reasonable time.

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

Website: oaic.gov.au
Phone: 1300 363 992

12.7 Drivers and other individuals

If you are a driver or other individual whose data is captured through a Customer’s account, please see section 5. In most cases, your rights are exercised through the Customer that operates the Service, not directly with us.

13. Children

The Service and our website are not directed at children, and we do not knowingly collect personal information from children. If you believe that a child has provided us with personal information, please contact us and we will take reasonable steps to delete it.

14. Linked websites and third party content

Our website and Service may contain links to websites and content operated by third parties. We are not responsible for the privacy practices of those third parties. You should read their privacy policies before providing them with personal information.

15. Changes to this policy

We may update this policy from time to time, for example when we launch new features, change service providers, or to reflect changes in law. The updated policy will be published on linxio.com with a new “Effective date” at the top.

Where changes are material, we will take reasonable steps to bring them to the attention of Customers and End Users, such as by email or through an in-product notification. Your continued use of the Service after the new policy takes effect means you accept the updated terms.

You can ask us for previous versions of this policy at any time.

16. Contact us

If you have a question, request or complaint about this policy or our handling of personal information, please contact us:

Privacy Officer Ready Track Pty Ltd (ABN 64 166 623 981) trading as Linxio 104 / 22-36 Mountain St, Ultimo NSW 2007, Australia Email: [email protected]

For urgent security or incident-related matters, please mark your email “Security Incident” in the subject line.

17. Glossary

Aggregated Data means data derived from Customer Data (and the Customer Data of other Linxio customers) that has been combined, aggregated, statistically processed or otherwise transformed so that it does not identify, and could not reasonably be used to identify, any individual, Customer, vehicle or business operation.

AI Systems means any artificial intelligence, machine learning, predictive model, algorithmic system or related technology developed, operated or used by Linxio.

APP or Australian Privacy Principles means the principles set out in Schedule 1 of the Privacy Act 1988 (Cth).

Customer means a business that holds a contract with Linxio to use the Service.

Customer Data means all data generated, collected, captured, transmitted or stored through a Customer’s use of the Service, including telematics, location, behaviour, video and audio data and associated metadata.

End User means an individual authorised by a Customer to access the Service on the Customer’s behalf.

Personal information has the meaning given in the Privacy Act 1988 (Cth) and includes information or an opinion about an identified or reasonably identifiable individual.

Service means Linxio’s GPS tracking, fleet management, AI dash camera and related products and software, including any updates, enhancements and new modules.